RAR Mapping? What Price Accuracy?
April 10, 2011 1 Comment
RAR – Why Is There No Accurate RAR Mapping of Salt Spring?
April 7, 2011 Address to Local Trust Committee
Thank you Madame Chair
I am addressing two issues involving the proposed changes to the Development Permit Area 4.
First, with regard to the recently drafted RAR amendments to the OCP which you are considering today, I am presenting you today with a detailed opinion which shows that contrary to what the LTC has perhaps been advised by Islands Trust staff and/or the Ministry of Environment, the LTC does not have to amend the Development Permit Area provisions of the OCP in order to meet the RAR policy directive from the Province.
The opinion clearly explains the basis on which the currently existing Development Permit provisions and setbacks meet the requirements of the Riparian Area Regulations and, contrary to what the public has been led to believe, shows how the LTC has a discretionary choice as to whether it wishes to proceed with the proposed RAR OCP amendments or not.
As you know, under the Local Government Act, OCP amendments must go through a thorough public process, and, in order to come to a proper, informed opinion, it is imperative the public not be misled or misinformed during that process. To date the public has been led to believe amendments must be made to the OCP in order to be compliant with the RAR.
As I believe you will find, nothing needs to be done and no amendments are necessary to be compliant. Until such time as the LTC has had a chance to thoroughly review the opinion, it is my highest recommendation that you proceed with caution in any further public pronouncements that changes to the OCP are necessary to comply with the RAR.
Secondly, I am here to formally ask the LTC questions regarding the proposed RAR mapping you have in front of you today for consideration of 1st reading:
To date the LTC has not requested or obtained the same kind of detailed and accurate mapping of riparian areas which many other islands have already completed, and, which more will be obtaining this coming year. Those islands’ LTCs have requested, and received, funding from Trust Council to secure accurate mapping for the tax paying property owners on those islands.
And, because of our current system of taxation, Salt Spring Island taxpayers have subsidized approximately 40% of the associated costs of that accurate mapping for other islands.
The January 14th LTC staff report stated, “While the RAR watersheds are identified, the exact location of the watercourses or their attributes (fish or non-fish bearing) is not known. While exact watercourse mapping is impossible given the current staff and monetary resources that would be required to properly locate all the watercourses, it remains a concern that will have to be addressed as bylaw changes are proposed.”
Now that we have finally received draft mapping for consideration, it is that specific concern which I am addressing.
At the RAR meeting held at the Lion’s Hall, I specifically asked Planner Nichols how much would it cost to obtain accurate mapping. His reply was he didn’t know.
At the same meeting, it is my understanding Regional Planning Manager Hartley told others it would be over $100,000.
At the Fulford RAR meeting I asked Trustee Torgrimson how much it would cost to obtain accurate RAR mapping and she told me it would be “hundreds of thousands of dollars” and it would take a long time to complete. When I asked her specifically where those figures had come from, she told me she had never seen an estimate in writing, and that she thought that no one really knew how much it would be. This was not only puzzling to me, but disturbing.
Today’s staff report states, “Salt Spring Island has a large number (of) RAR designated watersheds… whereas other islands have significantly less in the range of 4-6. This has allowed other islands to hire firms to accurately locate watercourses within the RAR identified watersheds so that their DPAs can accurately reflect each watercourse and their attributes.”
In other words, it is staff’s opinion, based on apparently nothing other than speculation, that while it’s apparently acceptable for Salt Spring to subsidize other islands mapping, it is too expensive and too time consuming to “accurately locate watercourses on Salt Spring.
This becomes even more puzzling when the actual estimated cost to provide the same level of accuracy of mapping and reporting which the other islands have already secured, is evidently less than $50,000, and would take less than one month to complete. The actual cost to Salt Spring taxpayers would only be about $20,000 – hardly an “impossible” or unreasonable amount of money to be spent to obtain mapping which is accurate and will be used for the foreseeable future. In fact, it is significantly less than the annual raises recently approved by the three of you, for Salt Spring Trustees.
This leads me to my next question as to why neither the LTC, nor Trust staff, have, to date, requested a detailed estimate of the costs of accurate mapping for Salt Spring? Surely this would have been the primary question to have asked and have answered before speculating, or guessing, the costs are far too high, and before misleading the public with such wild speculative guesses that costs of mapping were so high as to be “impossible.”
Today’s staff report states, “In the 2009-10 fiscal year, funding was made available to undertake RAR implementation.” That year Islands Trust mapping services cost taxpayers $255,430.
While no funding was applied for RAR mapping of Salt Spring, that same fiscal year the Trust paid Madrone Environmental Services $76,000, much, if not all of it, to do with RAR mapping and studies for other islands.
No funding for RAR mapping for Salt Spring was evidently applied for by the LTC in the following year, 2010-2011, in spite of the fact that $6,666 was budgeted on RAR communication for Salt Spring – essentially selling us the benefits of RAR implementation. That year Trust Mapping Services were $235,641.
No funding for RAR mapping for Salt Spring was requested or received this year either, while Hornby, population 1,000, received $5,000 for RAR mapping. Saturna, population 350, had already received about the same amount, while North and South Pender, combined population 2400, and Mayne Island, population 400, had evidently received considerably more.
The bottom line question here is – why is it, that time after time, year after year, our trustees have not requested any funding for accurate mapping of Salt Spring?
If the Trustees themselves have been misled or misinformed regarding the estimated cost of accurate mapping, now is certainly the time to take pause, secure a proper estimate, apply for funding from Trust Council next year, and in the meantime, put this whole issue on hold.
To the best of my knowledge, there is no deadline, or best before date, which has been imposed on the LTC by the Ministry of Environment. Other islands have not, and will not, complete their proposed OCP amendments until next year. There is no imminent threat or danger of harm to the environment in the meantime and I’m sure Riparian Area Assessments will continue to be requested by the LTC, as they have since 2006.
As I have mentioned, it is incumbent upon you to do ensure the public is not being further misled during this process. To do so will bring into jeopardy the validity of any OCP amendments you may propose to be approved by either the Trust Executive or the Minister.
Thank you and I look forward to your response to both my opinion, and my questions. If you have any questions for me, I would be happy to respond.
Note – Subsequent to my presentation, at the meeting, David Marlor, the new Director of Local Planning Services estimated the cost of accurate mapping at $75,000, while Trustee Torgrimson revised/reduced her estimate from “hundreds of thousands of dollars” to $125,000, both based on nothing other than wild ballpark guesses.
It appears none of the Trustees, or planning staff, or the Director, actually heard me when I said it would cost less than $50,000.