WaterWealth Comment on Chilliwack's Draft OCP 2040

Re: WaterWealth Feedback on Chilliwack’s Official Community Plan 2040

Chilliwack is a special place to call home with a unique abundance of natural wealth. Of course with this wealth comes the responsibility of stewardship and we commend the City of Chilliwack for it’s efforts to develop a plan that ensure the best interest of local residents now and for years to come.
 
Although there are many positives in the Official Community Plan, there was an alarming absence in the lack of explicit recognition of the Sto:lo people who have lived, worked and settled in the region long before 1858. At WaterWealth we believe that to ensure effective policies and governance of our home region, recognition and reconciliation of First Nations rights and title is essential. Although the City of Chilliwack may not have formal jurisdiction to consult with First Nations, recognizing unique contributions of the communities and culture of the Sto:lo is an easy first step in being good neighbours. As it is mentioned in Policy 6 of Goal 1 to ‘Manage Growth Responsibility’ to co-ordinate with First Nations, we want to suggest that it be an overarching feature to ensure ongoing communication and coordination with Sto:lo Communities about City plans and policies that may impact them. We hold that those communities are the judge of what will impact them.

The Official Community Plan is an impressive document that highlights a tremendous amount of work undertaken by City Staff and the Community Participants. From the City of Chilliwack’s Official Community Plan (OCP) Community Survey, 97% of residents want to see the "protection of drinking water and local streams" as a top priority in the plan for city growth. It is clear that large efforts were made to reflect this in the OCP 2040 draft, and we offer our comments in the spirit of assisting staff in achieving their aims to translate the hopes of city residents they heard from into a plan for managed growth.

We note that under the heading "Utilities" the second objective is to "Secure long term water supply sources." This is supported by objective 6 "Adapt to future system and environmental challenges through innovative and best practices." The Sardis Aquifer that Chilliwack's municipal water system currently relies on is fed by the Chilliwack/Vedder River which is in turn fed by glaciers in North Cascades National Park. Given that glaciers in the Pacific Northwest have been receding since about 1850 (eg the Lyman Glacier which has lost about 60% of its volume since the early 20th century), and given the opposing vectors of climate and population trends, we suggest that these objectives would be supported by undertaking study to determine to what degree the Chilliwack/Vedder River relies on glacier runoff in dry parts of the year, what long term prospects for those glaciers can be expected, and what impact might be foreseeable for the aquifer.

We focus our following feedback on the Development Permit Areas, as we see them having the most direct influence on how our home waters will be managed in the future. We note that each Development Permit Area (DPA) section begins with a “Description and Exemptions” section under which the area that DPA applies to is specified. The Description and Exemptions section of DPA 1 refers only to DPA Maps 1A and 1B which outline municipal watershed areas and aquifers. It would seem that this section should also specify DPA maps 1C and 1D as being designated DPA 1, can you confirm that this is an oversight in the document or inform us of the rationale for leaving it out?

In DPA 2, which refers to hillside and upland areas, we appreciate Guideline 1 which provides the additional requirement of 9 meters of undisturbed stream bank vegetation from the top of the bank of fish bearing or fish habitat streams. We would like to see similar or greater protection extended to all fish bearing or fish habitat waterways throughout Chilliwack. There are many such channelized streams in agricultural areas within Chilliwack. Creative solutions could improve fish habitat, reduce erosion of farmers’ fields, and reduce nutrient loading in waterways without imposing loss of income on farmers and with savings to the city through reduced need for ‘ditch’ cleaning. Riparian vegetation can also provide some air quality and carbon offset value. Furthermore to ensure the integrity of our drinking water aquifer, established riparian setbacks along urban waterways provide as filters for grey water runoff that is not captured by the storm drainage infrastructure.

Under DPA 3, which refers to riparian areas, we would like to see Guideline 3, which gives authority to the Federal Fisheries Act to justify the destruction or degradation of a local waterway, removed.  Given the recent changes to the Fisheries Act to protect only against “work, undertaking or activity that results or is likely to result in serious harm to fish that are part of a commercial, recreational or Aboriginal fishery, or to fish that support such a fishery”, the Fisheries Act no longer adequately ensures protection of fish habitat.

Furthermore the BC Riparian Areas Regulation allows but does not require a local government to permit development to proceed if the Minister of Fisheries and Oceans, or a regulation under the Fisheries Act, authorizes the harmful alteration, disruption or destruction of habitat. It seems prudent to rely on Guideline 1 of DPA 3, which calls for the assessment report of a Qualified Environmental Professional, to determine whether a development should proceed and not defer to the Federal Legislation. We want to impress the importance of this adjustment to ensure that it is local decisions and by-laws that have authority in determining how development affects our local waterways, rather than decisions sent down from Ottawa.

Additionally under DPA 3, Qualified Environmental Professionals (QEP) are given considerable authority but it is unclear about their accountability. The Provincial Fish Protection Act allows local government to enact bylaws that result in protection comparable to or exceeding that established by the Riparian Areas Regulation. We would like to see the city use this provision to require that assessment reports under DPA 3 be done by a QEP employed by or under contract to the city - rather than to a developer - so that the QEP would be directly accountable to the city and thereby to Chilliwack residents.

Planning for the future is one of the most important efforts to be made. Again we commend the City of Chilliwack for undertaking this ambitious task and we hope that our suggestions will be received in good faith. If you have any questions or would like any more information please do not hesitate to be touch.

Sincerely,
Sheila Muxlow, Director
The WaterWealth Project

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