Section Head
Ministry of Forests, Lands, Natural Resources Operations Rural Development
142 – 2080 Labiuex Road
Nanaimo, BC V9T 6J9
(sent via electronic mail) Dear Section Head
September 2, 2018
I am writing to voice my concerns, observations, and opposition to the application submitted by the Town of Qualicum Beach: Disposition of Crown Land File #1414799.
At the outset I will say that I support the general concerns off enhancing the Beach Creek estuary with improved stormwater outflow, and increasing resiliency to extreme weather events. However in 1.1 of the Management Plan (MP) it’s stated that; “This project is primarily for ecological benefit.” This is a fundamentally misleading characterization of this project. The scope and extent of the applicant’s incursion into into the Crown intertidal zone is completely predicated on accommodating the construction of a new roundabout at this intersection.
I find the fact that there is not one mention of the new roundabout in the whole Management Plan to be a failure of public disclosure on the part of the applicant. It should be noted for the record that there has been no public consultation between the Town and residents regarding this proposal.
Notwithstanding my previous points, I have the following concerns regarding the Management Plan:
1.2 Investigative Work
- The applicant states that : The public is strongly supportive of improving the Town’s shoreline to a natural beach profile..” The scale of the application is dictated by the roundabout and results in construction of a very large artificial headland that intrudes well seaward of the current natural boundary. This rock and boulder headland will not be seen by residents as consistent with the “natural beach profile” in the least.
1.4 First Nations Consultation
- The Town has undertaken no consultation of public record with the local Qualicum First Nations Band regarding this application, despite this coastline being part of their ancestral home. This would appear to be a fundamental omission of public process necessary for the Crown to be assured that this project has broad based public interest.
4.1.2 Soil Disturbance
- It is not clear to me how the Town can state there is no “potential for disturbance of archaeological, paleontological fossils or historical artifacts”. The Town has records on file indicating that this stretch of coastline has a number of locations where archeological sites have been identified.
4.1.3 Riparian Encroachment
- The extent of the proposed riparian encroachment is not warranted for habitat enhancement purposes and extreme weather resiliency, but rather a requirement of accommodating a traffic circle.
4.1.5 Visual Impacts
- The seaward extension of the rock headland will significantly alter the visual character of this stretch of the Qualicum Beach shoreline. The shallow sloping sand flats of Qualicum’s beach are a major attraction to summer residents and tourists. No material has been submitted by the Town that indicate that visual impacts from nearby properties and from the beach have been considered. The rock headland will be the only man made structure extending significantly beyond the natural shoreline in all of Qualicum Beach. As such, this alteration to the natural shoreline should have been put before the public for comment prior to being submitted to the Crown for approval.
4.1.6 Archaeological Sites
- It is not clear to me how the Town can state there is no “potential for disturbance of archaeological, paleontological fossils or historical artifacts”. The Town has records on file indicating that this stretch of coastline has a number of locations where archeological sites have been identified.
- An AIA should have been conducted as part of the Town’s efforts to prove ‘due process’ to it’s residents, and to address the subject of ‘archaeological sites’ with some degree of third party professional assurance.
5.1.1 Land Management Plans and Regional Growth Strategies
- The applicant states: “Town of Qualicum Beach Official Community Plan: Strongly supportive of proposed project.”
- Residents familiar with the Town’s OCP and The Waterfront Master Plan, could easily take issue with this contention. While the environmental goals of the application are consistent with the Town’s OCP and Waterfront Master Plan, the inclusion of a roundabout clearly contradicts major goals of those documents. Both documents state a priority on reducing traffic flows, and enhanced pedestrian and cyclist safety and access. Without public consultation that has affirmed that the proposal is compatible with our OCP, the Town’s claim must be seen as without foundation.
I will summarize in stating:
Ministry of Forests, Lands, Natural Resources Operations Rural Development
142 – 2080 Labiuex Road
Nanaimo, BC V9T 6J9
(sent via electronic mail) Dear Section Head
September 2, 2018
I am writing to voice my concerns, observations, and opposition to the application submitted by the Town of Qualicum Beach: Disposition of Crown Land File #1414799.
At the outset I will say that I support the general concerns off enhancing the Beach Creek estuary with improved stormwater outflow, and increasing resiliency to extreme weather events. However in 1.1 of the Management Plan (MP) it’s stated that; “This project is primarily for ecological benefit.” This is a fundamentally misleading characterization of this project. The scope and extent of the applicant’s incursion into into the Crown intertidal zone is completely predicated on accommodating the construction of a new roundabout at this intersection.
I find the fact that there is not one mention of the new roundabout in the whole Management Plan to be a failure of public disclosure on the part of the applicant. It should be noted for the record that there has been no public consultation between the Town and residents regarding this proposal.
Notwithstanding my previous points, I have the following concerns regarding the Management Plan:
1.2 Investigative Work
- The applicant states that : The public is strongly supportive of improving the Town’s shoreline to a natural beach profile..” The scale of the application is dictated by the roundabout and results in construction of a very large artificial headland that intrudes well seaward of the current natural boundary. This rock and boulder headland will not be seen by residents as consistent with the “natural beach profile” in the least.
1.4 First Nations Consultation
- The Town has undertaken no consultation of public record with the local Qualicum First Nations Band regarding this application, despite this coastline being part of their ancestral home. This would appear to be a fundamental omission of public process necessary for the Crown to be assured that this project has broad based public interest.
4.1.2 Soil Disturbance
- It is not clear to me how the Town can state there is no “potential for disturbance of archaeological, paleontological fossils or historical artifacts”. The Town has records on file indicating that this stretch of coastline has a number of locations where archeological sites have been identified.
4.1.3 Riparian Encroachment
- The extent of the proposed riparian encroachment is not warranted for habitat enhancement purposes and extreme weather resiliency, but rather a requirement of accommodating a traffic circle.
4.1.5 Visual Impacts
- The seaward extension of the rock headland will significantly alter the visual character of this stretch of the Qualicum Beach shoreline. The shallow sloping sand flats of Qualicum’s beach are a major attraction to summer residents and tourists. No material has been submitted by the Town that indicate that visual impacts from nearby properties and from the beach have been considered. The rock headland will be the only man made structure extending significantly beyond the natural shoreline in all of Qualicum Beach. As such, this alteration to the natural shoreline should have been put before the public for comment prior to being submitted to the Crown for approval.
4.1.6 Archaeological Sites
- It is not clear to me how the Town can state there is no “potential for disturbance of archaeological, paleontological fossils or historical artifacts”. The Town has records on file indicating that this stretch of coastline has a number of locations where archeological sites have been identified.
- An AIA should have been conducted as part of the Town’s efforts to prove ‘due process’ to it’s residents, and to address the subject of ‘archaeological sites’ with some degree of third party professional assurance.
5.1.1 Land Management Plans and Regional Growth Strategies
- The applicant states: “Town of Qualicum Beach Official Community Plan: Strongly supportive of proposed project.”
- Residents familiar with the Town’s OCP and The Waterfront Master Plan, could easily take issue with this contention. While the environmental goals of the application are consistent with the Town’s OCP and Waterfront Master Plan, the inclusion of a roundabout clearly contradicts major goals of those documents. Both documents state a priority on reducing traffic flows, and enhanced pedestrian and cyclist safety and access. Without public consultation that has affirmed that the proposal is compatible with our OCP, the Town’s claim must be seen as without foundation.
I will summarize in stating:
- - The environmental objectives of the application don’t warrant the seaward extent of the
works. - - The proposed boulder and rock headland is not consistent with a ‘natural beach profile’.
- - Lack of First Nations consultation is a significant omission.
- - Failure to address visual impacts and show evidence of ‘acceptability’ is an omission.
- - Likely absence of archaeological sites is not sufficiently substantiated.
- - Suggesting substantial support with our OCP for the overall project is misleading.
- - Lack of prior local community consultation for the overall project is a serious omission.
Respectfully submitted:
Bruce Fleming-Smith
564 Berwick Rd. North Qualicum Beach, B.C. V9K 1L1
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