June 22, 2019

District of Saanich

770 Vernon Avenue

Victoria, BC  V8X 2W7

Dear Mayor and Council,

RE: GHRA Comments on Staff Report from Director of Planning Dated May 30th, 2019

Environmental Policy Framework – Proposed Work Plan.  File # 1030-30

The Gordon Head Residents Association (GHRA) board has discussed the EDPA bylaw on several occasions, dating back as far as 2015.  We have recently reviewed the Saanich Staff Report entitled “Environmental Policy Framework – Proposed Work Plan” prepared by the Planning Department and discussed at your June 10th, 2019 Committee of the Whole meeting.  Given that our board members were unable to attend the meeting on June 10th, we have also reviewed video of the Committee of the Whole meeting that night.  The GHRA board offers the following comments to Mayor and Council for your consideration:

1)Endorsement of Councilor Mersereau’s June 10th Position: We would like to endorse the carefully considered, balanced position that Councilor Rebecca Mersereau expressed at the June 10th Committee of the Whole meeting during the discussion on Agenda Item II.D.4 Environmental Policy Framework – Proposed Work Plan.  In particular, we concur with Councilor Mersereau’s position that biodiversity conservation is consuming a disproportionate amount of public, staff and council resources, when as a community, we should be addressing other equally pressing environmental issues.  Councilor Mersereau highlighted protecting the Colquitz River, supporting pollinators and preventing the continued loss of urban tree canopy as examples of issues that are not receiving enough attention in Saanich.  None of these issues will be adequately address by implementing a new EDPA bylaw – we believe they require more comprehensive strategies and resources, and renewed debate over re-implementing the EDPA is clearly frustrating moving forward together on important environmental issues.

2)Disagreement with the Single-Pronged Strategy Recommended by Staff: The Staff Report entitled “Environmental Policy Framework – Proposed Work Plan” contains the following graphic on page 13:

The GHRA board does not disagree with the intent of this graphic – that is, to show mayor and council that development permits as a regulatory tool arguably provide staff the most control in influencing various development application types.  However, what we would like to highlight is what is missing from this diagram.  There is no mention in the diagram of other planning tools necessary for affecting positive change in communities.  Regulation by itself is arguably an ineffective planning tool – regulation is far more stable and effective when combined with aggressive education and incentives programs.  Without education and incentives, regulation acts like a “stick without a carrot” so to speak.  The lack of understanding and goodwill created by education and incentives results in mistrust and frustration.  We believe this is the root of why the EDPA was rescinded in the first place. What is missing from the above diagram is other planning strategies that are equally as important as regulation to moving a community forward constructively.

3)The importance of Rigorous Science to Guide a New Regulation: The GHRA board has significant concerns about staff’s recommendation to use ‘citizen science’ for data collection (Page 14 of the staff report).  A new EDPA bylaw will affect private property owners’ rights and privileges on their own properties and cost property owners money, so the data collected to essentially trigger the EDPA on specific private properties ought to be rigorous.  Without proper oversight by independent scientists, citizen science would be analogous to Victoria’s annual spring flower count.  Citizens are encouraged to participate in the flower count, but it is clear from the outset that the data collected has a limited purpose (ie: fun promotion of Victoria’s warm spring to tourists).  Citizen science used to collect data for new EDPA maps could serve as part of a public education program and/or engagement strategy, but the independent scientific verification required to render it useful for an EDPA bylaw would most certainly be costly and time consuming.

4)When the Provincial Government allowed municipalities to enact control of land by the use of  zoning bylaws, it also mandated that municipalities create a fair and transparent redress process for landowners who believe that they had been treated unfairly to get relief. The Board of Variance provides this mechanism for redress. The only aspects of the proposed actions in the staff report that are open to such a process are tree protection bylaws that can be appealed to the Saanich Board of Variance. If Saanich is to proceed with developing a new EDPA bylaw or interim measures, the GHRA board strongly recommends that Council create a redress process that is a fair, equitable and public, so that citizens may have a way to appeal interpretations of regulations or decisions affecting their property.

Considering the clear tension in our community over how best to develop Saanich’s new strategy for biodiversity conservation, the GHRA board urges Mayor and Council to move forward carefully.  We hope that council will pursue a more comprehensive strategy to addressing environmental issues in Saanich – one that de-emphasizes regulation and embraces a cooperative and constructive approach with citizens.  In closing, we respectfully suggest investment in two positive, immediately actionable biodiversity conservation initiatives:

1)Ecological restoration efforts in Saanich’s wonderful parks; and,

2)Education and incentives programs for property owners.


Gordon Head Resident’s Association (GHRA) Board of Directors.