Grace Doherty,
Box 507,
Cumberland, BC V0R 1S0
November 26, 2008

Village of Cumberland
Box 340,
Cumberland BC V0R 1S0
Attention: Mayor and Council, Planning Staff

RE: Bell Group- Cumberland Green

A motion was passed by Council on November 10 that scheduling of Bell Group's public hearing be put on the December 8 agenda.

While there seems to be some urgency on the part of the developer to move quickly on this, the supporting studies are not comparable to those provided by other applicants by this stage of the approval process. In light of the election of a new councillor not privy to the same information as the incumbents it seems ill timed as well.

A September 8th report to Council from Planner Judith Walker included 5 pages of concerns from Village staff, consultants and the municipal engineer about deficiencies in the reports that had been received from Bell Group. Council moved to table the report in order to obtain more information about on-site servicing. Mayor Bates confirmed in question period that the motion also tabled all of the recommendations actually set out in the report, including:

- not granting an exemption to allow for an on-site sewage treatment system;
- requesting further information to satisfy staff and consultants as to the viability of the proposed land uses;
- scheduling a public hearing when Village staff consultants and the municipal engineer are satisfied with the information received.
A public hearing date was subsequently scheduled on October 27 without any public indication that the issues had been addressed to their satisfaction. This was worrisome to me as was proceeding without a legal opinion on the CDA from our municipal lawyers.

The information meeting held by Bell Group November 3 provided little new information of any substance. It seemed more like a promotion of the Cumberland Green complex for prospective buyers than a session intended to convince villagers that this project would be beneficial to the community.

The audience was told that the water quality was "phenomenal". In the binder of reports made available to the public in the Village Office the water test result status was "adequate" from one sample. The result of the second sample had not been received. The September 8th referral response from VIHA Environmental Health Services read "I am unable to comment favourably at this time as I have not received information of how this development will be supplied with sufficient quantity and quality of drinking water." Testing to September showed inadequate quantity, although a second well would increase this.

We were told that there was talk of an alternate road access so that truck traffic to the landfill traffic would not pass the property. The July 4 referral response from CVRD however, recommends buffers- to the north to screen residents from existing and future solid waste management and composting, and to the east to screen residents from the anticipated increase in truck traffic generated from proposed expansion of the facility. A presentation to Council October 14 detailed a plan to expand the landfill and composting operations to the south (CVRD's property is adjacent to Bell Group's) and to truck Campbell River waste in via Bevan Road.

I asked questions about possible continued mine subsidence (up to several meters) and about contaminated materials described in a desktop geotechnical report of 2006. The study was done for a developer proposing 2-3 story residential and light commercial buildings. The conceptual drawings for the Bell Group project include many 4-6 storey structures: 2 care facilities, a hotel, a professional building and 14 apartment towers. The response was that the design of the buildings would distribute weight differently, and that building would be done to avoid the contaminated soil areas, possibly capping them.

The report speaks to the risk of sudden collapse of the backfill in the two known shafts, and their consideration that the entire property should be considered as impacted by the mine workings. It suggests removal of all of the contaminated material. A geotechnical update received in September cautions about implications for blasting (e.g. to bury utilities) given the extensive shaft network, and also to seismic concerns, given more stringent seismic reporting requirements in the December 2006 building code. Further study is recommended. There are many referral responses missing from the public reading binder, amongst them Ministry of Energy and Mines and Ministry of Environment.

These are a few of the concerns I have about this particular proposal. There are glowing claims and attractive conceptual drawings but insufficient data provided yet to support the viability of constructing an aging in place community on this site. To give third readings on the strength of the information given seems premature.


Sincerely,


Grace Doherty