Anthony Minniti, President of the Cordova Bay Association For Community Affairs, has CC’d us his letter to the District of Saanich regarding the Environmental Development Permit Area (EDPA):
District of Saanich
770 Vernon Ave.
Victoria BC V8X 2W7
To Mayor and Council,
The Cordova Bay Association for Community Affairs (CBA) was formed in 1976 to govern land use matters within our community of Cordova Bay. The role of the association is as follows: To examine all proposals for development and zoning changes to insure they meet the requirements of the Cordova Bay Local Area Plan. To attend council and other relevant meetings on issues of concern to Cordova Bay. Provide information and assistance to community residents with issues pertaining to Cordova Bay.
The CBA represents approximately 800 member families in Cordova Bay.
The CBA has been following the EDPA bylaw implementation over the last
2.5 years, community feedback, open houses and most recently council dialogue regarding the bylaw. Based on our mandate above and our exposure to the EDPA, we offer you the following comments:
The CBA does NOT have any vigorous objections to the objectives of EDPA which are to Protect the areas of highest biodiversity within Saanich; Require mitigation during development; and Require restoration to damaged or degraded ecosystems during development. However, we feel that these objectives are too general and require further amendments with community consultation.
Our board and residents do have serious concerns and objections to the implementation of the bylaw, they are as follows:
- Maps- the area maps of the EDPA are not evidence based and not indicative of actual conditions
- Landholder Information- many landholders with EDPA designations feel ill-informed. Not enough information was shared with landholders and no stakeholder acceptance of the bylaw, contrast this bylaw with the Community Plans. Unlike other bylaws, “Existing non-conforming status” does not exist, we feel this status should apply to lands clearly lacking natural biodiversity but requiring protection.
- Lack of proactive work on the bylaw, most of the work happening over the last 2.5 years by Saanich staff is reactive. This is evidence of poor management, implementation and process.
- Application Review- the CBA has received notices from Saanich to provide feedback on 2 development applications related to the EDPA within last 2.5 months, the CBA was not consulted on Saanich’s intentions to do this. The CBA is a volunteer organization, with a low threshold for capacity, we should have been consulted on this process.
- Also, unlike the community plans, the EDPA is lacking in the rigor of community consultation, application and enforcement. It’s difficult for community associations to comment without good evidence. We feel dropped into the frying pan, this is not a good partnership.
- Clarity of enforcement- what say does the CBA have? How much power do we have? What say does the Manager of Environmental Services have? How is the opinion of one scientist/biologist less or more important than that of a staff scientist/biologist? Why is there not a community committee that is overseeing applications, like minor variances?
- How is landowner hardship considered? Stewardship must be balanced with taxpayer satisfaction. The CBA is asked to navigate this balance on a monthly basis as we review development applications. We do this knowing we have a community plan which is well vetted, lots of community involvement, good process and good science behind it (urban planning principles) The EDPA bylaw in our opinion lacks some of evidence based principles expected by citizens.
We feel these 7 points are significant enough to warrant a moratorium on the bylaw until such time as good bylaw can be redeveloped with accurate maps, evidence based science, good community consultation, good information to landowners, training to community associations to review applications, better enforcement, an appeal process to deal with hardships.
We would ask for immediate action on this matter, stop, revaluate and modernize.
We need your leadership to respond to community volunteers. We have no vested interest, other than a good bylaw, because we are on the frontlines dealing with a noble idea but poor process.
I welcome the opportunity to discuss a mutually beneficial plan to improve this important bylaw.
President, Cordova Bay Association for Community Affairs