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.