Detailed analysis shows how Delta “Southlands” application fails in context of Metro Vancouver policies (Peter Duffey)

savethesouthlands-caIf local governments want an engaged populace, they have a model citizen in Peter Duffey of Delta. He is a long-time observer of civic affairs and well versed in policies and processes of the regional government — Metro Vancouver (GVRD). He has kindly shared his detailed analysis of the Southlands development application, approved by Delta City Council in November 2013, and going before Metro’s regional planning committee on March 7, and Board of Directors on March 28. Below is a summary, followed by his detailed analysis, both of which he has provided to officials at Metro Vancouver.

 Summary of why Delta’s RGS  Amendment  request should be refused.

  • It does not comply with any of the five Goals of the Regional Growth Strategy.
  • The request ignores the large majority of input from Delta residents, years of consultation, and at a cost approaching $500,000 of local taxpayers money.
  •  There is a mass of documentation which you have which clearly indicates this proposal is unacceptable. The Delta Official Community Plan was revised very recently after a long period of public consultation. This revision kept the Southlands designation and zoning has A1  Agricultural.
  • The project is on a floodplain, and in an area which has been identified as having a very high risk of liquefaction. Delta and the applicant have acknowledged that there would have to be a huge volume of imported fill to provide floor construction levels that will provide safety for residents.
  • The bylaws that have been passed by Delta include a Phased Development Agreement which would preclude any future Delta Municipal Council from amending or modifying any part of the development plan for a period of 20 years, unless the landowner agrees. Yet the development plan contains no information or detail of where or when the various types of structures would be built. All that is stated it is a Of 950 units. These could all be apartment blocks, or multistacked townhouses, etc. Far from obtaining certainty this Agreement would perpetuate uncertainty, which would be totally dependent on market demand and developer choice. This is an open-ended arrangement which is grossly unsatisfactory in any planning terms.
  • The disruption to of Tsawwassen would continue over a considerable period of time. Noise, dust, and  health contamination by the diesel particulate from at least 120,000 truck journeys through the main residential area would be a major disturbance. It is hard to see where there would be any commensurate benefits.
  • The supply of housing in South Delta is adequate, both in rental and ownership markets. Revisions to the Official Community Plan now allow infilling to proceed in many areas. With the Tsawwassen First Nation housing development within the area already offering affordable ownership there is no need for another high density development on the Southlands.
  • It is absolutely necessary to consider the impending sea level rise which is identified as 1 m by year 2100. The Fraser Basin Council has embarked on a two-year study to determine what should be the suitable policy of flood protection within the Lower Mainland. This has been supported financially by all municipalities in the Metro area, including Delta. Should Metro approve the Southlands development to proceed it will probably compromise future measures which will be needed to protect existing residences in BoundaryBay, and Beach Grove. It is quite clear that the eventual solution will be a programme of dyke protection. Quite apart from all the other objections this development it is clearly premature in the absence of a coordinated flood protection policy.
  • With such a large proposed development it is quite alarming to note the absence of a full independent health and safety analysis. There has been no published study of the effect of constructing 950 units perched on fill. The threat to existing residents from run-off requires detailed consideration. The bylaws do not show a firm plan of road layout, which will no doubt be dependent on the type of housing chosen, which is not determined in the plan. Emergency evacuation and access should be part of the consideration.
  • The assumed benefits for the community that  the Corporation of Delta assumes include the transfer of land to the municipality. It appears that this transfer is one of the reasons why Delta council thinks this is advantageous. The question of road ownership, and layout has not been examined properly. It appears that there will be a considerable proportion of bare land strata property where road maintenance will be the responsibility of local strata Council’s. Road access to the proposed community farming areas has not been shown, neither has the upkeep been discussed.
  • At this time the property owner leases approximately 235 acres of farmland to local farmers. Should this plan proceed, and Delta lease land to farmers in a similar fashion the amount of land would be almost identical. Much has been made that the landowner would provide money to improve the drainage and productivity of this land. The landowner has had possession of this land for 27 years during which time there has been little investment in land improvement or drainage. In fact the land for much of the time has been allowed to deteriorate without suitable care or maintenance. The conclusion is that it has been held on a speculative basis.
  • The inducement offered by the landowner subsidise the drainage and irrigation to the tune of $9 million seems to have clouded the judgment of Delta Council. It is difficult to discern any benefit to the residents of Tsawwassen however, as the use of land for community farming by the landowner will markedly reduce productivity of a considerable proportion of the transferred land. The B.C. Ministry of Agriculture has warned Delta that this would be an inefficient and unsatisfactory use of the land.
  • It is possible under the Agreement for the landowner to sell all or part of the property at any time to another company. The existing rights would be transferred, and could not be altered without agreement.
  • This proposal should be recognized as a move to obtain land value by redesignation and zoning without any guarantees that  anything will be built that looks like the pretty architect’s colour sketches that have been used to sell the concept.
  • Please read the detailed statement that is attached. Approval of this amendment request will be a disaster for local residents. The Planning aspects alone are riddled through with unspecified and unaddressed subjects.



Why the Delta Amendment Request should be rejected: 

Metro Regional Growth Strategy   

GOAL 1: Create a Compact Urban Area

            Contain urban development within the Urban Containment Boundary.   

The Southlands plan would create an isolated urban community outside the existing Urban Containment Boundary.  High-density housing, far from the Tsawwassen Town Centre, would fragment and significantly reduce the size of productive agricultural land and an environmentally-sensitive area. 

Focus growth in Urban Centres and Frequent Transit Development Areas.

 The Southlands plan for 950 units of mixed (mostly high-density) housing, and a commercial development, is inconsistent with the surrounding area, which is farmland adjacent to the environmentally-sensitive BoundaryBayRegionalPark, as well as existing areas of low-density housing.

 Transit service is infrequent, with no plans for improvement.  New residents would be car-dependent, living far from employment opportunities, medical and essential services as well as the amenities of the Town Centre.    

Protect Rural areas from urban development.

 The area has remained rural in character since the municipality of Delta was created.  Comprehensive Development in this location would negatively impact farmland, wildlife, and adjacent low-density housing areas.

 GOAL 2:  Support a Sustainable Economy

Promote land development patterns that support a diverse regional     economy and employment close to where people live.

 A sustainable economy recognizes the need for identifying and retaining agricultural and environmentally-sensitive areas which provide opportunities for farming, wildlife protection and recreation in the Lower Mainland.  Comprehensive Development in this rural area would negatively impact these resources.

 New residents would have to commute long distances for employment opportunities; this is contrary to sustainable principles. 

 Protect the supply of industrial land

 This is agricultural and environmentally-sensitive land.  Consequently it would be inappropriate to consider this area for industrial use. 

Protect the supply of agricultural land and promote agricultural viability   with an emphasis on food production.

 The loss of a considerable portion of the farmland to commercial and residential housing would not promote agricultural viability. A transfer of land to Delta would not result in any gain in agricultural production when compared to the existing situation.

The use of farmland leased back to the developer for a community farming scheme would be a very inefficient use of farmland, and has been criticized by the B.C. Ministry of Agriculture. That idea is more of a social project of doubtful viability, and actually would lead to the misuse of productive farmland.

 Bisecting and losing 47% of 537 acres of contiguous farmland to residential housing, commercial, and recreational uses would not promote agricultural viability. A transfer of land to Delta would not result in any gain in agricultural production when compared to the existing situation.

 This development would require construction of a new Municipal Road, of collector width plus cycle lanes, from the main street in Tsawwassen (56th St.) through the middle of productive agricultural land to Boundary Bay Road.  The road, using 6 acres of farmland, would detrimentally bisect farmland currently leased for food production.  The planned community farming project area would require an additional service road network which would further reduce the quoted 53% planned farmland to less than 50%.

 GOAL 3:  Protect the Environment and Respond to Climate Change Impacts

             Protect Conservation and Recreation lands.

  Delta is seeking approval to amend the Regional Land Use Designation of 252 acres from ‘Agriculture’ to 147.5 acres of ‘Comprehensive Development’ and 104.2 acres of ‘Conservation and Recreation’.  The amendment does not recognize and protect the habitat values of this land as the associated Delta Bylaw 7169 would rezone the lands to ‘Comprehensive Development’ and ‘Public Use’ without any recognition or protection of this internationally-significant habitat.

 A strip of treed land adjacent to the community of BoundaryBay would be added to the Urban Containment Area and proposed to be zoned Public Use and designated Environmentally Sensitive in Delta’s bylaws.  However, by including it within the Urban Containment Boundary, Delta could rezone the land for housing in the future without seeking approval from Metro Vancouver.

 The pressure of 2000 or more new residents and their constant movements would adversely affect the protected areas of the BoundaryBayRegionalPark, and the Boundary Bay Wildlife Management Area, which have been created by all levels of government at public expense. It should be noted that in June 1995 the Century company received $7.5 million of taxpayers’ money so that the BoundaryBayRegionalPark protected areas could be established.

 Considerable public funds have been expended to improve the facilities at CentennialBeach. To inject the pressure of this development proposal on this recreation area would undoubtedly require further expansion and expenditure from public funds.

              Protect and enhance natural features and their connectivity.

 This development would do nothing to meet these objectives. In fact it would have significant adverse environmental effects. The RGS recognizes the need to define boundaries that maintain vital ecosystems with interdependent habitat corridors.  Not only is this a large block of Tsawwassen’s valuable farmland, it is also unique critical wildlife habitat stretching from the important forested area shared with Point Roberts, across open fields to the foreshore of Boundary Bay. 

The area is environmentally fragile and should remain protected by the current Urban Containment Boundary which defines this natural asset of shoreline connecting with fertile floodplain to provide farmland combined with habitat of international importance.

These are key components of the number one Important Bird Area in Canada1.  The current Urban Containment Boundary in the RGS (previously called Green Zone) at this location supports the Boundary Bay Wildlife Management Area 2, the Boundary Bay RAMSAR site3, and a declared Western Hemisphere Shorebird Reserve Network site4. Development on the Southlands would negatively impact this protected area by removing adjacent wildlife and upland corridors, by introducing significant light, noise and air pollution, and by increasing intrusions.

 1Canada’s Important Bird Areas Program is a science-based initiative to identify, conserve, and monitor a network of sites that provide essential habitat for Canada’s bird populations.

2 A Wildlife Management Area is an area of land designated under section 4(2) of the Wildlife Act for the benefit of regionally to internationally significant fish and wildlife species or their habitats.

 3 The Convention on Wetlands (Ramsar, Iran, 1971) — called the “Ramsar Convention” — is an intergovernmental treaty that embodies the commitments of its member countries to maintain the ecological character of their Wetlands of International Importance and to plan for the “wise use”, or sustainable use, of all of the wetlands in their territories.

4  The Western Hemisphere Shorebird Reserve Network (WHSRN) is a conservation strategy launched in 1986 with the designation of the first site, Delaware Bay in the United States.  The Network aligns with the simple strategy that we must protect key habitats throughout the Americas in order to sustain healthy populations of shorebirds. To date, WHSRN site partners are conserving more than 32 million acres (nearly 13 million hectares) of shorebird habitat.

  Encourage land use and transportation infrastructure that reduce energy      consumption and greenhouse gas emissions and improve air quality.

 Constructing 950 housing units plus commercial development in this area will result in significant increase in vehicle mileage, both commercial and residential, with the associated use of energy and pollution. Added to that would be the discharge volume from heating units in homes and commercial premises to further reduce air quality. The adjacent wildlife habitat and protected wildlife areas will suffer commensurately.

 The Southlands development proposal does not mesh with Metro Vancouver’s strategies to meet greenhouse gas emission targets.  The project would generate thousands of car trips on the Tsawwassen peninsula because it is far from work locations and amenities.

The project requires millions of tons of fill with at least 120,000 diesel truck movements polluting the community with deadly particulates.  Additional emissions would be generated through 20 years of infrastructure development and building construction.

 Encourage land use and transportation infrastructure that improve the ability to withstand climate change impacts and natural hazard risks.

 This development requires an independently conducted Hazard and Health Assessment. The area is inter alia subject to a very high risk of liquefaction (B.C. Insurance Industry assessment).

 Both Century Industries and the Corporation of Delta have accepted that there is need for a huge quantity of fill to protect the proposed development from the forecasted rise in sea level.

Without an exact and detailed plan on where and what type of housing and commercial construction would be situated it is hard to determine the road layout that wouldl evolve. Yet there is a need for this information to determine how surface water and floodwater would affect the development and BoundaryBay village.

A much more detailed and careful examination is required. Initially it appears that the use of a Flood Construction Level lower than what had been recommended by consultants both for the proponent, and Delta, should also be questioned. The use of more fill volume may be required.

 However, the development proposed bylaws make provision for at least 120,000 diesel truck journeys through the centre of Tsawwassen. A health study is necessary to determine the safe level of diesel particulate that can be discharged by this volume of traffic through a densely populated area.

A full engineering study should be conducted to determine emergency evacuation routing in case of flooding, and/or earthquake.

 GOAL 4:    Develop Complete Communities

             Provide diverse and affordable housing choices.

 With regard to housing diversity, it is clear from the Phased Development Agreement that there is no specific commitment to any mix of housing type, and that the choice of what will be constructed would be determined solely by market demand at the time of construction.

 Without information on the mix of cottages, apartments, townhouses, stacked townhouses and single family houses, or the number of mixed unit high-rises, it is now obviously impossible to determine if this Goal is satisfied by what in essence is simply a draft planning proposal to obtain added value for the land.

            Develop healthy and complete communities with access to a range of             services and amenities.

 The Southlands Project would not meet Metro’s goal of a complete community.  The plan would plunk tall, high-density buildings and a 1.8 acre commercial development into an existing farmland and habitat area.  As the plan is not consistent with the existing uses, it would create an anomaly within Metro Vancouver’s recognized green zone.

 Transit service in the area is infrequent with no plans for improvement.  The development is far from services and amenities.  The plan invites 20 years of construction which would urbanize an area that is important for food production and internationally-significant habitat protection.

The Phased Development Agreement bylaw would allow the developer total flexibility to determine the type and character of housing. There is no specific portion allocated to single family, apartment condominium, townhouse, stacked townhouse, cottage, rental, or social housing.

 This is not acceptable Planning, and invites a planning nightmare. This bylaw would be inviolate for 20 years. There is also no indication of the bare land strata content, which would affect road ownership, infrastructure cost and maintenance, and could affect the overall safety of the project.

 The developer has already stated that homes would be sold at market price. This does not indicate “affordability”. In Tsawwassen there is a very good supply of homes now available for purchase which  covers a broad spectrum of price range and type. The development would no doubt be comparable to this existing market choice, but not offer any price advantage.


 GOAL  5.      Support Sustainable Transportation Choices

             Coordinate land use and transportation to encourage transit, multiple             occupancy  vehicles, cycling and walking.       

             Coordinate land use and transportation to support the safe and            efficient  movement  of vehicles for passengers, goods and services.

 It would be a considerable period before Translink could identify the need for a more frequent transit service to this area.

 The use of cars will be essential, yet the planned car parking space is about 50% of the existing Delta requirements. This is totally unrealistic.

 In the current plan, road widths are not clarified and this would be dependent on the bare land strata content and overall parking space provisions.

 Separation of cyclists from traffic is virtually non-existent throughout Tsawwassen, and is achieved at present only by painting symbols on the road surfaces. This development does not indicate how cyclist safety would be achieved. This is related to the lack of a full road plan.

  The encouragement of multi-occupancy vehicles is a Provincial target that is not being achieved because of less than energetic promotion and legislation. Tsawwassen as a whole would benefit from this goal being achieved but this development would not in any way further such progress.

Cycling and walking ease is being touted as an attractive offshoot of the development proposal. If approval or denial of this development relied on this factor alone, such benefits could possibly exist. However it is more than probable that they would be confined to those days when the weather is suitable, and when the residents are not working. Vancouver has already discovered that use of cycling lanes is of a low volume. At this time there is no shortage of roads, lanes, and parks for walking in Tsawwassen.

   It is rare to see cyclists using the many marked cycle lanes in Tsawwassen.    


 To further illustrate and increase clarity a list of the many problems with this development is included below.

 1. It fails the goal of creating compact urban areas within the Urban Containment Boundary.

Tsawwassen already has a compact urban area in the Town Centre where there is ample opportunity for more housing.  There are many housing projects underway with at least 672 new units.
 2.   The Project is not located in an area close to employment opportunities.  People in  Tsawwassen mostly work outside the community which is a reason for retaining the Urban Containment Boundary that has already been established.
3.   The area does not have an efficient transportation network.  Transit service is infrequent with no plans for improvement.
4.  The heights and densities do not begin to fit into the surrounding natural areas and nearby housing units.   The proposed housing would allow for three-storeys with a density of 123.5 units per hectare compared to the existing 8-18 units per hectare in BoundaryBay.
5.   The Project’s planned parking spaces are inadequate and will create future problems – probably expansion into areas of farmland and habitat spaces.  This can be done as there is no zoning for protection of habitat.  Almost half the land is zoned for Comprehensive Development or Public Use. 
6. The Project introduces inappropriate development in the middle of environmentally-sensitive agricultural land.  As the plan is not consistent with the existing uses, it will create an anomaly within Metro Vancouver’s recognized green zone.

7.   The Development fails to “protect rural areas from urban development” by building new concentrations of mixed, high-density housing and commercial development in the middle of farmland.

8.      The Development fails to “protect rural areas from urban development” by constructing a new municipal road through the middle of productive farmland in the Green Zone.  This will be a new thoroughfare connecting BoundaryBay to Tsawwassen’s main highway artery, 56th Street.

9.      The Southland’s proposal would see only 51% of the 537 acres retain the current  Agricultural Zoning.  The rest would be rezoned for Comprehensive Development, Public Use and a new municipal road bisecting the property.  This cannot be interpreted as protecting farmland.

10.    Delta and the Proponent will argue that the irrigation and drainage will promote agricultural viability but the cost of losing half the land to other uses does not meet the aim of protecting the supply of farmland.

11.    The land is already being farmed and, as stated by the B.C. Ministry of Agriculture (letter to Delta Council, May 15, 2013), the proposed development will not be a net benefit to agriculture.

12.    The plans include fragmentation of a significant portion of the farmland into small parcels for a Community-Based Farming Model.  There is no substantive information to prove that this would be the best productive use of the farmland.  To the contrary, Delta has received information from the B.C. Ministry of Agriculture raising concerns about lack of sufficient information on which to base this plan 

13.    There will be long-term significant financial and environmental risks to the community.  The infrastructure building and maintenance costs for Delta will be high in spite of costs paid by the developer.

14.    There will be reduction and fragmentation of the green space and large tracts of the valued floodplain will be destroyed with fill impacting the entire sloping region from 56th Street to BoundaryBay.

15.    The Development Plan contravenes Metro’s goal of defining and protecting boundaries that maintain vital ecosystems with interdependent habitat corridors.  Not only is the vast stretch of the Southlands valuable farmland, it is also unique, critical habitat stretching from forested habitat across open fields to the foreshore of BoundaryBay.  The area has international significance for migratory and resident birds. 

16,    Metro works to protect natural areas such as the MetroVancouverBoundaryBayRegionalPark.  Development on the Southlands will negatively impact this protected area by removing adjacent wildlife and upland corridors, by introducing significant light, noise and air pollution, and by increasing intrusions.

17.    The area is environmentally fragile and should remain protected by the current Urban  Containment Boundary which defines this natural asset of shoreline connecting with fertile floodplain to provide farmland combined with habitat of international significance.

18.     One area proposed for removal from the green zone for “Urban” designation is designated environmentally-sensitive in the Official Community Plan; a future application to rezone this area would not require approval from Metro. 

19.     This Application does not include all the properties in this large tract of green space. Three properties are not included so, if a precedent is set, Metro could be approached for future alterations of this Urban Containment Boundary.

20.      The Southlands development proposal does not meet Metro’s strategies to meet greenhouse gas emission targets.

21.      The project will generate thousands of car trips on the Tsawwassen peninsula because it is far from work locations and amenities.  The development is not located in a transit development area so housing development will add congestion and air pollution to an already overloaded road system.

22.      Development of the Southlands will add significantly to car-dependent Tsawwassen.  There are no plans for increased transit and the Tsawwassen main artery, 56th Street is not bicycle-friendly.  The proponent is advertising the project as bicycle and walking friendly but those attributes will be confined to the Southlands and the existing BoundaryBayRegionalPark and dike.  Movements outside this area require cars.

23.      The project requires millions of tons of fill with 120,000 diesel truck movements polluting the community with deadly particulates.  Add additional emissions generated through 20 years of infrastructure development and building construction.

24.     The Southlands Project does not satisfy the goal to prepare for, and mitigate, risks from climate change and natural hazards.  There has been no independent assessment of impacts of natural hazard risks and climate change.  The Southlands proposal is located in an area that has a very high risk of liquefaction in the event of an earthquake.

25.      There is a risk of flooding from natural causes or as a result of fill and construction on the site.  Flood construction levels adopted for this proposal do not meet potential sea level rise by 2100.

26.      People who buy homes in the area will be required to indemnify the Municipality against claims arising from flood risks. This illustrates the risk problems.

27.      There has been strong opposition to developing the Southlands properties with a majority of residents calling for retention of this fertile floodplain for agriculture and habitat values.



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