Thursday, January 27, 2011

Submission to View Royal OCP review

President: Terry Eckstein 12 Phillion Pl Victoria, B.C. V9A 4H9 Tel: 250 388 0398 email:
Portage Inlet Protection Society
Representing waterfront residents on Portage Inlet, Gorge Waterway and their tributaries

A submission to the review of the View Royal Official Community Plan
by the Portage Inlet Protection Society
April, 2010

Executive summary
The Portage Inlet Protection Society has been invited, as a stakeholder group, to make a submission for inclusion in the OCP review. This paper is based where possible on best available science, is economically feasible, and promotes sustainable environmental principles
Studies are described which show that Portage Inlet generally has good water quality. Toxicological studies published in 2010 show that organochloride pesticides are likely of limited or no toxicological significance. There is no evidence that waterfront owners contribute any significant pollutants to the Inlet. However, fecal contaminants from watershed storm drains cause shellfish pollution, as do sewer overflows .
Topics discussed include: ecotones, buffers and setbacks in relationship to Development Permit Area (DPA) widths; exemptions to activities in DPAs; sea walls to protect from erosion; climate change and sea level rise; wharfs and docks; public access pathways; and riparian rights.
Recommendations conclude this paper.

PIPS members value the quality of the environment. As stake holders we are allies of the Town in preserving our natural surroundings. In our newsletter The Shoreline Guardian, distributed to all shoreline residents on Portage Inlet and the Gorge Waterway, PIPS promotes awareness and proactive stewardship by remaining current with research based on best available science. We discourage application of domestic chemicals near the water between September and May

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while salmon are present in the Inlet. We promote Best Management Practices on our properties at all times.
Portage Inlet requires protection from human-generated pollution occurring within its watershed. View Royal should control, where possible by design, storm water contaminants entering Portage Inlet and Craigflower Creek. All properties within the catchment area contribute storm water volume as well as silt, pollutants, unwanted chemicals and metals, plus introduced nutrients.
The Town will install engineered bio-retention on Island Highway. Bio-retention can remove 80% of nitrates and 80% of phosphates as well as metals. Any storm drains entering Portage Inlet can be retrofitted with modern de-nitrification filters.
All new developments using Limited Impact Development (LID) techniques will reduce peak storm-flows and can reduce pollutants. The Capital Regional District’s Annual Stormwater Quality Report, Core Area 2007, provides the most recent figures. (Testing was discontinued in 2008 to concentrate resources on identified issues.)

Present condition of Portage Inlet
Portage Inlet pollution is much reduced since View Royal septic tanks were replaced by sewers. Previous annual algal blooms in May due to excess nutrients from septic runoff no longer occur.
The 2008 measurements in surface water of oxygen, turbidity, nitrates, and pH are below pollution levels and summer coliform counts are safe for swimming but exceed shellfish harvesting safety levels. Native oysters are now abundant in Portage Inlet. Living adult oysters were extremely rare in Portage Inlet, though present in the Gorge in 1967 (P. Lambert 1967). Oyster presence is probably an indication of improved water quality. Portage Inlet is a migratory bird sanctuary and the oysters, clams and eel grass are providing regular forage. The birds are thriving.
Otters are higher up the food chain, live on fish and concentrate fat-soluble organochlorine PCBs and organochlorine pesticides in their bodies. Measurements of organochlorines in otters foraging in Victoria harbour as well as east and west along the coastline have been made between 1998 and 2006. Otters living in Victoria harbour are exposed to legacy PCBs. Those at a distance have much less, including a family that hunt in Portage Inlet. As well as measuring PCBs, organochlorine pesticides were measured. Even among Victoria harbour otters with 9 x higher PCBs the organochlorine pesticides, which are at the “no effect level”, are “generally low throughout the region and are likely of limited or no toxicological significance”. Other biota (crabs and herons) reflect the same results. ref: Environmental Toxicology and Chemistry Volume 29 #2 pp 275- 284, 2010.

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The conclusion is that Portage Inlet is currently healthy in the summer and pesticide residues are insignificant. There is still contamination by heavy metals and PAHs, etc., contributed by vehicles traveling the nearby Trans Canada Highway. (Polycyclic aromatic hydrocarbons (PAH) are airborne particles which may be carcinogenic to humans if inhaled. They cause no harm to humans if dissolved in water.)
Colquitz Creek in Saanich has coliform counts of 340 and 360 which exceeds the safe swimming level of less than 200. This is from human sewage.
Craigflower Creek exceeds the guidelines for watercourse health in turbidity (from erosion), phosphates and fecal coliform originating from a developed area about 1,200m upstream. This requires ongoing monitoring and mitigation.
Hospital Creek had excess phosphate and coliform counts increasingly since 2005. Coliform is 340 and 1800 in winter and 620 in summer. There are many possible causes, but it is likely from human sewage. Further investigation is required to identify the source(s). Agricultural chemicals may contribute to the phosphates.
Storm Drain 0712, in the southwest corner of Portage Inlet, contributes much environmental contaminant; sediment sampling has been recommended. Fecal coliform counts of 120,000 (60 x the acceptable limit) has been cited as a priority. View Royal staff have narrowed down the source.
A serious source of sewage pollution occurs when overflow occurs at pump stations. This happens during storm events when storm water enters and overloads the sewer system or when there is a pump failure. The Scientific and Technical Review Panel, CRD Core Area Liquid Waste Management Plan, July 12, 2006, stated: “Municipal storm water waste management and watershed discharge affect marine areas where outflows are located. Overflow of sewage facilities causes severe fecal plumes, contamination of habitat and potential risk to human health.”
Waterfront properties contribute very little in the way of contaminants to Portage Inlet compared with the present traditional storm water drainage system. Withal, some form of protection should be employed for new development or redevelopment of Portage Inlet waterfront. The protection should be evidence based.

The salt water–upland interface is an ecotone which extends seaward to the low tide line and landward to the limit of salt-water penetration. An ecotone has a sinuous boundary; its length, width, nature, continuity, patchiness and height vary.

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It varies on a daily and seasonal basis, changes over years and decades. It is a source of energy and materials. It provides organisms, logs, nutrients, plant carbohydrates and insect proteins. It modifies wave energy, heat, and hydraulic flow which varies with tide height. It amplifies or reduces the intensity of waves by reflecting energy or absorbing energy by “run-up”. It acts as a mediator, filtering and altering chemical processes. It smoothes external impacts. It constrains energy and hydraulic pressure. Ecotones change humidity, temperature and sedimentation rate. They speed up mineralisation of organic matter and accelerate sediment build up. Ecotones change vegetation and nutrient retention.
It is unscientific to apply riparian (riverbank) ecology to saltwater estuarine upland. Likewise the term “riparian” cannot be used to describe a “supralittoral fringe” (above the beach) upland area. There are those who use the term, "marine riparian" instead of the term, "supralittoral." It is impossible to have a riverbank above a tidal beach. The misuse of “riparian” leads to confusion. The Department of Fish and Oceans is aware of this and emphasizes that you cannot apply the Riparian Area Regulations of the Fish Protection Act to the marine environment.

Buffers are that part of the ecotone between the natural boundary of the sea and
the landscaped upland above. In an attempt to apply best available science for
application of buffer widths and setbacks for urban coastal land planning use, a
Marine Riparian (sic) Expert Professionals’ Workshop was held in Tsawwassen
on February 17-18, 2004. It was a joint meeting of Fisheries and Oceans Canada
(DFO) and the Puget Sound Action Team (PSAT), Washington State.

The DFO/PSAT gathering identified data deficiency for establishment of vegetation buffer widths, aesthetic functions, soft versus hard engineering approaches, the effect of ground water flow disturbance and specifications for different plant species for their functions as restoration tools. Variable buffer widths by function was expressed: “Setback distances should be flexible at the time of decision, and all relevant issues should be accommodated in making decisions.”
Jim Brennan (King County Dept. Natural Resources, WA) states: “Unlike buffers, setbacks seldom account for ‘riparian’ or other coastal functions.” Variable vegetated buffer widths are difficult to implement in an urban environment with small lots but a narrow width can be set and expanded according to size of lot (as in Rhode Island). Likewise, setbacks should not be so restrictive as to totally, or nearly so, prohibit development. Single family

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residential development requires a 15 to 25-foot (4.5-7.5m) buffer for lots less than 10,000 square feet.
The main environmental value of a building setback is to leave room for a ground cover of grass to slow the surface runoff, control erosion, and for bacterial de-nitrification. This can be as little as 3 feet and up to 20 feet (three ft. removes 99% of coliform – Tillamook, Oregon). A 15-foot vegetated filter strip reduces nitrogen by 90% (Maddison et al. 1992). Most nitrogen removal is by de- nitrification; 66% by soil bacteria, 33% by plants. Roots promote soil bacteria. Most de-nitrification occurs in the top 6 inches, 88% in the top 2 cm. Trees are more effective than herbaceous plants because tree roots penetrate deeply and produce more carbon at depths. The area closest to high water should be planted with salt-tolerant trees that remove pollutants and nitrogen, which they store. To be effective, trees must be harvested or their nitrogen is restored to the buffer after they die. Trees also stabilize soil and protect against erosion. This buffer provides animal and bird habitat and increases biodiversity. Poplars remove up to 99% of nitrogen in surface runoff. Residential upland supplies nutrients and water so that a buffer works better than an undeveloped comparison. (Simmonds et. al. 1992)
Trees in a buffer should be pruned in the lower third or at least up to two metres for reduction in fire hazard. Excess fuel should be removed. Trees can be pruned to provide views, but should be thinned to reduce the chance of fire spreading from tree to tree. Deciduous trees are preferred over evergreens because of reduced fire hazard potential. Enough room should be available for a 10m. priority zone immediately adjacent to a given building to create an environment that will not support fire of any kind. [ Land Use Planning – FireSmart Chapter 7 p15.]
Newly-established buffer zones reach maximum function in 15-20 years. Shrubs provide limited function compared to grasses and trees. Lush weed-free grass lawns, such as creeping red fescue, remove pollutants and their rhizomes stabilize the soil. Grass is 3-6 times more efficient in nitrogen removal than other plants.

Development Permit Areas (DPA)
On July 14, 2009, an interim Natural Watercourse and Shoreline Areas Interpretation Policy, dated July 9, 2009, was presented to View Royal Committee of the Whole -- File #550-20-01.
The purpose was to clarify what areas were subject to the DPA.
The 1999 OCP contains a number of inconsistencies which make application of a policy difficult for Staff. An interim policy was later adopted for use until the new OCP provides rewritten DPA guidelines.

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A PIPS director made some comments at the time but was told by Council that the policy was only interim and that PIPS would have full input through the OCP DPA guideline review process. This submission with recommendations is presented as PIPS' carefully considered advice.
The width of a marine shoreline DPA describes the distance from the natural boundary of the sea within which a development permit is required. It is not to be confused with fresh water which is protected by the Riparian Area Regulations (RAR) of the Fish Protection Act (FPA)
The purpose of the DPA is to protect an Environmentally Sensitive Area (ESA) such as Esquimalt Harbour. Portage Inlet, Craigflower Creek and Millstream Creek.
At issue is the decision whether to apply a DPA width of 15m from high water mark or to include a whole parcel. Does a development permit applied to 15m provide sufficient protection? It is known that a 15-foot (4.6m) vegetated filter strip removes 90% of nitrogen, 80 % of phosphate, and 50% of sediment and pollutants. In general, doubling the vegetation width only increases the mitigation by 10%.
To apply the DPA to a whole parcel could mean that for deep lots, such as at Hart Road on Esquimalt Harbour, the DPA would be 127m and a little less on some parcels on View Royal Avenue.
Lots bordering Portage Inlet are much smaller; 20 to 25 lots are 30 to 37.5m depth. The application of a DPA to the total area of small lots as well as larger parcels will require time consuming and expensive development procedure for no additional environmental protection. Applications for a variance will needlessly take the time of staff and Council alike. PIPS views application of DPAs to entire parcels as unfair, onerous, overly-bureaucratic, an unnecessary expense and creating hardship.
If there is concern about development activities adjacent and upland of the 15m DPA, this can be addressed by enforcing Best Management Practices (BMP) as well as demanding satisfactory vegetation enhancement appropriate to the probable functions of a 5m buffer zone. All FireSmart recommendations may be considered.
The Town can include Low Impact development (LID) principles.
PIPS therefore argues that Option A (staff's second choice), a maximum DPA of 15m from high water mark, be used as the guideline in the revised OCP and to remove confusion.
PIPS also recommends, for clarity and, importantly, in compliance with the Local Government Act (LGA), that a list of exemptions be included.

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Central Saanich OCP bylaw #1600, attached to the “Interim DPA policy” provided to View Royal Council July 2009. lists 16 exemptions. PIPS supports, where appropriate, most of the list, provided that a correction is made to a recurrent error which replaces "Qualified Environmental Professional (QEP)" — whose expertise is confined to freshwater application in the RAR — with a suitable expert such as a "Qualified Coastal Professional (QCP)" who has established marine shoreline expertise.

The exemptions which matter the most to PIPS under by-law 1600, 11.25. are:
C. The placement of impermanent structures, such as benches, tables and garden ornaments.
E. Repair, maintenance, alteration or reconstruction of existing legal or legal non-conforming buildings, structures or utilities provided there is no alteration of undisturbed land or vegetation (a building permit may still be required). For clarity a structure damaged more than 75% may be rebuilt on its existing footprint.
F. Repair and maintenance of existing roads, driveways, paths or trails, provided there is no expansion of the width or length of the road, driveway, path or trail, and no creation of additional impervious surfacing including paving, asphalting or similar surfacing.
G. Removal of trees deemed hazardous by a qualified arborist that threaten the immediate safety of life and buildings.
H. & J. Removal of invasive plants or noxious weeds on a small scale within the DPA provided such works are conducted in accordance with a vegetation management plan prepared by a certified expert and measures are taken to avoid sediment or debris being discharged onto the foreshore and the area is replanted immediately in accordance with Best Management Practices.
K. Construction of a fence so long as no native trees are removed and the disturbance of native vegetation is restricted to 0.5m. on either side of the fence.
N. Gardening and yard maintenance activities within an existing landscaped area, such as lawn mowing, tree and shrub pruning, vegetation planting, and minor soil disturbance that do not alter the general contours of the land.
O. The construction of a small accessory building such as a gazebo, garden shed or play house within an existing landscaped area, native trees are retained and no nearer than 10m. from HWM and total building area does not exceed 10m. squared.
P. Emergency actions required to prevent an immediate threat from fire, flood or to erosion protection works.

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Doug Myers of Puget Sound Action team, Office of the Governor, in discussion of guidelines within urbanized areas, concluded that neither managers nor scientists should act to reinforce the management measures in current legislation because the measures are somewhat arbitrary. They should instead advocate adjustments justified by best available science.
Rhode Island Redevelopment considers parcel size and recommends setbacks of 4.5 to 7.6m. for lots under 10,000 sq. ft. (A. Desbonnet et al). A 5m buffer removes 50% of sediment and pollutants.
Seattle’s Shoreline Master Program, August 2008, recommends a setback of 7.6m for residential development (SMP Policy Paper, Aug 26, 2008).
Washington State has site-specific setbacks so that a setback is 1/3 of the height of bluffs up to 100 feet. Therefore, a 30-foot bluff would require a 10-foot setback.
Saanich does not establish marine DPAs.
DFO is silent on the matter because of data deficiency but states “setbacks should be flexible at the time of decision”.
Green Shores, quoted by staff, is a voluntary, new, untried pilot project which “...enables project planning and design so that site-specific cost-effective solutions can only be achieved by using an integrated design approach.” Consequently, they recommend different setbacks for rocky shores, beaches, estuaries, mud flats, and coastal bluffs.
Green Shores states that “...rocky shores are stable and erosion resistant”. Surface bed-rock can support only limited vegetation (moss but not trees) and therefore a vegetated buffer cannot be grown. Reduction of a 15m setback to 5m (or 1/3 of height) would be subject to assessment by a Qualified Coastal Professional (QCP). Rocky shores are present in parts of Portage Inlet as well as in Esquimalt Harbour.
Mud flats are accreted from sediment derived from Craigflower Creek’s watershed. Vegetated buffers provide more protection to mud flats than setbacks.

Apart from site-specific variables by shoreline type described above, landowners may apply to the Town for setback exemptions in cases where a 15m. setback makes a developable area of a lot too small to be developed for its intended purpose.
Erodable shores require special consideration. Eroded shores in Portage Inlet have been armoured for many years as a protection by landowners against loss of land. DFO's March 2001 Fact Sheet states, “...shoreline vegetation is effective in sloped areas not directly influenced by wave energy. Steep bluffs cannot be

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protected solely by shoreline vegetation.” Winter storms on Portage Inlet are becoming more severe and frequent. If occurring at high tide, waves are running up and over sea walls and washing out upland soil and vegetation, contributing to siltation. Wave energy is considerable. DFO recommends a rip rap with size based on flow rates, the least requiring a 70% composition of 20 to 45cm rocks to absorb low velocity scour, with a minimum of a 45 degree slope at the base of vertical walls; however, a 2:1 or 3:1 slope is preferred. This also increases habitat and biodiversity. Permission is required to place rip-rap on Crown land though it is usually given if the purpose is to improve habitat

Sea Walls
PIPS believes that permeable sea walls should be constructed in such a way as to allow hydraulic processes to remain as natural as possible without changing the pressures exerted on the shore substrate — and living organisms therein — or affecting upland soil stability with an increased water pressure or natural saline penetration.
Pesticides and metals often bond to silt . To avoid silt traversing the wall, silt cloth or engineered gravel detention layers should be constructed. Though seldom necessary for a small home project. a Qualified Coastal Engineer (QCE) can provide advice. A QCE is an engineer, geologist or geotechnical engineer with demonstrated experience and/or training pertaining to shoreline protection measures and coastal processes.

Sea Level Rise (SLR)
PIPS members, by their location, are a group of stakeholders who are most vulnerable to SLR. We are concerned about a predicted SLR of 126cm as postulated as a worst case scenario by the International Panel on Climate Change. Should a storm surge combine with a high-high tide, plus wave run-up, this could reach 175 cm. Sierra Club quotes 6 meters, even 35 meters.
The tectonic plate subduction is an additional factor. If a severe earthquake occurs (risk 1% every 100 years) then a isostatic (bedrock) drop of 2m. would occur almost instantaneously, followed by a 12-foot-high tsunami.
View Royal requires a Sea Level Rise plan based on these three scenarios: storm surge, sea level rise and subductive earthquake. The OCP review should include these considerations.
As far as PIPS members and Esquimalt Harbour residents are concerned, property owners need to take precautionary measures to prevent erosion. For

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existing structures, Green Shores recommends enhanced shoreline protection. Seawall enhancement should be encouraged in the OCP.
Further SLR information is provided in a document prepared for DFO by the Institute of Ocean Sciences, Sidney B.C, 2008, authored by R.E. Thomson, B.D.Bornhold and S.Mazzotti.

Docks provide a structure to assist access to navigable waters which is a riparian right of waterfront landowners in B.C..
If it were not for a dock, water craft would cause damage to the upland and buffer vegetation during launch. Docks are part of the pleasures of living on the waterfront.
Floats provide habitat to native oyster spat that colonize the under-surface during their dispersal to final sites in Portage Inlet and the Gorge. Native oysters filter pollutants and clean the marine environment. Docks are composed of a pier or wharf, a ramp and a float.
A wharf is attached to the upland and should be supported on piles, which provide the least disruption to the shoreline. It should be aligned north to south to cause as little shadow as possible. The higher it is, the less shadow it casts. According to DFO, it should be at least 2m above the highest tide, though Green Shores says 0.5m. According to Gee Chapman (Sydney University, Australia) shade, in fact, allows for increased biodiversity.
The number of pilings used should be as few as can perform the required job, and constructed of long lasting materials to reduce the frequency of replacement. Concrete, plastic or steel is preferred over treated wood. Creosote piles have survived in Vancouver harbour for over 100 years though not generally recommended now. Modern treated wood uses lower concentrations of copper and arsenates which are effective in Canadian climates. The wharf area should not exceed 25 sq. m.
A ramp connects the wharf to the float and should, where possible, be of sufficient length to reach deep water. However, most of Portage Inlet is less than two meters deep with large mud flats. Dredging is not recommended. For safety, the ramp should have a maximum slope of 30 degrees at low tide and be 1 to1.5m. wide.
A float should be large and heavy for stability but DFO recommends a size of 3m. width X 8m. length (24 sq. m.) Green Shores is more permissive and recommends no greater than 35 sq. m. Floats should be constructed of

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environmentally-friendly materials such as encapsulated extruded polystyrene. Dock logs eventually become waterlogged and provide substrate for invertebrates in intertidal zones.
Further information on residential docks is available from “The Dock Manual” by Max Burns, 1999.

Narrow pathways perpendicular to the shoreline, for public access, should be constructed to preserve the vegetation in a buffer zone of sufficient width to protect the area. A 5m minimum shoreline buffer is recommended. Pathways which access viewing platforms or viewing areas can contribute to loss of privacy for adjacent home owners — graffiti, litter, vandalism, violence, late night disturbances, hangouts, drinking, drug use, and burglary. They should be established under Crime Prevention Through Environmental Design (CPTED) principles with advice sought from police at an early stage in the planning process.
Pathways parallel to the water should not be allowed. A linear vegetative wildlife corridor should be preserved where possible all along the shoreline. (See buffers and ecotones). The buffer absorbs pollutants and provides a source of arthropods for insect-eating fish. It has aesthetic values in providing an attractive view-scape from the water where small water craft operators can enjoy the natural scenic environment.

Riparian Rights in B.C.
See "Riparian Rights Public Foreshore Use" in the Administration Aquatic Crown Land Occasional Paper #5 revised August 2008
1. Protection of land
B.C recognizes the right of upland property owners to protect their land from erosion or flooding by building embankments, dikes, or other protective improvements. This right may be exercised only on the upland property. Owners have the right to install protective structures on their own land but they require the consent of the Crown to extend any structures below the natural boundary.
2. Accretion and erosion
In order for the property’s title to reflect the actual extent of ownership the upland property owner will have to retain the services of a B.C. Land surveyor to

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redefine the property and deposit an updated legal survey plan into the land title registry.
3. Access
Waterfront property owners have the right to unimpeded access to and from their property to deep water for the purpose of navigation. The right of access to and from the water applies to every point along the natural boundary of the waterfront property

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PIPS' Recommendations
1. A DPA width of 15 meters.
The following list of exemptions should be included. Provision for : (1) Reconstruction of non conforming buildings on the original footprint if
damaged more than 75% by fire etc. (2) Repair, maintenance of existing structures , roads, driveways, paths or
trails etc. (3) Removal of hazardous trees (4) Removal of invasive plants (5) Construction of approved fences (6) Landscape maintenance (7) Small accessory buildings (8) Erosion prevention
2. Setback to be site-specific with variables related to parcel size, shore type, rocky, beaches, estuaries, mud flats, coastal bluffs, etc. Maximum setback should be no greater than 15m . The reference to 30m in Section of the 1999 OCP should be deleted.
3. The width of vegetated buffers should be based on best available science. The minimum width for a small lot could be set at 4.5m. and expanded to 7.5m. for larger parcels.
4. The distance between a vegetated buffer and habitable structure ought to be adequate to cope with fire hazard.
5. Plants for buffer restoration should include deciduous trees as well as salt- tolerant grasses and native shrubs. Other plants which provide superior root structure for soil stability and erosion control should be included. Buffers require pruning and maintenance which follow BMPs.
6. Sea walls are necessary to prevent the loss of land subsequent to erosion from tidal flow scouring the base of a bank.
7. Measures to protect waterfront property from sea level rise related to climate change should be encouraged. View Royal should perform vulnerability assessments, acknowledging that current storm risks will increase in degree and frequency. Adaptive approaches are necessary.

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8. (Suggestions for construction of wharves, ramps, and floats are included in this paper above.)
9. Pathways for public access to the water should be constructed to preserve a vegetated buffer. Pathways parallel to the water should not be allowed unless they are upland of a fenced vegetated linear wildlife corridor sufficient to provide an adequate buffer designed so as to exclude humans and dogs.
10. Preservation of riparian rights: The rights of access to the water, protection of land from erosion, and ownership of accreted land must be respected.

Appendices (2)
Terry Eckstein, Bill Stavdal, Dr. Doug Critchley,
President View Royal Director View Royal Director

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