Board opinion after the presentation below was such that it appeared the majority of board members were in favour of the proposed subdivision, enabling more one hectare lots to be developed in the vicinity of Jim Smith Lake. This matter is of grave concern to many area residents as it appears to be in contravention of existing Official Community Plans for the RDEK and the City.
The public is invited to attend this Public Hearing on Tuesday April 23rd at 7:00pm
I am here as a
representative of the Jimsmith Lake Community Association to address changes to
the proposed by laws 2427 and 2428.
The introduction
to Area C Official Community Plan (By law 2255) states that the OCP reflects
the vision of the community, and as such, it states that it is the official
position of the Regional District Board.
I realize that the OCP is a guideline and it is riddled with loopholes
so that the official position can be very flexible. However I intend to demonstrate that there is a limit to the
flexibility offered in certain cases and that the intent of the proposed by-law
changes goes beyond that limit.
Despite the
unanimous recommendation, twice, of the Area C Advisory Planning Commission
against 1 hectare lots, the planning staff have made a unilateral decision to
allow this developer to plan for 15 of the 17 lots to be less than 2ha on this
greenfield acreage.
This is justified
by planning staff on the basis of “land
use efficiency”. But there are other factors that make up the overall
efficiency of land use, such as water run off, wildlife needs, lake habitat, recreational
pursuits etc. These are less concerned with such a semi-urban outlook as higher
residential density but tend to decrease
residential density for a higher total efficiency..
Staff are talking
not about land use efficiency, but merely economic efficiency.
I have heard the
argument that because there exists a large amount of uninhabited Crown land
relative to available private land, we should fill the private land to make up
for it. There is plenty of land for
wildlife and trees, the suggestion goes, and so we can put as many people as
feasible regardless of other uses into the rest. This philosophy is plain wrong
because this is not about the economics of development. It is about retaining our rural environment.
Other consequences
of almost doubling the residential density over normal rural densities of 2 ha.
are numerous, they include;
·
Increased
traffic density on Lakeview Drive will impact painted turtle and human safety
·
Increased
greenhouse gas emissions
·
Increased
fire hazards
·
Increased
pressure on birds and ungulates and their predators
·
Increased
potential for high nutrient water to run into the lake
·
A precedent
will be established to develop any large Rural Resource acreage in Area C into
1ha lots if this proposal is approved.
·
On the basis
of economics alone there will be little incentive for developers to stick to 2
ha lots in the future, if staff continue to encourage them.
·
And others
The OCP makes the
point in a couple of places that RR-1 (estate) developments are intended for rural infill, not greenfield
developments. This is board policy. However the planners don’t seem to recognize
this. In OCP clause 3.1 it says smaller lot sizes are permitted where an infill need is identified and in 3.2 it
says R-Res designation recognizes potential for rural infill development.
Since this is board policy we can assume that neither RR-1 estate nor
R-RES designations apply in this case under consideration.
With a total of 43
new lots, including these proposed ones, at the West end of Jimsmith Lake, approximately
10 to12km from this office, gas emissions can be reduced by creating 2 ha lots.
Smaller lots can be developed nearer town.
Even though the
OCP states that greenfield development is not generally accepted we have to
recognize that it is unlikely that subdivision of private land will be
prevented in the Rural Resource areas.
However under no circumstances does the OCP recognize the Estate designation.
In other words the
RR 1 designation in bylaw 1402, Cranbrook Zoning, cannot be applied to a greenfield
development, according to board policy. The smallest lot size that can be used for
residential greenfield development is RR-2, medium holding.
The fact that
significantly smaller lots exist in the village of Jimsmith Lake cannot stand
as a precedent because the subdivisions were largely created in the 1960’s and
early 70’s as summer cottages. This was
a time when there was less awareness of biological diversity and the heavy
impact small residential lots have on land.
Even though these are economically efficient from a planning point of
view, in this day and age they are entirely unacceptable.
No longer in
Jimsmith area do we have moose and elk which were common at one time. Also we no longer have crayfish, trout and
many invertebrates that used to be abundant in the lake. In addition to a loss of diversity, we also
suffer from an excess of submerged plant growth in the form of Canadian Milfoil
and other thick growing plants, due to an excess of nutrients in the runoff
water.
The 1 ha lots in the neighbouring subdivision,
Soaring Hawk Ridge, provide no precedence either. It was considered necessary by the board, because under the OCP
the area was designated R-Res, and that seems to be justification to make a
higher density of population in the environmentally sensitive wetland
area. The actual reason for this is
inexplicable, unless economic efficiency overrides overall efficiency of land
use.
However these factors have no bearing on the
Daprocida lot since the environmental sensitivities do not require a
development permit other than a fire hazard report.
It is not true to
suggest that there will be no more subdivisions around the lake. The private property at the North West
corner of DL 2311 will now gain access through this new subdivision.
In summary;
·
Because the
Daprocida lot is currently zoned RR 60 and is a greenfield development with no infill requirements, policy
states that rezoning to RR 1, estate, is inappropriate.
·
Popular
community opinion is that 2 ha lots are a minimum for rural residential
purposes and result in a gentler impact on our valuable rural resources.
·
If this
development goes ahead with 1ha lots then a precedent will be established for
all greenfield developments to be planned for economic efficiency alone in the
future.
We in the Jimsmith
Lake Community Association wish to express our understanding of the need for
private land to be used for residential development, but do not accept that
economic factors alone should override all other considerations. Especially Board Policy.
Specifically we
are requesting you to delete any reference to SH, small holding, in bylaw2427
and in bylaw 2428 delete any reference to RR-1 Rural residential (estate) and
change Schedule A to reflect this.
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| Jim Smith Lake, Fall |
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