My letter to staff regarding Housing Accelerator Fund MINORREV-2023-0106

HRM Housing Accelerator Fund Team
PO Box 1749
Halifax NS B3J 3A5

February 16, 2024

RE: Housing Accelerator Fund MINORREV-2023-01065

Dear Kate, Kasia, Josh, Byungjun and all the staff that worked on this,

Thank you so much for this hard work delivered on a very tight timeline over winter break.  This is an extraordinary amount of work, and you really must be applauded.

My response below should be read not as a criticism of this work, rather as input into a process that in its very nature will require revision and change.

I am writing today to share my thoughts as the elected official representing my district, the regional centre, and all HRM and to share what have learned about concerns raised by residents throughout the process.

I know that now is the time for bold changes to address the housing crisis, and after writing an explainer of the proposed changes I’ve certainly received a great deal of feedback.

I’ll start with a review of the direction of HRM Regional Centre Community Council, Federal Minister Fraser, and Regional Council.

On July 12, 2023 at Regional Centre Community Council, my motion suggested allowing both secondary and backyard suites in ER zones, rather than allowing either/or which would raise the unit counts for ER1 from 2 to 3, and ER2 from 3 to 4, and allowing internal conversions in ER2 and ER3 zones to 5 units, an allowing modest increases to the building envelope to accommodate fire escapes/secondary egress.

In addition, my motion called for strengthen controls to reduce impacts on neighbouring properties including but not limited to garbage screening, landscaping, and parking placement and enabling policy to allow affordable housing, cohousing, shared housing and similar forms of housing in a missing middle form in the ER-2 and ER-3 zones with a focus of ensuring compatibility with the built form of neighbouring residential uses.

On September 21, 2023, Federal Housing Minister Fraser wrote to ask HRM to consider legalizing 4 units as-of-right within the service boundary, legalizing dwellings up to 4-storeys high for all residential areas in the regional centre, creating a non-market affordable housing strategy with staff dedicated to it; and increasing density and student rentals within walking distance of the City’s first-rate postsecondary institutions.

On September 26, 2023 Halifax Regional Council directed staff to expedite amendments to the Regional Plan and supporting secondary planning strategies and land use by-laws, create a minimum of four units per lot in all residential zones within the urban service boundary.

It proposed changes in the Regional Centre to enable more missing middle housing, with a particular focus on smaller, faster building form and construction, and wood frame construction, while ensuring water supply and wastewater capacity is considered and existing and proposed heritage conservation areas are exempted, and to work with HRM post-secondary institutions to increase density and create opportunities for student housing within a walking distance from post-secondary institutions across HRM.

Analysis of Staff Proposal for HAF

Apart from the university areas and Fenwick CEN zone this is generally still true to what was proposed in the Centre Plan with the intensity dialed up with more height or units for density.  The proposal by and large reads as an increase in development allowed in the regional centre while still generally using the Centre Plan findings, mapping, zoning, design guidelines.

I don’t see this as walking away from Centre Plan. It’s what would have happened in the Center Plan eventually, but 25 years earlier than we thought we might need it, as we are now growing at an unprecedented rate.  Much of what is proposed in the rest of the serviced area, or suburban area, is logical and is the kind of thing that will flow from the suburban plan.

While this largely builds on the good work and community engagement done to get Centre Plan adopted there are some things I think should be changed, which I outline below.


While I support increasing the population in both the regional centre and the rest of the serviced area, it is important that the cost of infrastructure be acknowledged and quantified.

There are swaths of the suburbs, like Herring Cove Road and Bedford Highway, where the proposed rezoning for apartments makes sense, but the proposed road, sidewalk and bike infrastructure improvements need to be funded. There is risk in proceeding without the funding models being in place. Allowing a few buildings now may make sense to enable housing quickly, we need to speed up our assessment of infrastructure to support the Suburban Plan.

In the Centre Plan area some corridors and areas may not be appropriate to up zone now until infrastructure upgrades are in place, for example water and sewer in the Marlborough Woods neighbourhood.


Backyard suites should be integral and encouraged in the R and ER2 zones.  The zones should be written so that the small homes/ suites built on Stanley Street by Kerry Lynch would be allowed by right. As Kerry Lynch wrote on a LinkedIn Post:

Height is not the enemy, lack of diversity is. It shouldn’t be a choice between one or the other. The housing discussion is often led by height but there are clear benefits to secondary suites, missing middle, and invisible density:

  • Maintain walkable, human-scale streetscapes
  • Allow people to stay in their homes longer by generating income
  • Create flexibility to downsize to the secondary suite and rent the primary residence
  • Disperse vehicle congestion
  • Decrease clustered impact on municipal services; schools, fire, water, electrical, police
  • Avoid wind tunnels and shadowing resulting from height 
  • Lower financial risk related to development
  • Less development impact on neighbourhoods; excavation in days vs months (or years), no blasting or construction cranes or heavy truck traffic
  • Disperse wealth to homeowners from developers and keep it local
  • The land is free, no landbanking required
  • Services in place

The most notable is the speed of execution. Labour to execute both height and infill is the same, the upside is a backyard suite can be produced by modular and panelization in a fraction of the time. 

Smaller, smarter housing options can be move-in ready in 6 months instead of 6 years. The issue is urgent and a solution is needed now.

In addition to looking to spread out the impact on municipal services through gentler density, staff should conduct a review of how much scaling up would be required for municipal services, for transportation infrastructure, water and sewer, and transit.

By quantifying these costs, HRM can apply for confirmation that funding will be available from the Federal and Provincial government to help cover these significant costs prior to upzoning in these critical areas.


I support the increase in FAR proposed in the CEN and DD zones.

I propose the removal of the height limits from the CEN and DD zones, and allowing FAR and the design requirements to govern development here.  The focus on height is not useful in these intense zones.

I feel the design requirements are more than sufficient to allow this to work well.  We need to convince the province that these design requirements are essential to building complete, health communities.  The design criteria need to be defended so we don’t end up with later day Scotia Squares and Maritime Centres.

The additional height that may come will be a business decision, the first three stories will be well done if they meet the requirements and the tower separation, and setbacks are met to address the wind and sun concerns.

These increases in FAR will encourage faster development and more dwelling units per building.

I am gratified to see the Fenwick CEN zone which I have been supporting as a concept for some time. It is a solution to a number of issues that are coming with potential redevelopments of some of the larger lots and commercial spaces in that area.  My one concern is that the FARs should come down as the lots approach the proposed South Park HCD.  

For example, on South Street the WCB lot should be lower than the apartment lot which in turn should be lower than the Fenwick Tower property.  It is not a good idea to go from 40+ stories to a 3-story heritage district.


Absent from what I have seen so far (and there is a lot, I may have missed some) is a discussion of whether the proposed Future Growth nodes targets should be re-evaluated.  I note that the Dartmouth FGNs proposals are generally coming in higher than originally anticipated, and that is a good thing, but explicitly looking at population/unit targets for Robie/Young/Almon, Strawberry Hill, Halifax Shopping Centre and its Annex would inform our medium- and long-term supply of units.


I support the increase in height proposed for the COR and HR.  The design guidelines for COR and HR are strong and I think the designations are generally appropriate.

I understand and generally support the increased depth of the zone to allow faster development.

The one area of concern I have is around the universities which I address below.


During the creation of the Centre Plan we tried to make sure all the registered Heritage Properties were zoned to the envelope of what was already there.  I understand that staff intend to restore these buildings zoned to envelope.  All registered heritage (outside of the DH zone) should be zoned to ER2 8m or 11m.


What has been proposed around the universities is in some cases a substantial departure from both the Centre Plan and the Minister’s request.  There is a lot to think about here but what I think is lost is that 7-9 story HR2 zoning in what was previously ER1 will not result in fast changes driven by missing middle wood frame construction.

HR 7-9 stories is NOT missing middle.  Wood frame 3-4-5 flats that look like the podium of St Joseph’s Square on Gottingen, the classic riff off the “brownstone or brick walk up” is what I think we need here.

It is also important to note that the motion of council directed staff to “work with HRM post-secondary institutions to increase density and create opportunities for student housing within a walking distance from post-secondary institutions across HRM.”  This work has not yet happened in any meaningful way.  The level of upzoning proposed is not required by SMU to meet their undergraduate housing goals, for example.

The argument that larger taller buildings are required to have development happen at all are disproved by recent developments like the Capital at Coburg and Seymore, the 6345 Coburg, and the Seymore project show several recent 5-6 story buildings being successfully built, or the four story wood frame buildings at Brewery Park on Almon and Agricola.

The reason completes take three years now has more to do with complex large building forms than anything else. Missing middle is critical to faster unit completes.

I can see the merits and issues with all of it, and I want to address the four broad areas of upzoning:

  • Support for the expansion of the already existing HR and COR zones adjacent to Dalhousie on Oxford and Coburg, and the height increases.  We’ve had an extensive public engagement that already identified these lots as appropriate for these zones, and the proposed changes are in line with many of the developments already there (Coburg Tower, Le Marchant Tower, the Carlyle).  While this will be contentious for immediate neighbours, it is generally in line with the plan now.
  • Support the HR zone, but support a reduction of height on the blocks of Seymore, LeMarchant, Henry and Edward to match the six story heights to match the university plan, and the private six story developments already built.
  • Support for the zone change on Inglis backing Gorsebrook Park and proposed height limit, and support for a height increase for the HR zones the Wellington and Tower area at a 4-5 story limit
  • I cannot support the rezoning of Dalhousie/Beaufort South, South Street, Robie through to Marlborough, Tower through to Bridges and adjacent streets, and Gorsebrook through to Rogers to HR. The lots facing the universities should be upzoned to ER3 or HR uo to 3 stories on Gorsebrook, Tower, South (where currently proposed HR) and Robie south of Inglis. The zoning in area between Inglis/Ivanhoe/Atlantic should be firmly missing middle ER3, building on the success of missing middle developments like Lindola Place.  The lots on the streets behind the rest can be rezoned ER2 like the rest of the area (see below).


The proposal to rezone all of the Regional Centre to ER3 needs to be reconsidered.

I support the goal of four units in all zones in the serviced area, both regional centre and suburbs.

This proposal uses ER3 to provide everything from duplexes to small multis, and I don’t see how a single zone can provide good and consistent results.

It is important to note that we have not had true “R1” on the peninsula for over 50 years.  Since the 50s we’ve allowed internal conversions, and since the 70s in R2 HRM has allowed to turn a house into up to 6 units.  The late 70s/early 80s bylaws allowed 3 unit conversions in R1, and more units in R2.  The 2021 bylaw allows 1 unit + a suite, the ER2 allows 2 units + a suite. All zones in HRM already allow at least 2 units (house + suite).

There is no question that multis in “R” can and should be allowed throughout the regional centre, as they have been for generations.

The direction from the Minister and HRM’s own direction is 4 units in ER zones and R zones in the serviced areas.

The staff proposal is to apply the ER3 zone, possibly with modifications not yet public, to all residential zones in the Regional Center, and to allow bedrooms and units limited only by building code, while also increasing 50% and in some cast 60%  lot coverage, an increase of height to 12m. The zone would no longer provide a benefit or bonus to retain and expand a building by providing more units to an internal conversion.  Land assembly and lot consolidation would allow for small apartment buildings in ER zones.

This goes far beyond the Minister’s request for 4 units per building everywhere in HRM.

My feeling is the rush to deliver this proposal means that staff are applying ER3 with a broad brush due to lack of time for a deeper analysis.  Applying this across the regional centre is trying to use one tool to achieve a number of things in a way that it was not intended to do.  Four units, intensity in corridors, appropriate low rise missing middle apartments cannot be successfully applied to all of the Regional Centre using a single zone.

Upzoning to this degree generally means that the land owner will feel compelled to develop to the maximum allowed under the zone.  Wide open zoning in ER risks slowing new units, by turning potential developments away from infill, gentle density and conversions to land assembly, tear downs and new builds with the inevitable empty lots like we see on Robie.

Potential Changes to Approach – ER2 should be amended and applied across the regional Centre.  ER2 should allow more units and encourage backyard suites and small homes.  ER3 may be applied on all collector and arterials not already up zoned to HR and COR.  

To ensure HRM continues to meet the goals of the HAF funding I urge staff to consider implementing a broadened ER2 across the Regional Centre that allows the required four units.  My understanding is the ER2 changes to allow this are already proposed for the future Heritage Conservation Districts. Consider allowing increases to the building envelope to the lot coverage maximum in a way that preserves the look of character of these areas.  We’ve done this with mixed success in the Wellington/Tower area, and the lessons learned from the late 2010s R2A amendments can help guide this approach.

This is not to say that a higher intensity up zoning on corridors and arterials to ER3 or similar should not be considered.  It may be here that further relaxation of unit counts and bedroom limits may be considered. Further discussion is required about what form ER3, a possible ER4 or HR lite zone might take.  This does not have to happen on the HAF timeline.

Additional zones may be required – ER3 may not be the tool to ensure duplex, small homes, townhouses and quads and also multiplexes and small apartments. I am not against any of these forms. Simply put, we need to zone for what we want with more intention.  If we want Montreal style apartments, perhaps ER3 or some kind of ER4 should require that and not allow duplexes and single family homes.  If we want the most dense missing middle, we need to zone for that.

I think we need to have a much deeper dive where the lots are larger and the grid breaks down in the post-war suburbs (Connaught/ West End / North Dartmouth / Crichton Park / Manor Park / Penhorn Mall / Southdale etc).  I am concerned this cannot be done on timeline proposed, and if necessary ER2 should be applied now with the increased unit count and lot coverage changes, and we should come back for a “Package B” discussion to make sure we don’t make changes now we regret later.  That said, there are areas where the very large lots and smaller post war homes may require a modified approach to unlock the potential of these neighbourhoods for density and more dwelling units.

ER2 should be changed to four units + a backyard suite, and the current front, back and side yard setbacks, and height limits of the zone should be maintained. These limits may be relaxed if certain conditions are met when retaining and expanding an existing building. Lot coverage should be relaxed as laid out in the proposal.  ER2 requires tighter controls in proposed heritage districts. (edit) Bedroom counts should be maintained.

ER3 or HR should be applied to remaining corridors and arterials, with modest height limits of 3-4 stories.

Larger multis that fit the neighborhood as I suggested in my motion of July 2023 could be allowed by DA for appropriate uses (seniors homes, affordable housing, special care).

The intensity of upzoning suburban R zones should be less than we consider in the regional centre.  Two units + 2 basement or back yard suites would be sufficient for our goals.


These proposed changes raise once again real, recurring and as yet unaddressed concerns in the Regional Centre.

Beyond zoning change, is a general lack of confidence in HRM from longer-term/more permanent residents in the City’s ability to manage smaller rental units especially near universities. HRM needs to invest in proactive compliance of noise, garbage, parking, and unsightly premises bylaws, among other things. Further, HRM needs to encourage or require small property owners to reinvest in their properties and to effectively manage them.

At present, many of the student rentals are in poor condition, in part because any reinvestment or upgrade leads to increased property tax for landlords. Much of the opposition to zoning change in university districts also reflects some degree of opposition to students and student dwellings, which are not effectively managed by HRM at this time; the concern amounts to a zoning change that moves our neighbourhoods closer to becoming student enclaves.

The modifications that staff have spoken about related to M200 and the noise bylaw, and a better managed and resources enforcement plan need to come hand in hand with whatever changes Council subsequently approves.  I encourage the CAO to bring an amendment package forward immediately.

Finally, some form of empty lot/demolition control needs to come hand in hand with this proposal, combined with some kind of inclusionary zoning program in place, to help minimize reduction of units in the short term through land banking, and replacement of affordable units with similar.


We heard on February 13 during the Planning and Development budget presentation that to meet the requirements of HAF funding we cannot delay, and I support moving forward as quickly as possible.

I accept that at face value, but there are two separate goals here – the first ensuring we meet the requirements requested by the Minister, and second a general increase in intensity for the Centre and suburban plans.

Much of the latter goal can be met during the HAF process, but there are going to be issues and pain points that go beyond the HAF request and simply do require more examination and public engagement to get them right. I urge staff to set those aside for deeper examination rather than try to get all of this done at once with the risks that entails.

Thank you again for all your hard work on this file, it really is impressive.  I look forward to the next steps!

Waye Mason
Councillor | Le Conseiller | Comhairlaiche | Wunaqapeme’j
District 7 – Halifax South Downtown
Halifax Regional Municipality

Cell      902.430.7822