The Myopic Vision of Mr. Attorp…

Myopic

Def. “myopic” – shortsighted, narrow vision.

That aptly describes Mr. Frants Attorp’s Viewpoint article in the December 12, 2019 issue of the Gulf Islands Driftwood, titled “OCP survey suggested.”

I don’t know when Mr. Attorp moved to Salt Spring, but, I’m going to assume it was sometime after the 2008 OCP review, and, given his viewpoint, it is clear he either hasn’t studied the housing challenges this community faces, or, is in support of a lifestyle-of-the-rich-and-famous version of Salt Spring one hundred years from now.

In 2008, when the Trustees of the day lowered the densities available for amenity zoning from 100 to 40, they cut off the community’s nose to spite its face.

Like Mr. Attorp, those Trustees had not carefully considered the economics of real estate supply and demand as it applies to the future.

However, Mr. Attorp has the benefit of another 11 years of economic history to draw from, but has still failed to grasp reality.

Allow me to spell it out for him, and anyone who at this moment tends to agree with his perspective.

The lowest priced home on Salt Spring right now is $424,500. To qualify to purchase it, let’s say you can scrape together a 5% down payment of $21,225 and Property Purchase Tax $8,490, CMHC mortgage insurance of say $16,000, and closing costs of say $1,000 = $46,715.

Your mortgage will be $403,275, with monthly payments of about $2500.

Great you say, I can afford that because I’m already paying $2500/month in rent….however, now, to qualify under the current federal government lending regulations, you will need to qualify for the mortgage at 2% above prime.

The consequences of that qualification requirement mean you will need to have a combined family income of about $110,000…to purchase the lowest priced home on Salt Spring in December 2019.

Let’s take a look at some other current real estate realities.

The average price of a home for sale on Salt Spring at the moment is $1,025,000.

The median price of a home for sale on Salt Spring at the moment is $850,000…to qualify for a median home, with 5% down, you will need an annual income of about $190,000.

I will take all bets that house prices will be higher 5 years from now.

I’m hoping reality is setting in a bit.

And this is only 2019, not 2119…long after Mr. Attorp has left the planet.

That, in a nutshell should make anyone with a modicum of math skills understand that, unless radical measures are taken, this community as we know it, with the economic diversity which has given us such the cultural mosaic we currently cherish, will DIE…and, that’s what we are currently experiencing…the death of this community as we know it.

We live in arguably one of the nicest places in the world. It will not continue to go unnoticed as Vancouver, Victoria, Duncan and Nanaimo continue to develop into multi-level suburbias.

Mr. Attorp’s stated concerns would have us become a naturally gated/moated community of the rich and famous.

As a born and raised Salt Spring Islander, I’m going to continue to call bullshit on that vision…sorry…lack of vision.

The solution to our housing crisis, which is also the solution to creating a vibrant, diverse, sustainable community, requires a significant increase in density to achieve.

Who’s fault is the situation we now find ourselves in? You can lay that at the very entity charged with preserving and protecting this community – the Islands Trust. With the implementation of the Islands Trust Act in 1974, the dynamics of supply and demand were put into effect. The Trust limited the supply, while the demand grew. The population has about quadrupled since the Act came into effect.

While Mr. Attorp suggests Islands Trust Policy Statement may be violated if sufficient number of community housing densities, necessary to preserve and protect the community, are created, his alternative of basically “do-nothing-everything-is-all-right-Jack-because-I-already-can-afford-to-live-here” is, IMO, not only myopic, but, completely self-serving (in that his property value will continue to rise).

Mr. Attorp suggests “a detailed questionnaire (be sent) to every household outlining strategies for dealing with growth, people pressure and the climate crisis, all while emphasizing the limitations of living in a protected area.”

Great, but as well as all of the scare issues being sent to everyone, the challenges of housing, as it relates to the survivability of this community, should also be spelled out.

In essence this would be a vote for your choice of:

(a) Close down all development because we think we are incapable of dealing with issues, in spite of the fact dozens of other communities worldwide have met the same challenges, or

(b) Face our challenges and make the necessary, albeit difficult, changes required to ensure the community does not become another Martha’s Vineyard, Nantucket Island or Vale, Colorado.

Pick your choice….mine is (b).

Myopic 1

 

Disgrace of the Commons -Open Letter to CRD Director Gary Holman

Centennial Park, along with the Boardwalk, including the walkway around Gasoline Alley, has become a dog park, where smoking, drinking, vaping, swearing, pot/crack smoking, heroin injection, littering, and partying into the night are all too common events.

Centennial Park is supposedly the jewel of Ganges, where the world renowned Saturday Market attracts off-islanders.

It should be a place where families and children should be able to relax and play without being assaulted by the aforementioned activities.

The CRD is the authority over all of the areas (including the right of way around Gasoline Alley) and, has bylaws in place which are not being enforced.

The situation is not getting better. It is has not levelled out. It is getting worse.

Every business owner in the area is being affected.

It is time for our CRD Director, Gary Holman, and/or PARC, both of whom have the authority to have the bylaws enforced to act.

The park itself in the middle of summer is a disgrace as it has turns into a dust bowl due to not being watered, while the CRD pumps out 115,000 gallons of near drinkable water each and every into the harbor.

As I write this, the playground equipment is being replaced. It is time for the CRD to take the park back and gently move those who are abusing the space on to somewhere else – e.g. Peace Park seems like a reasonable compromise.

Mr. Holman, you’ve been dead set against incorporation for the past 20 years. Great. You won two years ago. Now FFS take responsibility for being the singular representative who can actually do something about this.

Come up with a plan, enact it, and do the job the community elected you to do.

The existing situation is a disgrace which is remediable. Remedy it.

 

 

Send in the Bailiff

BC’s Water Sustainability Act came into effect in 2015.

One of the Act’s prime purposes was to ensure that water is being used efficiently and responsibly.

Section 32 (2) allows for the government to appoint a “Water Bailiff” in cases where: ”

(2) If an engineer reports to the comptroller or a water manager that works used by more than one person are not being adequately repaired or maintained, the decision maker may appoint in writing one or more water bailiffs, set the terms and conditions of the appointments and give directions to the water bailiffs, including, without limitation, directions to

(a) operate and inspect the operation of specified works, and

(b) perform routine repairs on and maintain specified works.

In other words, if, as an example, an Improvement District, drawing water from a lake which had many other water licences on it, had leaks amounting to 19,000,000 gallons a year (25% of its withdrawal), and the works (pipeline supply) in question had not maintained to deal with the leaks, or that the reported leaks had not been investigated, the comptroller can appoint a Water Bailiff to remedy the leaks.

Given North Salt Spring Waterworks has not addressed the self-reported, annual, 25% leakage in the St. Mary Lake system since the Act became law, perhaps its time for the comptroller to send in the bailiff.

What’s the point of having a water conservation law if its not enforced against those who waste 19,000,000 gallons/year?

bailiff

The Sky Isn’t Falling Just Because November Rain Isn’t

The article in Driftwood’s December 4, 2019 issue (see below) would have the average reader alarmed…OMG it has stopped raining on Salt Spring and St. Mary Lake is really low!!

IMO, this just one more example of fear being used to manipulate the masses on the water issue.

First, here’s the article:

Driftwood NSSWD article December 4, 2019

So, let’s look at St. Mary Lake levels as of November 29th:

St. Mary Lake Water Levels November 2019

The first thing you’ll note is they are at the same level as last year (2018) at the same time, and, up until the middle of November, had been higher than 2009, 2015, 2017 and 2018.

Now, lets look at the precipitation for this year:

November 2019 St. Mary Precipitation

You’ll note we had more rain in September than the 5 previous years, and nearly twice as much rainfall than the 1981-2010 climate normal average. October was above “normal.”

Here’s the precipitation at St. Mary over the past 43 years:

Precipitation 1976-2018So, November this year was significantly below “normal,” but, does anyone truly believe, given the current lake level, and the likelihood of more rain in the next five months, that lake levels are concerning at this point in time?

I see the article as just another exaggeration in a series of exaggerations intended to make people believe we are in a crisis.

Now, take a look at this historic perspective of St. Mary Lake levels and ask the question, why on earth did NSSWD remove the beaver dam in 2006, and thereby reduce the volume of the lake in summer months by about 80-90,000,000 gallons? Unless you’ve been following this blog, you likely have never seen this analysis. (Data source – NSSWD)

Lake Levels Before and After

1998 OCP

OCP Volume 1

OCP Volume 2

 

Moratoriums Be Gone – The 80,000,000+ Gallon Question

The following is an open letter to the Board of Trustees of the North Salt Spring Waterworks District (NSSWD) Board.

Warning – The following contains an in-depth analysis of data and may lead to your eyes glazing over. If you feel signs of drowsiness, please skip to the Conclusion Questions section.

 

November 29, 2019

To – North Salt Spring Waterworks District Trustees Chris Dixon, Les Howell, Gary Gagne, Michael McAllister and Sandra Ungerson

Re – NSSWD Moratoriums

Dear Trustees,

North Salt Spring Waterworks District’s moratorium on water supply was “effectively” placed into effect in March 2014, when it did not approve water supply for the CRD’s Drake Road, 80 unit, affordable housing project.

On October 1, 2014 the Board officially declared a moratorium on any further applications until such time as the hydrology studies (were) completed and studied, a demand analysis completed, and other agencies consulted with.”

Lake Maxwell Moratorium

In April 2015 the detailed hydrology study, by engineering firm Kerr Wood Leidal, on Lake Maxwell (https://northsaltspringwaterworks.ca/wp-content/uploads/2018/03/Maxwell-Lake-Hydrology-Study-Final-2015.pdf) was received by the Board.

With respect to the Lake Maxwell system, the hydrology study concluded/recommended that the “withdrawal from the lake would have to be limited to 72% of the licenced withdrawal limit such that the lake could refill the year following the 10-year return period drought.”

Recommendations

Based on the outcome of the hydrological and water balance analysis carried out for Maxwell Lake, we recommend that:

  1. Withdrawals from Maxwell Lake be capped at 72% of the licenced withdrawal limit (477,900 m3) such that inflow from Larmour Creek, Rippon Creek and Maxwell Lake watersheds can refill Maxwell Lake after 10-year drought conditions;
  2. The cap should remain in-place until such time that sufficient data is collected at Maxwell Lake to complete a multi-year drought analysis;
  3. NSWWD consider installing water level sensors to record lake level, spillway outflow level and Rippon Creek Parshall flume level to provide continuous hydrometric records at the lake for operations purposes as well as to provide average daily record which can be used for future multiyear water balance assessment;
  4. Once sufficient data has been collected at Maxwell Lake, carry out a multi-year drought analysis to assess if multiple years of Larmour Creek, Rippon Creek and Maxwell Lake watershed inflow could refill Maxwell Lake after 10-year return period drought conditions; and
  5. Using hydrometric data collected; conduct a review of Maxwell Lake water balance at regular intervals (approximately every 10 years) to assess potential future impacts to water availability as a result of changing climate and changes in water withdrawal.

License and Withdrawals

The total water license on Lake Maxwell is 146,000,000 gallons per year (“GPY”).

72% of that is 105,123,303 GPY.

According to the 2015 hydrology study, from 2010-2013 the average “Bulk Withdrawal” (“BW”) which was withdrawn from the Lake was 73,126,011 GPY.

In 2013, the BW amount was 63,077,000 GPY which also included 15,674,426 gallons which were considered “losses.”

In other words, in 2013, only 47,402,574 gallons were “consumed” by ratepayers…the rest of the water leaked out of the system or was utilized for system functions such as flushing. The “consumption” or “metered” figures are based on how much water flows through each Ratepayer’s water meter.

Earlier this year (2019) NSSWD contracted with Westbrook Consulting an “Analysis of Potential Demand of Undeveloped Properties” ( https://northsaltspringwaterworks.ca/wp-content/uploads/2019/01/Analysis-of-Potential-Demand-from-Undeveloped-NSSWD-Properties-FINAL.pdf ) Its stated purpose was to estimate the additional water supply required to service 65 additional single family and multifamily properties in existence within the Lake Maxwell serviced area. That additional demand was calculated to be 2,347,530 GPY.

Analysis of Available Data

Which brings us to present day, and, my following analysis of the underlying, and updated, data for the Maxwell system.

I extracted the annual BW data for 2013-2018 from the studies and NSSWD’s annual audited water reports.( https://northsaltspringwaterworks.ca/water/annual-water-demand/ )

NSSWD Data - 2010 - 2018

I found the average BW’s has dropped significantly from 73,126,011 GPY in 2010-2013 (average 4 year as reported in the Kerr Wood Leidel 2015 Hydrology Study) to a 5 year average of just 50,085,220 GPY, in 2014-2018, and just 47,926,325 GPY in 2015-18.

Most of that drop was a result of a rather staggering, but pleasant, 14,025,309 gallon reduction in “losses.” (In 2013 losses were 15,674,426 GPY compared to just 1,649,117 GPY in 2018).

It was reported by Staff to the Board on December 17, 2014 that, “The control valve that was installed at the Ganges Hill tanks to eliminate tank overflow has reduced daily flows by 30 to 40,000 imp gallons/day. The crew has recorded flow below 100,000 imp gallons/day.”

Annualized, 30 to 40 thousand gallons equates to 10,950,000 to 14,600,000 GPY.

NOTE – This information, reported in December 2014, was not incorporated into the Kerr Leidal hydrology study, in spite of the fact the study would not be released for another 5 months (April 2015).

This drop in bulk withdrawal, due to the elimination of the tank overflow, logically alters significantly the findings and conclusions of the 2015 Keir Leidal Hydrology study, AND, the Islands Trust’s 2016 Opus Dayton Knight Water Conservation and Demand Management Plan for Salt Spring Island (the findings of which were rejected by NSSWD). https://islandstrust.files.wordpress.com/2019/11/opus-dayton-report-2016.pdf

I am going to assume the balance of any drop, in consumption, was/is due to water conservation measures being taken by ratepayers due to the implemented accelerated rate structure.

Earlier this year (2019) NSSWD contracted with Westbrook Consulting an “Analysis of Potential Demand of Undeveloped Properties”. Its stated purpose was to estimate the additional water supply required to service 65 additional single family and multifamily properties in existence within the Lake Maxwell serviced area. That additional demand was calculated to be 2,347,530 GPY.

I next calculated how much “head room” water supply was left after adding together the current average BW’s (50,085,220 GPY – 2014-2018 average) PLUS the calculated potential demand (2,347,530), = 52,432,750 GPY.

52,432,750 gallons represents ONLY 35.9% of the entire licensed amount.

In other words, the average, annual amount of water being taken out of Lake Maxwell, plus the calculated future demand equals just 35.9% of the amount NSSWD is licensed to take out of the lake. This means, that there is an additional 36.1% of water left BELOW the 72% recommended restriction.

The additional 36.1% is equal to 52,706,000 GPY.

Another way of looking at is that there is over TWICE the volume currently used, which is available BELOW the 72% recommended threshold.

The proposed housing developments on Drake Road (80 units), Kanaka Road (48 units), Croftonbrook (54 units), Meadowlane (48 units), Swanson Road (6 units), Rainbow Road (2 units), Lady Minto hospital expansion, Hastings House expansion, and/or laundromat in TOTAL would perhaps amount to an additional 6,000,000 gallons per year…which would still leave 46,700,000+ GPY in reserve BELOW the 72%.

The aforenoted reductions in bulk withdrawal provide the District with a significant safety factor.

Analysis of Lake Maxwell Water Levels

The aforementioned significant decreases in withdrawals since 2013 are also evident in the historical lake level measurements.

I have overlaid the 2014-2018 bulk withdrawal data with the lake level graph from NSSWD.

Maxwell Lake Level

As shown, the drop, in withdrawals, from 58M GPY in 2014 to 48M GPY in 2018 resulted in a significant increase in lake level from 2014 to present 2019 lake level, and, are significantly above 2009 levels.

In effect, the graph shows the positive effect of the 14,000,000+ gallon leak stoppage reported in 2014.

This is further observational evidence warranting the lifting of the moratorium.

St. Mary Lake System

Losses/Leakage

The 2001 Aqion Water Supply and Demand Analysis Study recommended the following actions be taken with respect to water losses from both Maxwell and St. Mary Lake systems (Note – at the time no data on losses was available from NSSWD for the St. Mary Lake system):

  1. Quantify annual flow volumes related to reservoir overflows
  2. Accumulate data on water main breaks including break frequency, pipe materials, pipe age, cause of failure, and other relevant information
  3. Replace the four aged meters in the distribution network that can no longer be calibrated
  4. Institute an annual calibration program for all water meters installed within the service area

Unfortunately St. Mary Lake losses (2013-2018) continue to hover around 25% of total BW from the lake. (2018 – 19,282,132 gallons = 26%). The amount which is lost per day is 52,827 gallons.

I am not aware of any professionally conducted acoustic leak detection study having ever been conducted on the St. Mary Lake system. The cost per mile of system, as sourced online, can be as little as $300. Assuming there is approximately 30 miles of main pipeline, the cost could be as low as $10,000 to have a study conducted. Even if it were 5 times that amount ($50,000) that cost would be recovered with just 5 new densities being created at $10,000+ Capital Expenditure Cost Charges.

The reduction of even ½ of the losses, would see about 10,000,000 gallon reduction of withdrawals, which would bring the total projected usage to about 50% of total licensed amount.

Maximum Daily Demand (MDD)

More good news. The MDD per capita has been falling significantly for the last 12 years as the combination of conservation and rate structure have taken effect.

That reduction in average per capita consumption, as shown from 2007 – 2015 is approximately 25%. Future reductions will continue as old toilets are replaced, and new construction meets higher water efficiency standards under the revised building code.

NSSWD MDD

Channel Ridge and Supply

Staff have previously made the statement that NSSWD has “guaranteed” each property in the district 550 gallons/day (2500 litres/day). The alleged rationale is that the Province (Ministry of Transportation and Infrastructure) “require” that amount as a condition of subdivision.

That is however not true for two primary reasons.

The following is from the Ministry’s Rural Subdivision Approval Manual http://www.th.gov.bc.ca/da/manual1/SubdivisionManual.pdf

2.3.1.01 Water Supply

Water Supply Regardless of parcel size, assurance of an adequate supply of potable water suitable for the proposed land use is required.

Water may be supplied from:

  • individual surface sources
  • individual wells
  • on site new water system
  • extension of an existing water system

If there is no subdivision bylaw regulating proof of water supply, the Approving Officer may require proof of 2500 litres [550 gallons] per day per dwelling unit, as well as a statement from a laboratory regarding the water’s quality.

If there is a subdivision bylaw regulating proof of water supply, the proposed subdivision must comply with it.

In general, the local government determines whether the proof of water supply requirements has been met. (See “Water Systems”)

Salt Spring Island Local Trust Committee Land Use Bylaw 355 includes, within the bylaw, subdivision requirements with respect to water. However, within those regulations is the following:

5.5.6 If the required amount of water cannot be supplied or if the certification, water license or confirmation referred to in Subsections 5.5.3, 5.5.4 or 5.5.5 cannot be made, the Approving Officer may nonetheless approve the subdivision if the applicant grants a covenant under the Land Title Act to the Salt Spring Island Local Trust Committee that restricts the development of the subdivision to the buildings, structures and uses for which the required amount of water can be supplied, licensed or certified under Subsections 5.5.3, 5.5.4 or 5.5.5.  

It is clear the Islands Trust allows the MOTI approving officer to “nonetheless approve the subdivision” in spite of a subdivision proposal not meeting the requirement for, as an example, the 1600 litres/day (350 gallons) for a single family residence required in Bylaw 355,

However, the important takeaway from this is that there is no Provincial requirement that an Improvement District MUST provide 550 gallons per day per lot on a continued basis.

Rainwater Catchment Volume Requirements for Subdivision or Construction

As to what alternative source of water an Approving Officer may accept for proof of adequate water supply, rainwater catchment has been recognized in BC as a proven source, and, in the Capital Regional District Area, which includes Salt Spring Island.

Relatively recently a subdivision of an island (with no source of water other than rainwater) within the CRD Area was approved based solely on the requirement to register on the title of each new lot, at the time of subdivision, a covenant requiring an engineered rainwater catchment system as a condition for acquiring a building permit for a residence.

The CRD Building Inspection on Salt Spring will accept a proposed engineered rainwater catchment system, with a minimum of 1500sf of catchment area, as proof of potable water supply for a residential dwelling building permit application.

The math underlying the acceptance of rainwater catchment has been overlooked by the Islands Trust and NSSWD.

1500sf x 3’ (approximate annual rainfall) = 4500 cubic feet of water x 6.22 gallons/cf = 28,000+gallons/year.

28,000gpy/365 days = 76 gallons per day.

CRD Water Districts

 

According to the CRD, the 6 smallest water districts within the CRD use an average of 60 gallons/day (271 litres) per residential connection/lot (NOT per occupant).

Water Consumption by smaller water districts within Southern Gulf Islands:

 

District Island Gallons per day per residential connection
Cedar Lane Salt Spring Island 356 L/day
Lyall Harbour/Boot Cove Saturna Island 315 L/day
Cedars of Tuam Salt Spring Island 287 L/day
Magic Lake Estates Pender Island 260 L/day
Surfside Mayne Island 220 L/day
Skana Mayne Island 190 L/day
Daily Average per Lot 271 L/day
   

Table 1                                   Source – Cedar Lane water service commission – 15 March 2010 – Annual Report on Operations (page 2)

 

Note – None of the districts have multi-family projects, and all lots are residential.

 

By accepting into policy that subdivision on Salt Spring could be approved by an Approving Officer on the CRD’s rainwater catchment requirements with as little as 76 gallons, then 100 gallons per day (approximate actual usage in St. Mary Lake system) would seem to be rational.

Differing Government Requirements for Water Supply

The differing requirements and actual water usage on Salt Spring are as follows:

  1. 550 gallons per day – NSSWD unwritten policy requirement (not in any NSSWD Bylaw)
  2. 350 gallons per day – Islands Trust for single family dwelling (rezoning or subdivision only)
  3. 123 gallons per day – Island Health/Ministry of Environment (225l x 2.5 residents) water license
  4. 108 gallons per day – NSSWD actual single family dwelling usage (2019 Demand Study)
  5. 96 gallons per day – NSSWD actual multi-family average usage (2019 Demand Study)
  6. 76 gallons per day – CRD rainwater catchment criteria used for subdivision and building permit (with storage)
  7. 60 gallons per day – average actual usage of 6 small water districts in Gulf Islands including two on Salt Spring

The fact that there are 7 different governmental volume requirements or actual usage statistics should give rise to discussion between the government entities.

Given CRD administers the Building Code of BC, and allows 76 gallons per day (with storage), it would be reasonable for future planning purposes, given the downward, per capita, trend in water usage reported by the District, that 100 gallons per day should be acceptable for new construction, given BC Building Code water conservation requirements.

Channel Ridge

As required volumes apply to the proposed Channel Ridge development, the existing, approved Master Development Permit was primarily approved for “building strata” units (duplexes/triplexes/quadplexes), which is NOT the subdivision of a property. A building strata is simply deposited at Land Titles and does not require the approval of a subdivision Approving Officer. The only water requirement falls to CRD at time of building permit application.

Taking the actual consumption rates from the 2019 Demand study, and applying them to Channel Ridge, which is proposed to be primarily multi-family units (MFD’s), the generalized math would be 410 units x 100 gallons per day (based on the actual 2017 usage of 108 gpd SFE and 96 MFD) = 41,000 gallons per day or about 14,000,000 GPY. That is in stark contrast to the 550 gallons per day suggested that is required = 82,307,500 GPY.

By bringing Channel Ridge back online, there is a potential for capturing approximately $3.0 million in CEC charges, which represent 60% of the estimated cost of raising the weir ($5.0 million).

Total Potential Withdrawal

By recognizing that current actual usage per SFE (100+GPD) is reasonable, NSSWD’s total annual BW from St. Mary Lake would be approximately:

6,790,168 GPY (2019 Potential Demand Study)

14,000,000+ GPY (Channel Ridge at 100 gpdu)

73,757,560 GPY Bulk Withdrawal (2017)

62,691,235 GPY Duck Creek Environmental Flow

-9,641,066+ GPY – Recapture of 50% of 2018 water loss through leak repair in system

150,906,723 GPY = 50.7% of licensed amount.

 

The “threshold” for withdrawal, as per the 2017 St. Mary Lake update report (Figure 4-2 below) for 95 out of 100 years is 50% of licensed amount which equals 132,253,750 gallons/year.

The additional 7% in the above scenario would potentially reduce the estimate to about 95+ out of 100 years.

You will note that the raising of the weir would not be necessary using the above scenario, since the potential yield in 95 out of 100 years is virtually identical.

NSSWD Potential Yield

 

St. Mary Data and Calculations

St. Mary Bulk Metered Loss Loss GPY
2013 85,053,860 62,297,983 27% 22,755,877
2014 86,074,311 64,945,923 25% 21,128,388
2015 73,256,778 56,670,008 23% 16,586,770
2016 80,619,250 56,159,761 30% 24,459,489
2017 73,757,560 54,825,530 26% 18,932,030
2018 74,229,220 54,947,088 26% 19,282,132
Average 2013-18 78,831,830 58,979,841
Buildout (2019 Demand Study) 5,024,724
Average 2013-18 83,856,554
Duck Creek 62,691,235
Total 146,547,789
Add Channel Ridge 14,000,000
Total 160,547,789
Recapture of 2018 50% Loss 9,641,066
Total projected use 150,906,723
NSSWD License 264,508,000
Percentage 57.05%
Recommended 70.40%
Buffer 13%
13% of License = Below 70.4% 34,386,040 GPY

 

Conclusions:

  1. current usage per SFE and MFD (96-108 gallons per day) is a reasonable amount to use to project future usage,
  2. total projected demand at current usage plus projected usage represents only 35.7% of total licensed amount of Lake Maxwell and 57% of St. Mary,
  3. a 95-98 year out of 100 year projection is within a reasonable margin of error,
  4. Mary Lake and Maxwell have sufficient supply to lift the moratorium,
  5. over the past 5 years the MDD per capita has been reduced by 25%,
  6. Lake Maxwell lake levels have increased during the summer months due to the leaks being decreased by 14,000,000 gallons per year.
  7. An acoustic leak detection survey of the St. Mary Lake system could be completed at relatively low cost, which could be recaptured through Capital Expenditure Cost charges, with potentially a significant reduction in bulk withdrawals,
  8. Ratepayers are facing significant increases in taxation as a result of planned upgrades and improvements and the Board should be actively working to allow increased densities in both systems in order to capture CEC charges to offset future proposed tax increases.

Questions Arising From Conclusions

In 2014, as Ratepayers, we were informed the moratorium would be in effect until, “hydrology studies (were) completed and studied, a demand analysis completed, and other agencies consulted with.”

Since then, the hydrology studies were completed and studied, a demand analysis has been performed, updates to St. Mary hydrology study completed, and other agencies have been consulted with. We now have sufficient data.

In addition, since 2014, 14,000,000+ gallons per year of losses have been turned into 14,000,000 gallons of additional available supply in the Maxwell system.

Over the past 5 years, as ratepayers, we have been led to believe there is insufficient water supply to service new development within the Maxwell system. This is in spite of over a 50,000,000+gallon buffer contained within the 2015 KWL hydrology study’s 72% threshold of licensed supply.

Over the past 5 years the MDD per capita has been reduced by 25%, Lake Maxwell lake levels have increased during the summer months.

The data clearly show we are using less than ½ of the 72% conservative recommendation for withdrawal, and that over 50,000,000 gallons are available for use.

As a result of the moratorium, the District has denied several dozen applications for service, including several housing proposals in Ganges. Those denials have resulted in (a) significant ($1.5-2.0 million) Capital Expenditure Cost revenue not being realized, and (b) significant parcel tax and water usage revenue not being captured ($30-40,000/year).

As a ratepayer I am left with the following questions:

  1. If the District, CONSERVATIVELY (considering the 72% recommended withdrawal limit), now has over 50 million gallons excess water supply, which is significantly more than reported in the 2015 Hydrology study, on what scientific basis, or study(ies), or findings or rationale, is there still a moratorium on the Lake Maxwell water supply, which includes almost all of Ganges (south of Country Grocer)?
  1. If, based on observed actual consumption rates (100GPD) St. Mary Lake has sufficient supply to project a 50%+ of license scenario, why is there still a moratorium on that system’s area?
  2. Does the NSSWD Board have a fiduciary duty to existing Ratepayers to:
    1. supply water to properties with development potential within the Maxwell system IF supply (below the 72% conservative threshold), is available?
    2. realize potential Capital Expenditure Cost charges of $1.5-2,000,000+ (150-200 affordable housing dwelling units, or hospital expansion, etc. all proposed within the Ganges area serviced by Lake Maxwell), which would help to offset costs to Ratepayers?
    3. increase tax roll revenue by providing service to 150-200 SFD equivalents ($30-40,000+ year), thereby reducing the existing tax burden on Ratepayers?
    4. offset planned/proposed (2022) Lake Maxwell system treatment (est. $5,000,000) with capturing CEC charges through the lifting of the moratorium?

 

The above evidence indicates the moratorium should/can now be lifted.

Thank you for your attention and I look forward to your response.

Eric Booth,

for Salt Spring Ventures Inc.,

NSSWD Ratepayer

ericbooth@shaw.ca

 

POST SCRIPT NOTES

  1.  $50,000 in legal fees is now budgeted for 2020…assume it is for the Channel Ridge lawsuit. (Source )
  2.  2020 parcel taxes up by 2% and in the range of $700/year average.
  3.  November 8, 2019 a Notice of Intention to Proceed was filed in the Channel Ridge Properties (Onni)/Paradigm Mortgage lawsuit against NSSWD/Salt Spring Local Trust Committee/Salt Spring Water Preservation Society. It appears the suit is moving forward at the moment.

Studied to Death…(and just one more comment about water availability.)

The issue of affordable housing has now literally been studied to death, with the last “affordable” (as per Islands Trust definition <$270,000) home on Salt Spring having been sold recently.

Over two dozen studies over about 30 years have been done on the subject. That would be a significant number of studies if they were talking about BC in general, but, I’m talking about Salt Spring and the Islands Trust Area.

The issue is now a joke…a bad joke…but a joke nonetheless. As real estate AND construction prices rise, both the Provincial and local government bureaucrats have failed to realize the magnitude of the issue, let alone address it sensibly.

The latest report that only 71 rental units of some 1500 planned have been completed Province wide because of delays (read regulations, red tape, lack of funding, etc.) only underscores the ridiculousness of government trying to fix what amounts to a market problem.

If the Province really wanted to “fix” the problem it would hire someone like Jimmy Pattison to set up a 3 person panel to administer funding to projects on a commercial appraisal basis. Have the proponent get a commercial appraiser to give an end value on a project and lend money based on an insured mortgage basis at the lowest possible interest rate the Province can get. Cut through the red tape.

On a local level, the Islands Trust should make blanket rezoning changes to allow affordable housing, instead of the one by one, death by a thousand rezonings process that currently plagues progress and infuriates each neighbourhood as the NIMBY card is played, usually by someone who has moved here in the last 20 years.

Its not good enough. It’s 2019 and planning for community housing should have started in 1974 with the passage of the Islands Trust Act. They have had 45 years to come up with a plan dealing with the effects of limiting a commodity in an area of high demand.

And While I’ve Got Your Ear, One More Comment About Availability of Water (in My Continuing Comments About Water)

The Islands Trust should get out of the water business entirely.

Remove ALL requirements for water servicing from the Land Use Bylaw and OCP, and replace them with a very simple covenant required to be placed on title at the time of rezoning or subdivision – “All buildings which require to be serviced by water must either prove availability of water from a source of water at a rate equal to or greater than the equivalent of a rainfall catchment area of 1500 square feet, with sufficient storage, if necessary, to meet BC Building Code requirements.” Period. Stop.

If a property owner can’t meet Building Code water requirements without building a rainwater catchment system (e.g. well, water system) then they have to build a catchment system to obtain their permit to build.

I repeat – The time to prove availability of water is not at rezoning, or even subdivision, but at the time of  building permit application.

A recent subdivision of an entire small island was approved on that basis by the CRD. All lots have rainwater catchment covenants on them because THERE WAS NO WATER ON THE ISLAND. You want to build on one of the lots you MUST submit your rainwater catchment plans with your permit application.

The idea that Islands Trust requirements for water somehow magically guarantee water will still be available in 20 years from now on any particular property isn’t a bet I would take. An earthquake could kill a well or a forest fire could result in sedimentation of the Maxwell watershed making the entire water system servicing Ganges unusable.

However, I would bet that 20 years from now it will still be raining here, and, that desalination will be as cost effective per gallon as any other source of water.

No one is going to die from dehydration here. Ditch the water requirements.

The next time someone tells you Salt Spring has a water problem put on your best shocked look and exclaim to them, “Oh my God…Did it stop raining at your place? Where do you live? How are you still alive? Can I get you some water?”

And yes, I know how sarcastic that sounds, but, there are still those who actually believe Salt Spring has a water problem. If you are one of them, I urge you to stand out in the rain for an hour or so and contemplate the above. The truth may just soak in.