Project Watershed files complaint against Town of Comox over Cape Lazo rip-rap

Project Watershed files complaint against Town of Comox over Cape Lazo rip-rap

By Jennifer Sutherst

Project Watershed has filed a natural resource violation complaint with the province against the Town of Comox for the work they are undertaking along Lazo Road in the Point Holmes area.

The town has chosen to install rip-rap (large angular rocks) to address erosion taking place along the shoreline, and to make room for a three-meter wide shoreline trail. We believe this treatment will destroy an important remnant area of sensitive Coastal Sand Ecosystem and will be ineffective in the long-term.

Erosion-control structures such as bulkheads, seawalls and rip-rap, are known as hard armouring and have been shown to cause a loss of natural shoreline ecosystems, damage vital shoreline habitat and exacerbate erosion problems on adjacent properties.

Hard armouring amplifies the energetic forces of the waves that come into contact with it, whereas a natural, gradually sloping beach will absorb the energy of the waves.

You can read more about Comox shoreline erosion and its causes, and other concerns over the town’s rip-rap project at Cape Lazo here and here.

The accelerated erosion in the Point Holmes area is the result of a domino effect of hard armouring that started when the CVRD buried a sewer pipe beneath the Willemar Bluffs in the mid-1980s. This initial disturbance destabilized the natural processes of erosion and accretion from longshore currents and wind that shape the landforms such as spits, dunes, beaches and sand bars.

Local property owners began to experience erosion issues and successfully sued the CVRD for damages. In order to halt this erosion rip-rap was installed below the Willemar Bluffs. Soon after, other beaches began to erode and private property owners to the north of the bluffs began to lose shoreline. They in turn also began to install rip-rap to save their properties.

Now, the popular Cape Lazo/Point Holmes beach has started to suffer from erosion during more frequent and intense winter storms, a trend which is likely to continue as we experience the impacts of climate change.

Another consequence of this work being undertaken by the town is that the remaining natural dune vegetation in the area will be significantly reduced or lost due to the stabilizing effect of the rip-rap armouring. This will promote the establishment of shrubs and then trees over herbaceous dune plants. Species present at the site such as Silver Burweed and Beach Dunegrass will likely diminish in extent.

Given the high level of soil disturbance associated with the work, Scotch Broom and other invasive plants will likely become dominant in many places.

Rip-rap armouring of shorelines in our region also impacts the marine ecosystems. In particular, the beach areas shorten and become steeper which reduces the area available to beach spawning fishes (known as forage fish), and decreases the availability of forage fish to salmon, seabirds and other marine species.

The State of Washington recognizes that hard armoring destroys sensitive shorelines and has an incentive program to help landowners remove hard armouring and replace it with Green Shore projects.

Green Shore projects imitate natural systems and confer many benefits including: shoreline stability, improving the habitat for fish and other wildlife, improving access for swimming and other water activities, offer a more natural aesthetic, and can save a significant amount of money.

The Town of Comox has stated that they are using a blending of ‘Green Shore methods’ but no Green Shore project would include the installation of rip-rap along one of the last remaining sand dune areas in our region where the greatest amount of natural dune vegetation is located.

Based on the information that has been provided to Project Watershed, the Town of Comox does not currently have a permit to undertake this work on Crown land. We have made multiple requests to the provincial government to clarify whether or not they require such a permit, but have received no response to date.

We believe that permits and an adequate public review processes are required and in the interim we have filed a natural resource violation complaint against the town and the contractor undertaking the work. Extensive damage has already been done to the area since work started at the end of June.

This area is one of two locations in the entire Georgia Basin where wind-formed backshore dunes are known to occur, and the only place on Earth where Garry Oak – Shore Pine – Sand Dune communities occur.

Jennifer Sutherst is the estuary coordinator and staff biologist for Project Watershed. She wrote this article on behalf of the Project Watershed  board of directors: Barbara Wellwood, Bill Heath (biologist), Bill Heidrick, Brian Storey, Dan Bowen, Don Castleden, Paul Horgen (biologist) and Tim Ennis (biologist).

On Lazo, Comox shows no accountability

On Lazo, Comox shows no accountability

By Judy Morrison

I attended the recent Town of Comox Open House where one of the featured topics was the Lazo Road shoreline. I have learned much since that date. I now know a lot more about shores and water and and their “systems.” I have also learned more about people, and most of that has been good.

And I learned something about accountability.

I learned that the Town of Comox, when they annexed the Lazo Road shoreline, were given ownership of the foreshore. They can develop or reconstruct it with no accountability to the Ministry of Forests, Lands and Natural Resources Operations.

I learned that because the project is under 1,000 metres in length, the town is not accountable to the Ministry of Environment for the project’s design or the completed work.

I learned that Mayor Paul Ives seems to rule with an iron fist, and that when I am denied an opportunity to speak at a council meeting, no councillor or administrator disputes the decision. Neither council nor staff hold him accountable.

I learned that our Town Council isn’t accountable to its electorate. Under the guise of a road improvement, a major shoreline reconstruction can occur without accountability under the Municipal Government Act. Regardless of requests from me and a number of other Valley residents, council has not held a public hearing on the subject.

We elect councillors to make good decisions. But on the Lazo Road project, they failed to question the pre-packaged solution  given to them by staff. Councillors should know that, “If you give an engineer a hammer, all they see is nails.” Mea culpa? No, lack of accountability. Each member of council can do the same research I did, and am still doing, to learn about the Comox environs.

I learned that town staff are not accountable to the council. Letters from the Comox Valley Land Trust and from other individuals were sent to town staff questioning the design for the Lazo Road shoreline project. It appears that those letters were never shared with council.

I was told via email in May 2015 that when the project drawings were done, “ … I [the town’s engineer] am thinking an open house of some sort may be beneficial to the locals in the area including Cape Lazo Recreation Association, so that the design can be discussed in detail with the design team to get a better understanding of the design and to answer any concerns/questions the residents may have.”

Would have been a good idea, but it didn’t happen. Accountability.

I am used to a municipal parks department that would jump at an opportunity to integrate any part of the Comox Valley shoreline into its parks system, in a natural state. To my knowledge, that was never suggested for the Lazo Road shoreline since its annexation into the Town of Comox in 2006. Accountability.

And we, the voters, aren’t innocent either. We are accountable for the Town Council we have in place right now. I guess we deserve them. But I also suspect that we have learned something, too.

Judy M. Morrison is a professional land surveyor. She lives on Lazo Road.

Work stopped on Comox rip rap project

Work stopped on Comox rip rap project

Second update: Work on the project resumed on Wednesday, June 29.

This article was updated at 10 a.m. after receiving information from the Town of Comox regarding the work stoppage.

Work stopped almost as soon as it began on the Cape Lazo shoreline stabilization project because the Town of Comox failed to get all the necessary permits. Workers started to dig a two-metre deep trench on Monday, June 20 and shut down operations late Thursday of the same week.

According to the town, the project received notice on Thursday, June 23 at approx. 4:55 p.m. to stop works ‘beyond the natural boundary’ until an appropriate permit was in place. As this limited  general construction, staff elected to stop all works until the permit from Ministry of Forestry, Lands & Natural Resource Operations was obtained.

The town voluntarily stopped work above the natural boundary but the remainder, or the bulk of the project, was issued a Stop Work Order.

The town has now applied for permission to do what Mayor Paul Ives says is “a small portion of work to be done outside the road allowance.” The necessary permit also requires consultation with the K’omoks First Nations.

The town is attempting to slow the erosion of the large, vegetated back shore dune that comprises the Cape Lazo shoreline. It’s known as a Coastal Sand Ecosystem (CSE), and is part of the of the Quadra Sands glacial deposition that includes Willemar Bluffs, Goose Spit and the Tree Island complex.

The one segment of shoreline in the Comox area that still contains a remnant natural back shore dune is currently being destroyed by the Town of Comox, who have decided to armour that last remaining segment with rip rap.

According to Tim Ennis, executive director of the Comox Valley Land Trust, CSEs are rare in the Georgia Basin-Puget Sound-Salish Sea region.

“Erosion and redeposition of sand within an active dune complex is a common phenomenon on an annual cycle, but sand deposition is typically net-positive over the long term,” Ennis wrote in an email to members of the Land Trust and Project Watershed.

“Wind blown dunes are particularly rare in the Georgia Basin, with only two known occurrences of remnant, semi-stabilized dunes remaining extant: Savary Island and Cape Lazo (Point Holmes),” he said.

To many people, the accelerated erosion at Cape Lazo comes as no surprise. It stems back to a decision by the Comox Valley Regional District’s Sewer Commission in the mid-1980s to bury a sewer pipe beneath the Willemar Bluffs. That disturbed the shoreline, causing property owners to sue the CVRD, which resulted in the placement of rip rap (large, sharp-edge rocks) to slow the erosion.

But after the construction of the sewer pipe and placement of rip-rap below the Willemar Bluffs, other beaches began to erode. Homeowners to the north of the bluffs began to lose shoreline. So those residents installed rip-rap to save their property.

And that moved the accelerated erosion action further up the shoreline to the popular tourist beach at Cape Lazo/Point Holmes. Increasingly large chunks of land disappeared with more intense winter storms.

To fix that problem, the Town of Comox has chosen to spend about $1.6 million to add rip rap from where the homeowners stopped to just south of the Point Holmes boat launch.

Accelerated erosion of Comox Valley shorelines has only occurred where the CVRD buried sewer pipes or tried to remediate the effect of the pipes. It doesn’t seem like a coincidence.

“The one segment of shoreline in the Comox area that still contains a remnant natural back shore dune is currently being destroyed by the Town of Comox, who have decided to armour that last remaining segment with rip rap,” Ennis says.

The town had other options.

Judy Morrison, a former Alberta Land Surveyor with a Calgary engineering firm, and a Lazo Road resident, has advocated a soft shoreline restoration, as opposed to the hard stabilization project chosen by the town. She says a “green shore” would cost about $600,000 less and be more effective.

“The town’s solution means that the residents of the Comox Valley, as they walk
along this stretch of beach, are now going to see 640 metres of rip rap, instead of limited green growth,” she says.

Ennis says the town’s rip rap project “will likely function for only a short period of time,” due to the increasing severity and frequency of winter storms. A provincial report recommends flood construction levels of five metres or more for the east coast of Vancouver Island.

Based on experience, it’s possible the new rip-rap will shift erosion further up the shoreline, and may accelerate erosion of the bluffs at the end of the CFB Comox runway, which stand above the sewer outfall into the Strait of Georgia.

It’s also likely that the impacts of climate change on shorelines will eventually threaten the sewer pipe buried beneath the Cape Lazo beach, not far from where the town is digging.

Meanwhile, the rip rap project has stalled. Mayor Ives believes the missing permissions will be granted shortly. More will be known later this week.

Let’s make it socially unacceptable to feed deer

Let’s make it socially unacceptable to feed deer

I’m done with deer.

On any given day, small herds of deer eat their way through local neighborhoods. They wander onto busy streets and stop traffic, sometimes with fatal results. They damage property, threaten people and pets, pose health risks and attract dangerous animals.

We call them “urban” deer, perhaps to trick ourselves into thinking they belong in our environment. Kind of like metrosexuals.

Why do we put up with this? If any other creature roamed our city streets with such brazen disregard for human existence, the phones of pest exterminators would ring off the hook.

Aren’t deer just rats with longer legs and better PR? Not so, for some people who see deer as lovable woodland creatures, like Bambi, and out of this misguided fantasy decide to feed them.

But gardeners lose thousands of dollars worth of plants to the voraciously hungry deer, and spend thousands more on fencing and other methods to deter them. Seiffert’s Farm lost so many crops to foraging deer that they fenced off their entire farm, at great expense.

“We need to make it socially unacceptable — just like littering.”

Other communities have mounted a variety of counter-offensives to send the deer high-tailing it out of town. So what is the Comox Valley doing?

Nada. Zippo.

Representatives for both the Town of Comox and the Comox Valley Regional District say neither entity has a bylaw against feeding deer, and have no plan to reduce the Valley’s urban deer population.

A CVRD representative said the deer are a provincial problem, but the B.C. Conservation Service and the Ministry of Forest, Lands and Resource Operations deny it. There is a B.C. law against feeding dangerous animals, and deer don’t qualify. The province will only help reduce urban deer populations if local governments request their assistance.

Everyone knows, or should know, that it’s harmful to feed wild animals. So let’s urge Comox Valley municipalities to pass laws that prohibit feeding deer, as Parksville, Nanaimo, Oak Bay and other B.C. communities have done.

Even the B.C. Society for the Prevention of Cruelty to Animals opposes feeding wildlife. They say feeding makes habituated wildlife more susceptible to predators and traffic collisions.

“We need to make it socially unacceptable — just like littering,” said the BC SPCA chief scientific officer.

There are myriad reasons why the Comox Valley should reduce its deer population.

Deer attract dangerous animals. Deer make up about 95 percent of a cougar’s diet, and are lured into the urban area by the easy prey of unwary deer. The area conservation officer confirmed frequent cougar sightings in the Valley.

School District 71 occasionally issues warnings about cougar sightings. Many parents who fear cougar attacks in rural and semi-rural areas stay with their kids until they board the school bus.

Letting the deer population go unchecked raises the risk of spreading Lyme disease and other tick-borne illnesses. While reported cases of Lyme disease are not as prevalent here as in the Lower Mainland and other areas, a high density of deer means more ticks and a greater risk.

Some B.C. communities are going beyond no-feeding bylaws to control their deer populations. Kimberly, a town of 10 square kilometers removed 200 deer in one cull. Cranbrook reduces its deer population by 20 to 25 annually.

A group of four Kootenay towns spent $100,000 to live-trap about 80 deer and relocated them to wilderness areas. But the experts we interviewed say this is a bad idea. Domesticated deer don’t survive long in an environment with more predators and less garden produce to snack on.

I only support culling wildlife as a method of last resort. But it would cost far less to cull the local deer population and donate the venison to Comox Valley food banks.

Whether to act, and how aggressively, depends on our community’s values. Is the current urban deer population socially acceptable? I join the chorus of those who say no.

But we’d better have this important policy debate. Because after we figure out how to manage the deer, there are about 80 gazillion feral bunnies hopping into our yards right behind them.

On Oceans Day, tiny celebrations

On Oceans Day, tiny celebrations

Thanks to a Canadian initiative at the 1992 Earth Summit, the world celebrates Oceans Day on June 8. Unfortunately, our oceans haven’t done so well lately, putting a little damper on the party.

We’ve overfished and under protected them, polluted them and ignored the undeniable impacts of climate change. We’ve treated beaches as opportunities for high-rise housing developments, carelessly disregarding the ensuing stress on shorelines and marine life.

Oceans are warming and acidifying, causing disruption to marine life and habitats. Corral reefs are bleaching. Sea birds are dying off. The polar ice caps are melting.

The B.C. Liberal government shamelessly promotes the oil and gas industry, urging more oil tankers into the Salish Sea where the inevitable accident will cause catastrophic damage.

The Great Pacific Garbage Patch continues to grow. It already stretches from the North America West Coast to Japan, in two giant swirls called the Western Garbage Patch and the Eastern Garbage Patch, and known as the Pacific trash vortex.

Currents in the Pacific Ocean round up more garbage every day. Most of it is non-biodegradable plastic that has broken down into tiny pieces.

Facial scrubs intended to exfoliate dead skin, and toothpaste intended to whiten teeth, and other personal care products, contain plastic microbeads. They’re little bits of plastic so small that the filters in most wastewater treatment plants don’t catch them.

Just one tube of facial scrub may contain up to 300,000 microbeads.

When they reach streams, lakes and oceans, these beads absorb other pollutants, and are consumed by fish and shellfish. Like plastic bags, they persist in the water and in sediment for more years than we can imagine.

When marine life consumes these microbeads it affects the food chain all the way up to you and me.

But even if we all stopped using products that contain plastic microbeads today – and even if we never used another plastic grocery bag – our rivers, lakes and oceans will suffer from these persistent pollutants for a millennium or more.

And speaking of wastewater treatment plants … While Victoria area elected officials argue, the region continues to flush untreated sewage into the Juan De Fuca Strait. The citizens of Comox and Courtenay pump their poop — only slightly better treated with decades-old technology — into the Strait of Georgia.

But the existing CVRD treatment plant does not screen out pharmaceuticals, or remove nitrogen and other toxic chemicals to any significant degree.

Are you thoroughly depressed yet? Calm down, because there is a little bit of good news.

Fewer people now deny the reality of climate change, save Drumpf supporters in the U.S. and too many Liberal Party supporters in B.C. A new generation of people, including engineers and scientists, who have grown up with the impacts of accelerated global warming, will affect positive change.

They are glimmers of movement toward shoreline protections and restoration along the B.C. coast. Groups like Project Watershed in the Comox Valley, for example, take unilateral action and press governments for sensible solutions.

But when, we wonder, will humans acquire the wisdom to figure out the long-term consequences of our consumption of everything from fossil fuels to toothpaste before — instead of after — they cause such damage?

Something to ponder on Oceans Day.

Should UBC divest from fossil fuel companies?

Should UBC divest from fossil fuel companies?

Should the University of British Columbia buy shares in and take profits from fossil fuel companies or invest in funds and projects directly linked to controversial energy projects?

The UBC Board of Governor’s considered that question after some faculty and staff urged the university to divest its endowment fund stakes in fossil fuel projects.

On the surface, the answer is simple. The Board of Governor’s mandate is to make money for the endowment fund. Its fiduciary duty is simply to get the best return possible to support the school’s academic mission.

But setting investment policy is more complex than that. UBC is responsible for examining the short- and long-term risks of its investments. And that requires assessing both internal and external factors that might influence an investment’s return.

A large institutional investor such as UBC can use its leverage to change company policies.

When evaluating any individual investment, the university must consider whether climate change poses any financial risk to its expected returns.

In regards to its positions in projects related to fossil fuels, UBC’s investment committee waffled. It decided not to divest from fossil fuels at this time, but directed its lawyers to review legal questions arising out of any possible future divestment.

That certainly is a cautionary approach. Given the speed at which climate change is occurring and the global pressure to reduce carbon emissions now required by the Paris Agreement, the university should have already answered its legal questions and been prepared to update its investment policies.

If divestment exposes the board to potential legal action over its failure to produce as much value as possible, then it will have no choice but to continue investing in lucrative but controversial energy projects. And it should work quickly to change whatever mandate or legislation impedes them from divesting.

In the meantime, however, UBC should develop a strategy for showing greater sensitivity to environmental issues. The university’s Board of Governor’s should press companies for greater transparency about the risk from climate change, and how they are mitigating that risk.

A large institutional investor such as UBC can use its leverage to change company policies.

And, by the way, let’s put to rest the notion that the UBC investment committee is handling only “public” money. Private individuals and group donations account for 75 percent of the endowment funds. It’s more difficult to classify the balance, which comes from housing developments on UBC’s land.

It’s important for UBC to move quicker than it has. If Canada is going to meet its obligations in the Paris Agreement to keep emissions below the 1.5 to 2.0 degree target, every institution and every individual has to start today planning for a world that does not depend on oil or gas.

The UBC Board of Governor’s has done the prudent thing, for now. But that action is woefully lagging.