It depends what you consider to be the 'peak', but I think we've probably already seen the peak.
There was a spike in homebrew development when Ninjhax was released, but this seems to have petered out with much less active homebrew being developed. There are a handful of projects right now which are all interesting, but the nature of running homebrew on the 3DS makes it difficult to attract new homebrew developers. Requiring specific firmware versions, obscure games and/or expensive flashcarts means that many potential homebrew developers are probably eyeing formats with larger userbases.
This isn't helped by the fact that it is only going to become harder to obtain homebrew-capable 3DS hardware (i.e. 9.2 or below). An awful lot of stuff that could be used to open up the 3DS more isn't publically available due to concerns about piracy. Understandable concerns, but somewhat ironically driving people towards the Gateway flashcarts that they hate so much. The only other option is Cubic Ninja, which is roughly the same price of the aforementioned flashcart.
The Wii scene is actually more active at the moment, to be honest. I'd love to see the 3DS scene take off, but it's not easily accessible to new developers and that will continue to cripple the scene.