Lakeshore Development Public Hearing

This letter was delivered to TNRD in preparation for the Lakeshore Development Public Hearing.

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September 18, 2012

Public Hearing Comments

The mandate of our Association is stewardship. We are not opposed to development. We are opposed to development when due diligence in ensuring the sustainability of the area’s water resource has not been carried out.

We have the following concerns:

1.     All criteria developed by the Thompson-Nicola District (TNRD) regarding Lakeshore Development have been ignored. According to the 2004 TNRD publication, “Lakeshore Development Guidelines”, Big Lac Le Jeune has been classified as “Development Lake sub-class” with the notation in the document that there should be NO FURTHER DEVELOPMENT. This classification is based on the two criteria used by the TNRD, namely “perimeter development” and “user unit ratio”, both of which are currently exceeded.   Again, based on TNRD criteria, Little Lac Le Jeune, the lake the proposed development will be adjacent to, has been classified as “Critical” with the notation that there should be NO FURTHER DEVELOPMENT. Little Lac Le Jeune has been given a Critical designation because of several factors. It has a mean depth of less than 5 meters. The size of Little Lac Le Jeune (between 60 and 100 hectares) allows for 20% perimeter development. Currently there is approximately 40% development. Ministry of the Environment personnel have determined that Little Lac Le Jeune is eutrophic. (overly rich in nutrients…i.e. nutrient pollution)

2.     The TNRD requires that an environmental impact assessment be completed prior to any lakeshore development. Our letter to the TNRD dated December 11, 2011 outlines our concerns with the study done by Lakeshore Environmental Ltd. (Please refer to #3)  Further to the concerns we mentioned, we are particularly concerned that the assessment was done on Big Lac Le Jeune when the proposed development is immediately south of Little Lac Le Jeune. We are also concerned that the data used was extremely dated. The most recent data cited in the report came from 1996 with the bulk of the data thirty-five years old from 1977. Wrong lake with data over a third of a century old!

3.     In our December letter, we expressed concern regarding the sheer volume of water that would be taken from the lake or water table if the proposed development proceeds. We are concerned about the potential draw of 4,471,250 gallons of water from the supply (based on 250 gallons per day with 49 proposed homes). Can the lake and water table sustain an additional draw of this annual amount?

4.     Since we wrote the December letter to the TNRD we have undertaken a water monitoring program supported by the Ministry of the Environment and the British Columbia Lake Stewardship Society.  Preliminary reports from our monitoring since ice-off in May, 2012 indicate an alarming increase in the phosphorous levels (over 1300%) and an almost doubling of the Specific Conductivity of the lake since the reports cited by Lakeshore Environmental Ltd. This information is in addition to the concerns raised by testing of water samples taken from Lookout Road by Interior Health prior to the installation of a filtration system mentioned in Concern #5 in the December letter.

5.     Since earlier this year, the proposed development has moved over 60 feet closer to the lake (from 60meters from high water mark to 40 meters).

Lakeshore Environmental Ltd. was contracted to write the Cariboo District Lakeshore Development guidelines. In that document, Mr. Holmes writes “ENSURE THAT (our capitalization) buffer leave strips are required on ALL developments within 150 meters of a low sensitivity lake and 250 meters of a high sensitivity lake to protect water quality.”  (Little Lac Le Jeune would be defined as a High Sensitivity Lake.)  He also states that “prior to further development there should be a water quality sensitivity rating. This should include a map of the lake basin morphometry, lake volume, depth, surface area, perimeter development, chemical sampling of lake at spring overturn, calculation of mean phosphorous concentration rate, calculation of flushing rate, watershed boundaries and information on land uses within the watershed. Mr. Holmes also recommended that a “Lake Carrying Capacity” measurement be done to “determine the capacity of the lake to support additional development. Of course, none of this good advice was followed when Lakeshore Environmental Ltd. wrote its environmental impact study to support Lakeridge development.

6.     We were informed that an engineering firm would be hired to do an impact assessment of the proposed development on the lake. This has not materialized.

7.     We described a number of anecdotal concerns in the December letter (refer to concern #6). Subsequent to this, we were alarmed this spring at the significant fish kill in the little lake. While there is usually some fish kill over winter, long term residents report that they have never seen anything that approached the magnitude of the fish kill this spring.

Perhaps Don Holmes of Lakeshore Environmental Ltd. said it best when writing for the Cariboo District.  “Even if each development was properly managed, this might not be adequate to protect lakes from the cumulative impact of many developments in high demand areas.”

Photographs to support these comments are available online: http://goo.gl/bosWu

Thank you for considering our concerns.

                                                       

Sincerely,

                                                             

David Wyse, President, LLJCA