Letter from District of Highlands Re: RGS Bylaw Public Hearing Comments

Re: Regional Growth Strategy Bylaw Public Hearing – District of Highlands’ Comments

District of Highlands Council considered the draft RGS at its meetings of October 11 and 17, 2016, and wishes to provide input to the RGS Bylaw Public Hearing, which is scheduled for October 19, 2016.

• The District of Highlands cares about the region. It believes in regional resilience, active and strong growth management, and comprehensive climate adaptation.
• There is appreciation for the Board’s response to the District of Highlands’ earlier comments through the addition of the water servicing policy. The District ultimately prefers to maintain the current (2003) RGS policy framework for water servicing. This is consistent with draft RGS’ goals for climate change.
• There may be an opportunity to investigate a compromise regarding allowing piped water servicing to Kemp Lake / Shirley.
• At this point, Highlands Council is not supportive of the RGS as written.

Rationale Supporting Strong Growth Containment through Control of Piped Water Service

Generally speaking:

• The use of piped water fosters a change in attitude with regards to land use policy protecting the quality and quantity of aquifer resources.
• The cumulative effect of piped water dependence is a society that is less resilient to major disaster events. This impacts all CRD communities.
• The right to “clean/potable” water is not the right to “piped” water.
• Installing infrastructure in areas with low density is not a good use of regional funds and all of the CRD will face increasing costs of maintenance of the water system due to expanding piped water coverage.
• The 2003 RGS was a stronger tool to support managed growth for the benefit of the entire region.
• Incremental sprawl affects biodiversity and fundamentally negates the value of an RGS

In regards to water service past Shirley:

Policies 2.2 (2) and 2.2 (4), on the surface only, attempt to control growth through limiting water services. However, they will not, in fact, accomplish growth management, especially in regards to the Private Managed Forest Lands (PMFL) and Renewable Resource Land Policy Area:

• Why would piped water be extended to help forests grow? This rationale for piped water extension reduces confidence in the rest of the reasoning behind the water servicing arguments.
• These policies promote development. They appear to only support low residential density, but will inevitably result in increasing the residential density to cover the up-front costs of extending the infrastructure.
• PMFL is a provincial designation that can be changed by simply paying a fee. The result will be that these lands will then be vulnerable to residential development at a land owner’s will. This is precisely the situation regional growth strategies are meant to prevent. This potential result will, in the long term, financially affect the entire CRD, in that the long term maintenance – and repair because the larger system is now more vulnerable – of the extended water lines will be subsidized by other CRD communities. In the end, the region will be less resilient to the reality of climate change. The policies as written are set up to create a similar situation with respect to lands within the Agricultural Land Reserve.
• Having water infrastructure in rural, low populated areas along routes that are prone to impacts from excessive rains puts the infrastructure of the entire interconnected system at risk. All costs of repair and maintenance and upgrades are born by CRD rate payers as a whole... bulk water rates will rise.
• What are other options for a community water service or system to Jordan River? A stand-alone system?
• Policy 2.2 (6) lacks clarity and risks approval of water extensions for the wrong reasons.
• From a regional cooperation perspective, the proposed water servicing policy is likely to expand confrontation within the CRD including the subcommittees, as well as within and among the various regional water supply commissions. There is already concern about the cost of the bulk water rate, and if services are extended, regular repairs, maintenance and upgrades will come at the expense of other local governments.

Yours truly on behalf of Highlands Council,

Laura Beckett, MURP, MCIP, RPP Municipal Planner / Approving Officer

LB/lc

cc: RGS Member Municipalities