2 April, 2019
Dear Mayor and Council,
Regarding the proposed development at 12555 240 Street, 12599 240 Street, 12516 240 Street, and 12511 241 Street, please be advised that ARMS does not support this application. It is our hope that the following facts and concerns being presented will propel you to deny this application and initiate an examination of the existing densities in the Alouette River watershed and whether density bonus provisions should be allowed within it.
Firstly, at this point, we believe the most important step is to deny this application for the following reasons, which are a snapshot of the fuller concerns we will be presenting at the public hearing that Council recently enabled through granting second reading to the application.
The following is a link to a study commissioned relating to the Alouette River Valley after the 1995 flood. Please note the 200-year flood is set at higher than 500cm/s. This is relevant, as the developer’s professionals have presented slightly lower flood predictions and have omitted references to key flood episodes.
Here is another study that goes back to after the 1955 flood occurrence that also places the cm/s at a higher rate than is being used by the developer.
We believe it is important for all of Council to be informed of the historical, heritage status this river has within Canada, as the South Alouette River is one of 20 heritage rivers in British Columbia and one of two in Metro Vancouver, sharing the designation with the Fraser River. We ask that Council respect why this status was given and that increased densities, regardless of the minor conservation improvements that are being claimed within the staff report, are in conflict with the intent of the OCP when it protected the river with the RS-3 and RS-2 zoning and included the river’s heritage designation.
What does Heritage Status mean?
A Heritage River proclamation does not carry legal or regulatory power. Rather, the designation serves each river by:
- providing a greater emphasis on river-related values during land-use planning processes,
- raising awareness of the importance of healthy river systems,
- helping to protect the special values of the river, and
- helping to build stronger public support for, and involvement in, stewardship of the river.
There are a number of criteria categories that allow for a river to be designated heritage status and a key criterion for Alouette was the river having a significant place in the cultural heritage of the area. As per the description by the province, “The Katzie First Nation have historically depended on the salmon of the river and have maintained spiritual, cultural and economic ties to the river. The valley was part of a travel corridor for First Nations people between the Lower Fraser River area and the Lillooet area.”
As well as the concern that we have for the impact densities of this type will have on the environment of the river, it seems illogical for the City to try and obtain infrastructure gains, or conservation gains for the City through densifying in the flood plain when densities for the City could be gained in more logical serviceable areas. Please keep in mind that even though it is in the Regional Boundary, the application is outside of the Urban Boundary for Maple Ridge.
Within the OCP, RS-3 and RS-2 were designated for this area to protect the river and ensure that the densities that are being requested would not happen, so allowing them for this river without a complete study of how it will impact the intent of the OCP is needed, as we believe this will ensure further applications of this nature do not move forward.
All of Council should have had the opportunity to read the bridge report that was commissioned for the City prior to this decision. Over and above our concerns with the flood assumptions that are being used within the application, information contained within the August 2008 Maple Ridge Feasibility Study for Alouette River Crossing is also very important to understand.
The public would want to know that every Councillor was fully informed of the historical conversations and studies done prior to the reports that are now being driven by the professionals provided by the applicant and staff’s support of gaining conservation land and infrastructure support relating to the bridge. We state this, because it is staff’s job to relay the benefits of such proposals, but it is Council’s job to weigh the policy impacts and values identified within the OCP that this application is in conflict with.
The report that was commissioned for the City speaks to the unknowns and states many directives that this development application appears to be in conflict with. We request that council fully review all documentation regarding the bridge, as there are many unanswered questions contained within the reports that this application does not or could not fully address, due to the bridge not being designed yet. Some points from the bridge study that we would like you to consider are the following:
- The importance of not allowing fill within the bridge project as an absolute.
- Page 1-2, paragraph 1.6 states “the District has indicated that roadway embankment fills in the floodplain are not to be considered.”
- It also states that there is no way of knowing the true impact of the bridge on the water levels.
- The report states that Council should consider, due to the size and capacity of the required bridge, putting more residents in proximity to the bridge would not be advised, due to the noise, traffic and environmental issues.
- It also speaks to the shadowing that the bridge would cause on surrounding properties.
Although it is now understood that the bridge is more than likely to be similar to the existing 232 Street span, shadowing most likely is not an issue, nor is the reference to the size, however, all other concerns remain—especially the capacity as the traffic flows out of this area are only going to increase.
Pictures of previous floods prove that the developers will have to bring in fill that we believe is over and above what is being claimed in the application, as the flood levels and where they propose to build the houses do not support these homes being safe from future floods.
The compensation lands on the north side that are being gained through this application only would have yielded three lots if allowed to be developed, as most of the land is not developable. Therefore, in reality, the RS-3 and RS-2 zoning is the mechanism to which conservation is gained without it costing the City anything, as these zonings keep human impact to a minimum.
Essentially RS-3 and RS-2 act as de facto conservation mechanisms for the City at no cost, as the low residency private lands have minimal impact and lower the human impact on lands that if become public are then open to public access. We would argue that this has greater impact on wildlife corridors and the environment than the impact three households would have; further, the City could mitigate this by using other designation tools to protect such land.
We are concerned that sound planning principles are being ignored to gain compensation offsets for the City that will be required when the bridge is built. Low density zones in sensitive areas and higher densities as development moves away from such, is one of the few protections that the river has, and this development ignores these solid planning principles. In reality this site should only be allowed to get 7-10 lots max under the RS-2.
Does Council know how many other RS-3/RS-2 lots could be opened up to this type of development application through this precedent setting application? We posed the question of this being precedent setting to the City staff member that met with ARMS members about this and this was the answer:
How many properties along the Alouette River would qualify for density bonus provisions?
Answer. It is important to realize that all properties within Maple Ridge jurisdiction could potentially qualify for density bonus provisions. However, only the properties that are within the Metro Vancouver Urban Containment boundary could qualify for urban levels of density (less than 1 acre) without first triggering an amendment to the Regional Growth Strategy. The only area that currently has a prescribed formula for density bonusing is the Albion Area Plan.
In all other cases, proposals that request density bonus measures must be considered on a case by case basis. Each approved development may set an example for Council consideration, however, as each proposal offers unique opportunities, approvals should not be considered precedents. Also, what qualifies as an acceptable offer for bonus density is limited and generally is considered for lands developable with high quality environmental features that cannot be preserved with traditional measures.
We challenge the assertion that this property fits what has been stated within the aforementioned answer from staff, as the lands in question are not developable with high quality environmental features that cannot be preserved with traditional measures as the traditional measures that the OCP provides for such by zoning them RS-3 or RS-2 and through the 30-metre set back and many other protections.
We also question that lands are considered on a case by case basis and should not be seen as precedents, as staff continually raise the Dogwood development as an example that shows how density bonusing provides amenities to the city in cases where they previously would not have occurred. If they are case by case, why is Dogwood being proposed by staff as a precedent setting model?
Further, as mentioned before, the land that is being donated would only yield about three lots, due to the proximity to the bridge set-backs and overall topography of the land, which means that conservation would have been achieved through the low-density zoning and such private ownership would yield less traffic than public land.
We understand trails are important to this area, but any trail system that would be of benefit to the area could be served through the bridge right of way.
ARMS has spent an extensive amount of time reviewing all of the technical reports that have been provided by the consultants for the applicants and previous documents that the City has commissioned relating to the lands in question. As you are aware, the board of directors of ARMS is made up of long-time residents who have intimate knowledge of the river and its history and a number of them have extensive background with the Hydro history within the watershed.
These members have been able to provide extensive counter information and personal experiences that challenge the assumptions within the consultants’ reports that purport the development will have minimal impact on the flow of the river, as well as their assumptions of the future flood potential to the site. Does all of Council feel confident that you can trust flood predictions that have been selective within the applicants’ reports?
Also, a number of our members have intimate knowledge of the southern slope stability and we are not aware if the surrounding slope and the upper road system has been assessed? We are still waiting for answers from staff on that question.
Also, we are unclear if the fish habitat is also being used for a silt retention area for the southern slope? That seems impossible to accept, as we expect the environmental team at the City to ensure this would not be the case, as silt has negative impacts on fish bearing waterways. However, we still need clarity on this and hope that you have those answers. If you don’t, they need to be provided.
The City can ask for a peer review of the information provided by the developer, which we would like you to consider prior to moving forward. Do you understand the provisions and use of this tool? City staff gave us the following answer:
Provide a rationale for a peer review of the hydrological study.
Answer: Normally, the Engineering Department would require a peer review if there was sufficient justification to require it. The hydrological study was prepared by an established company with extensive experience in floodplain modeling of the Alouette River with findings that have been verified through field research. The base model used for this work was compiled previously and has been accepted by the City.
We believe reputable engineering companies that we have cited in the attached reports give enough conflicting information that warrants another look by an independent body. We stand by this, as you are being asked to approve a beautiful subdivision where people will invest in the single most expensive purchase in their life and it is in the flood plain, so you should be confident that you can defend your decision.
Although a number of the references to the floods that have occurred in the past are relating to the 1995 flood, our members’ relationship with flooding goes back as far as the 1955 flood and some have relatives that can cite even earlier floods of even greater magnitude. We are gathering that information. All of this is on record in the Maple Ridge Archives and we have provided a clear example of the magnitude of the 1955 flood. Considering its location of Maple Ridge Park, it is fair to say that the flood capacity is of concern for all of the properties along the Alouette River.
Flood of 1955 Maple Ridge Park
Here is a reflection by one of our members of the flood:
“The highest flood “downstream” of the Alu dam I believe was in 1955. The Alu reservoir was rising at an alarming rate and the dam caretaker was directed to open the 3 stop log gates as a pre-spill into the river. There may have been a southwest wind blowing and with no debris boom in the forebay, stumps and woody debris jammed under the gates and the dam caretakers could not close the spill gates again with the reservoir still rising to the crest of the dam. Some of the debris slammed down on the spillway apron and it was breaking up the concrete too -there are museum pictures of this.
It looked so bad that they thought they were going to lose the dam. But the reservoir drained down into the river until it reach the sill bottom. A relative of mine worked for the Dist. MR and told me the scum line on the trees in the 232st Park was 6 feet high when the river recessed to access the Park.”
It is important to know that the estimated flows that were experienced in 1955 were still less than 60% of the predicted 1:200-year projections.
Members of ARMS also strongly urge Council to reflect on how much effort has been put forth by ARMS and City staff in supporting the City with their environmental goals, as well as the money that has been put forward by BC Hydro ratepayers through the Fish and Wildlife Compensation Program working to rebuild fish and wild life habitat in the Alouette River Watershed. This relates to the proposed development project because much of the clearing and grading for the roads and building sites will be on, or near, owl, heron, frog, turtle and possibly Species at Risk (SAR) critters (tailed frogs-etc.). We would like to highlight for you some of the work that has been done in partnership with ARMS to this end:
- Between 2010 and 2017, the BCH-FWCP funded 19 projects in the Alouette River Watershed with a combined value of over a $1 million dollars. BCH-FWCP, successful grant applicants worked in the Alouette River Watershed to restore and maintain spawning and rearing habitat for Chinook and Coho Salmon.
- A habitat mapping and species inventory project on at-risk species including herons, owls, turtles and frogs, as well as goshawks and deer was also completed. Risk species include: Western Screech Owl, tailed frogs and the Western Painted Turtle, which were the focus of a project.
- Inventory of riparian and wetland species as a first step toward future restoration and habitat protection in this watershed.
- In 2017 – 2018, the FWCP’s Coastal Region Board approved an additional $312,000 for four fish and wildlife projects in the Alouette and Stave River Watersheds. Part of this funding will be used by the Alouette River Management Society to explore fish passage for anadromous salmon in the Alouette River watershed.
We recognize that every house in Maple Ridge has the potential to impact the aforementioned creatures, but this is not a NIMBY reaction, it is the reality of trying to sustain the eco-system of this river and there is specific wildlife that are threatened in the area and the hard work that has gone into protecting them should be acknowledged.
The scope of work that is within the consultant’s reports for the developer are primarily limited to the footprint of the development and does not recognize the special and unique value of the watershed. Nor does it recognize the cumulative effect of this development to the watershed or the consequences of fragmenting habitat. Because of the City’s requirements this is not a requirement of the study, but it calls into question how there is any chance of protecting the watershed. In effect this section of the South Alouette watershed is being destroyed by a thousand cuts.
A true EIA, which ARMS believe should be conducted for this project, requires a comprehensive assessment of the site or area of impact to determine the species that use the area, the type of use (nesting, breeding, rearing, staging, migration, denning, etc.); information on the numbers or densities of each species; are they resident or transient; the extent of the habitat; etc. This is the inventory component which the Letts report attempts to do but it appears to be little more than a literature review and field surveys in October and November which is one of the least active times for many groups of wildlife including birds, reptiles and amphibians. In reality we do not know the current existence and status of the fish and wildlife species identifying the report or if those identified are a complete accounting.
Due to the area plans that are associated with the north side of the river, safe wildlife habitat and corridors are becoming more predominant on the south side of the river. Density such as these being allowed within the RS-3 and RS-2 zones will only exacerbate an already challenging job of protecting the wildlife that is dependent on these lands. Fewer residents interfering with and adjusting to living amongst the wildlife that are present within the area is another reason that the OCP designated the lower densities.
On another point of evidence that due diligence needs to be done on this application, the following link is a report that was done for the Hammond Area Plan. You will note that attention was given to the impact density bonus would have on Hammond. Yet, the Alouette, which has just as much historical importance, if not more, is facing a change to the zoning that was put in place to protect it—RS-3 RS-2—and a full impact study on what that means for the rest of the river has not been discussed. Here is the link:
The following is a snapshot of what happens when the big one hits. The following is a statement that was made after the Alberta floods of 2013 and then a link with respect to the impact of the flood.
“It used to be that the largest threat to a person’s home was fire,” says Bill Adams, Insurance Bureau of Canada Vice-President, Western and Pacific. “That’s long since been surpassed by water-related issues, largely the result of Mother Nature.”
Here is the link to the Calgary flood of Bow River. When Mother Nature shows us, we should believe her. Why would we do this when we have enough land in our urban boundary for the development that we need? Why would we put future homeowners at risk to gain compensation funds for an infrastructure project that should have been planned using the proper channels?
In conclusion, with over 80% of this development being in the flood plain, the impact on the river and the surrounding watershed will undermine the fabric and intent of our Official Community Plan as it relates to protecting the environment and our waterways, which ARMS actively strives to support within our mandate. And while we recognize that the amenity gain of conservation land in such a desirous location may seem to justify the impacts on the river, we believe that logic should instead fall on the side of continuing to protect this heritage river and the fish habitat and wildlife corridors that are already under assault. We also strongly argue that RS-3 and RS-2 in the flood plain should not be included within Density Bonus consideration and this was an error when the by-law was adopted.
And although we will present a fuller argument against this application at public hearing, we hope that this body of information in itself gives you reason to deny the application. ARMS believe that there is enough land in our Urban Boundary and Urban Reserve that the City does not need to densify in the flood plain of the Alouette River and you would be opening up future applications with this precedent setting application. And at minimum, we do not believe you should be putting future home owners at risk, when it is clear there is still risk involved in developing in the flood plain and, as nice as this development proposes to be, it should not be the legacy this Council strives for.
Thank you for your attention to this matter. We truly respect the role that you have taken on.
President of ARMS