Mike Bell
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September 14, 2010

The Board of Directors
Comox Valley Regional District
Public Hearing-Filberg Centre

RE: FIVE RECOMMENDATIONS TO IMPROVE THE RGS PUBLIC STRATEGY (BYLAW 120)

Here are five recommendations which, if implemented, will improve the RGS. But first, a word about the all-important Introduction (p.3). It describes both the purpose (or goal) of the RGS and the means by which it is to be achieved.

The purpose of the RGS is somewhat unclear for there are a number of purposes spelled out (on page 2 and page 3). But the ultimate purpose or goal of the project seems to be “preserving the region’s high quality of life.” (p.3)

The way to achieve this, according to the document, is by using the document to: 1) “build consensus among local governments on future policies regarding land use activities and development and, 2) “provid(ing) a framework for future decision making.” (p.3)


Recommedation #1: SHIFT THE FOCUS OF THE DOCUMENT FROM FACILITATING DEVELOPMENT TO THE REAL PUPOSE PRESERVING THE VALLEY'S HIGH QUALITY OF LIFE. What does the “high quality of life” mean? It means supporting the lifestyles of those who have lived here a long time and decided to stay, and those of us who have discovered the Comox Valley and decided to move here because we knew the valley would support our lifestyles. Next to family, the ability to live our individual lifestyles is, for most of us, our highest priority.

Each one of us has his or her opinion of what a healthy lifestyle means for us. The farmer, the small business person, the member of the military, the civil servant the shellfish harvester, the school teacher, the parents of young families, the person with disabilities who rides our streets in a mobile scooters with the little flag up in the back cautioning the traffic—each one has his or her own idea. There is a rich diversity of people who are here because this valley will support their diverse lifestyles. The bottom line is this. We are here because we like it here.

We like the small size of our communities, the arts community, the summer concerts, the farmers markets, the fish for sale in the harbour, the services we find here, the shopping, the economic opportunities, the right mix of urban, rural and semi rural living.

But most of all we have been attracted by the spectacular beauty of the valley. The mountains, the ocean, the moderate climate, the wildlife that even wander our streets, the eagles above us, the salmon passing by to spawn, the trumpeter swans in our fields, the backyard gardens we tend, the trails we hike, the roads we cycle, and the rivers we can swim in. Out of this emerges an awareness, a sense of place, that links our personal life-styles to all that surrounds us.

In my opinion, most people who are objecting to the RGS, or who want significant changes, are doing so because they believe—with good grounds—that the current document does not adequately protect their lifestyles.

I know things change and we must prepare for change. But we have the ability to do it without radically changing the nature of this place and the support it brings to our lifestyles. Yes you must lead us in preparing for growth, development and change. But you must not do this at the expense of this regions high quality of life So please shift the focus from development to your first priority—preservation of the richness that is now ours. That is why we have elected you.


Recommendation #2. STOP CHANGING THE NAMES OF , OR ADDING QUALIFICATIONS TO , THOSE MUNICIPAL EXPANSION AREAS. JUST GET RID OF THEM. They have the possibility of radically altering the nature and character of the valley and denigrating our high quality of life and our lifestyles. That is what much of the controversy is about. The real purpose of these designated expansion area is not to accommodate a growing population. It is to attract developers.

I’m reminded of that scene in the movie “Field of Dreams” when Ray Kinsella, played by Kevin Costner, is having doubts about building the baseball field. He hears a voice that says, “If you build it he will come.” He is not even sure what the words mean but Terrence Man, played by James Earl Jones, says to him later in the movie: “Build it Ray, they will come, they will come from all over.” And in the last scene we see line of cars, bumper to bumper, moving toward the field, their headlights illuminating the night sky.

Working together we can build a strategy that will attract people from all over to come to this valley—as long as they are convinced that “what they see is what they are continually going to get.” But those municipal development areas-well, they present a real problem. They communicate the message that it is open season for all development—development that can radically change the nature of the valley. In such designated area, whenever it comes to a clash between development and the environment, development will win—especially if there is a explicit agenda to urbanize the area,

If you are really concerned about protecting our way of life, get rid of those municipal expansion areas and create effective, less risky and more gradual ways of dealing with growth and development.

Recommedation #3: PUT THE MISSING PROJECTS AND ELEMENTS BACK INTO THE PLAN. We don‘t know anything about the real needs or expectations of the K’omoks First Nation. Perhaps, at this stage of their land clams development, they don’t even know. But proceeding without them is unfair to KFN and to the rest of us. This situation must be rectified—assuming that the directors are even allowed to speak to KFN after the close of the public meeting.

The greatest, single environmental threat to the Comox Valley is the appearance of a number of coal mines between Fanny Bay and Campbell River—starting with Raven Coal Mine near Fanny Bay and the Bear surface mine between Fanny Bay and Cumberland. Yet there is only the vaguest hint about coal mine development in the document. We have been told the reason for this is that coal mines are provincial responsibility and thus outside the Terms of Reference for the RGS. This is utter nonsense. The premier and the cabinet don’t live here—we do. The project is a real risk to water sources and to the 600 people in the shell fish industry—all in support of the invisible, 40-year old, unemployed, underground miners who must be around here somewhere and need jobs. Can you imagine the tourism industry, always vulnerable to economic conditions, having to change its message? It will be trying to coax visitors to come and visit the coal fields of Vancouver Island, “our very own Appalachia.”

The Courtenay River Estuary, the heart of the Comox Valley, has been given short shrift in the report and would receive no attention at all were it not for the efforts of Project Watershed which keeps pushing the issue. Case in point, the Comox Marina.

Last week we I got a surprise when I read in the Comox Valley Record that Comox Marina had received a $400,000 grant toward a $1.6 million expansion. It will add another 550 linear feet of floats and 320 feet of deck and will double the capacity of the marina. Obviously this project has been in the works for some time. It may be a good idea. But, if it requires more dredging of the estuary or result in marine habitat destruction it will be a lousy idea and could be a disaster. The point—this is a major project that has been in the works for some time and it was left out of the RGS. Why? It wasn’t because the consultants missed it. As a management consultant with 25 years experience, often working in projects similar to this one, I can assure you that consultants don’t determine what goes into a report and what is left out. Elected officials do. The failure to account for this project goes against transparency.

There is a need to put the projects and elements that are is missing back into the report.

Recommendation #4. CREATE A SET OF GUIDING PRINCIPLES TO GUIDE POLICY DEVELOPMENT IN THE ZONING BYLAWS.

The RGS is supposed to provide a framework for decision making. But it doesn’t do this. There are some good ideas in the report—but they are not, as their name suggests, policies.

In government terms, a policy is a commitment on the part of government to do or not to do certain things. There are almost 200 so-called “policies” in the document spread across 8 different categories. But they are not commitments. Some of them are extremely vague, impossible to implement or to even understand. (Example: Promote and support growth within rural areas provided that the rural character and primary functions are maintained. It seems to most people that the more growth you have in a rural area the less rural area you have.)

Here are some examples of principles (and these are only examples to serve as illustrations) that might constitute a framework for decision-making.

1. Full Cost Accounting. An assessment of all developments must be based upon the principle of full-cost accounting. This involves an analysis of the complete range of benefits compared to liabilities–as far as they are able to be determined.

2. A Development Freeze. To avoid a land rush, there will be a freeze on all major development ($1 million plus) in the time period between the passing of the RGS and the creation of the OCPs.

3. Character. All developments must retain the unique character of the Comox Valley, including the present mix of urban, rural and semi-rural areas, as defined by... (Identify a Character Document to be developed that describes the characteristics of the Comox Valley’s “ high quality of life”).

4. Steady State Economy. In determining the suitability of developments, the economic and other benefits of the development must be weighed against, and balanced with, the demands that the development makes upon the area’s natural resources—particularly the availability of water (given the demands by all other users or developments.)

5. Democracy. Any expansion of municipal boundaries, or any change in areas from rural to urban may not be done without appropriate consultation with local residents in the affected area. A survey or referendum may be required.

6. Consistency. The individual OCPs must be consistent with one another in all significant components.

The policy statements in the current RGS document do not provide the required “framework for decision-making.” It is impossible for decision-makers to review more than 200 suggestions and make intelligent decisions. A smaller set of guiding principles related to growth and development is required.


Recommendation # 5 ADOPT A SYSTEMS APPROACH TO COMPLEMENT THE LAND-USE PLANNING APPROACH
The RGS refers to the importance of eco-systems. It indicates its support for Nature Without Borders, the Comox Valley conservation strategy. But it doesn’t use a system’s approach to understand or describe the ecosystems. Instead it takes the parts of the ecosystems, divides them up and tries to shoe-horn them into a land use plan: estuaries, watersheds, parks, greenways, biodiversity corridors, etc. When you try to divide ecosystems into various components, you destroy the system. That is one of the limitations of trying to use a land use approach to deal with eco-systems.

To illustrate further; you can’t fit Nature Without Borders into an RGS. The very title “Nature Without Borders illustrates the problem. Instead, given the much broader scope of the ecosystems in Nature Without Borders than the discreet, bounded areas in the RGS, you have to fit the RGS into the conservation strategy. This is not easy to do with a land use approach because the elements of eco-systems transcend land use boundaries: water flows from one area to another, fish and birds migrate though different areas, artificial municipal boundaries do not prevent toxic air born or water born pollutants, global warming and rising tides affect all areas, etc.

One of the basic principles that affects planning on a systems level is the realization that what happens in one area or component of a system can, and usually will, affect all areas of the system. This has all kinds of implications for decision-making, governance and other matters related to an RGS strategy. It is important to know how decisions made within one municipal area can have consequences in other areas.

One of the ways of introducing the concept of a systems approach into the RGS is through the maps. The current maps, because they are land use maps, are static. They cannot illustrate flows and transitions. But it is possible to incorporate a few maps that do illustrate how water and tides flow across boundaries. This should be done.

Conclusion
It is essential that the RGS focus on preserving the valley’s high quality of life and our individual lifestyles. I am continually recommended of the great blessing it is to live here.

Last week a man phoned me up about an eagle nest near his property. In the course of our conversation he told me he had recently moved from Toronto. I asked him how he liked it here. He said, “Yesterday I was swimming in the Puntledge River, I looked up and saw those mountains and that glacier and thought... I must be in Heaven. Our conversation reminded me of that other scene in Field of Dreams

Shoeless Joe Jackson says to Ray Kinsella, “Hey, is this Heaven?” And Ray says “No, this is Iowa.” If the swimmer I talked to was just passing through our area, wasn’t sure of where he was and asked me, “Is this Heaven?” I’m sure I would have said to him, “No, this is the Comox Valley.”

Thank you.

Mike Bell, Chairperson
Sierra Club Comox Valley


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