Comparative Analysis
of the Town of Gibsons
Official Community Plan
Requirements, Goals, Objectives,
Guidelines, and Policies
As They Apply to the Proposed
Gospel Rock Neighbourhood Plan
Land Use Concept
Prepared for the Friends of Gospel Rock
December 2010
COMPARATIVE ANALYSIS OF THE TOWN OF GIBSONS
OFFICIAL COMMUNITY PLAN
REQUIREMENTS, GOALS, OBJECTIVES, GUIDELINES, AND POLICIES
AS THEY APPLY TO THE PROPOSED
GOSPEL ROCK NEIGHBOURHOOD PLAN
LAND USE CONCEPT
EXECUTIVE SUMMARY
An analysis of two documents—the Town of Gibson’s Official Community Plan and the
Land Use Concept recommendations submitted to the Town by the Gospel Rock
Refinement Working Committee on November 22, 2010—was undertaken by and for
the Friends of Gospel Rock. Comparison of the stipulations of the OCP to the
recommendations in the LUC revealed numerous conflicts. In fact, the comparative
analysis found the LUC INCONSISTENT with the OCP in 27 areas.
Council of the Town of Gibsons would seem to have two options:
1. Change the OCP to allow it to accept a neighbourhood plan based on the Gospel
Rock Land Use Concept, or
2. Change the LUC to bring it into conformance with the OCP.
Changing the OCP would entail gutting its principles, goals, objectives, guidelines, and
policies on such a scale that the citizens of the Town of Gibsons would be unlikely to
accept the assault on their stated and well-considered values. The Town would be
vulnerable to legal challenges, and Councillors would likely face an angry electorate.
The second option then, as challenging as it may be, becomes imperative.
To that end and based on the analysis herein, this paper makes several
recommendations, which are offered in the spirit of being useful to Council members
and staff in their deliberations.
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RECOMMENDATIONS
We recommend that Council ensure that the Land Use Concept and any Gospel Rock
Neighbourhood Plan include, at a minimum, commitments that the proponents,
including the Town where applicable, will:
A. Supply the information the OCP requires of a Neighbourhood Plan, specifically:
1.
Undertake a complete drainage/ analysis and plan with details of on-site
retention works, limits to impervious surfacing, and plans for runoff reduction and
the siting of these in the plan area. This drainage plan must alter neither the
“natural drainage” systems of the overall area nor the waterways of the area. As
well, the drainage plan must not alter the three separate catchment systems,
north, east, and west, as identified in Holland Barr Figure 14.
2.
Have a habitat mapping study performed, with newly identified areas of critical
habitat protected from development with DPA setback areas, as recommended
by the Ministry of Environment, this mapping to include, but not be limited to: rare
or sensitive plant communities, nesting sites, perching/feeding/hunting trees for
raptors, snags and stumps for woodpeckers, bat habitat, alligator lizard habitat,
songbird feeding habitat trees, mammal habitat including all freshwater
accesses, wildlife trails and corridors, and freshwater seep plant communities.
3.
Have an Archaeological Assessment performed with input from the Squamish
First Nation including maps of and preservation plans for the sites identified.
4.
Identify the freshwater seeps, their surrounding plant communities, and the bluffs
and gullies below Gower Point Road, which have been newly identified as
sensitive ecological systems, and establish setbacks of 30m for each, as per
Ministry of Environment recommendations.
5.
Map important and unique natural features (e.g., “footprint” and “stone circle”)
and draw up preservation plans including appropriate setbacks.
6.
Identify and arrange protection for sites of historical significance, like the natural
clearings, quartz cross and the slope west of the rock used historically by citizens
to gather for special religious worship, including the area historically used to
access the beaches below Gospel Rock itself and Secret Beach.
7.
Ensure forest preservation below Oceanmount through to Gospel Rock lands
(see OCP page 44), including identification and protection of raptor, bat,
woodpecker, and migratory bird habitat trees, and snags and stumps used by
both birds and mammals.
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B. Avoid development uses or activity in areas of concern as defined in the OCP (and
other regulatory regimes), specifically:
8.
Designate for passive preservation, not active parkland, the land located in
polygon 82, also identified as the “bluffs to the east of the viewing site,”
implement measures to minimize deleterious pedestrian overuse, and include a
30m setback (as per provincial Ministry of Environment recommendations 2004
for “sensitive ecosystems”).
9.
Withdraw all development uses from DPA1 and -2 zones of Blocks 6 and 7.
10.
Withdraw plans for development uses in all Greenbelt areas.
11.
Plan no development uses of the waterways on Block 6 and include a setback
from development of 30m, as recommended by the BC Ministry of Environment
2004, around each of the tributaries.
12.
Undertake no uses at all on the marine backshore below Gower Point Road, and
acquire it for park.
13.
Include neighbourhood parkland dedications on flat land other than DPA1 or
DPA2 or Greenbelt areas.
14.
Maintain present trails along ravines, and where necessary, carry out the works
required to protect the banks from negative impacts of trail use.
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COMPARATIVE ANALYSIS
PREAMBLE
The Town of Gibsons is blessed with having crafted a powerful, overarching Official
Community Plan, its SMART plan. This document is visionary and sensitive as well as
being pragmatic and instructive. Future generations of Gibsons citizens will thank their
forebears for their foresight in drafting it.
From its introduction OCP Part A 1.0:
Once an OCP is adopted as a bylaw, the Community Plan becomes ‘official,’ and
all future land use decisions made by Council must be consistent with the
objectives and policies outlined in the Plan.
…several tools are required to implement a Plan’s policies and objectives. This
includes the use of regulations or guidelines such as those contained in the
zoning bylaw, development permits, capital expenditures planning, development
cost charges and subdivision control. These bylaws and regulations must be
consistent with the Plan.
Town OCP page 1
So, having adopted their Smart OCP, Council MUST ensure all land use decisions are
consistent with the objectives and policies of that Plan. Council has no options; it MUST
do so.
This paper examines the Land Use Concept proposed as a basis for the Gospel Rock
Neighbourhood Plan (hereafter GRLUC) to determine whether it is in accord with the
objectives and policies of the Smart OCP.
ANALYSIS
OCP PART B SECTION 4.0 THE NATURAL ENVIRONMENT

Council’s Objective (CO):“Protect the quality of the natural environment, including
the presence of valued wildlife and greenspace in the Town’s wooded and natural
areas.”
Page 23
GRLUC: The LUC proposes dropping the Greenbelt designation on lands below Gower
Point Road (GPR) to allow for housing. It also proposes dropping the Greenbelt
designation for waterways on Block 6 to allow for development uses. In this way, the
GRLUC is
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NOT CONSISTENT with Council’s OCP objective. (Environmental reports prepared for
the Town have identified two creek ravines on Block 6 as having high value for wildlife,
as well as the bluffs, gullies and freshwater seeps below Gower Point Road.)

CO: “Acquire through purchase or by dedication as park or by other creative
arrangements, environmentally valuable land, riparian areas, sensitive marine
backshore areas, including streams and watercourses [our emphasis]….”
page 23
GRLUC: The LUC would allow roads over/through the two Seward Creek headwater
tributaries on Block 6. Therefore, the GRLUC is
NOT CONSISTENT with Council’s OCP objective of acquiring those watercourses as
park.
Note: This Council Objective effectively removes the Riparian Act Regulations (RAR)
discussion from this policy, as streams and watercourses are specified in the objective,
along with riparian areas, so that, as a watercourse, it MUST be acquired by the Town
as park.
GRLUC: The LUC allows housing below Gower Point Road, i.e., it recommends
developing the sensitive marine backshore area, rather than acquiring it for park. The
marine backshore is the area of bluffs, gullies and freshwater seeps mentioned above.
Therefore, the GRLUC is
NOT CONSISTENT with Council’s OCP objective.

CO: “Minimize risks to life and property from natural hazards and disasters such as
floods, erosion and slides.”
Page 23
GRLUC: GRNP lands pose known hazards to downslope development both in the
Bayview Heights subdivison below Gregory lands and in the Gibsons bay area.
Flooding, landslide, debris slides, mudslides, culvert blockages, and streambed shifts
are all hazards that have been identified in geotechnical assessments (since 1981). The
Town has not yet built recommended works to ensure citizen safety (called for in the
Dayton and Knight report and the Thurber report and referred to in the most recent
Golder report). The GRLUC contains no plans for the required mitigating works.
Therefore, the GRLUC is
NOT CONSISTENT with Council’s OCP objective to minimize risks to life and property.
GRLUC: The LUC recommends allowing Mssrs. Gregory to clear and open a road into
the lands. This undertaking has been identified, by the owners’ own engineer (Golder),
as problematic since the area is prone to landslides:
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We consider, however, that the annual probability of occurrence for debris
slides on the steep slope area may be increased by the presence of the
existing road that traverses this slope. We understand this road will be
upgraded to form the primary access to the proposed subdivision
development. We consider the stabilization of this roadway, including
appropriate storm water management and possibly cutslope retaining
structures and/or engineered fills, will be necessary to mitigate against
road-related landslides that could impact existing downslope residential
development.
The GRLUC is silent on the matter of requiring these mitigative works. Therefore, the
GRLUC is
NOT CONSISTENT with Council’s OCP objective to minimize risk to life and property.
Note: It has been suggested that the proposed access to the land above Bayview
Heights will not be to the Town’s roadway standards, but rather will be a “driveway”
access and, as a driveway, would not be required to meet the same standards as a
Town road would. The GRNP needs to ensure this “driveway” is properly engineered,
designed, and built to mitigate the documented hazards. Interestingly, the GRLUC does
not indicate this access as temporary, as had earlier been posited.
It has also been suggested that further engineering, such as the details of this
road/driveway, will occur at later stages in the development process. As the overall
neighbourhood plan rests on sufficient access (among other requirements), it is entirely
appropriate to establish in the overall plan area whether such servicing is or is not
possible.
OCP 4.1 GEOTECHNICAL HAZARDS

Council Policy (CP) 1: “Require a geotechnical report, prepared by a professional
engineer, for areas that have steep slopes or are a geotechnical hazard to determine
the conditions and requirements of the area for development…see Schedule BDPA1 for areas that are subject to a development permit in order to protect from
geotechnical hazards….”
page 23
GRLUC: No geotechnical engineering report has been done for lands below Gower
Point Road (steep slopes) that have been identified as having geotech rock fall hazards,
or for the two waterways on Block 6 that are in both moderate and high zones of
geotechnical hazards, to determine the conditions and requirements for development.
Any plan to “grade” the ravines into development land would require geotechnical
assessment before any final neighbourhood plan can be adopted. As the eventual road
layout for the plan area depends upon these creeks’ elimination, it needs to be
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established whether eliminating the creeks is or is not possible. Such a consequential
undertaking is not a “detail” to be determined at rezoning or subdivison.

“Unless recommended otherwise by a professional engineer with experience in
geotechnical engineering, no dwellings, structures or other use of the land shall be
permitted within the areas defined on Schedule B as high geotechnical hazards.”
Page 102
The Land Use Concept indicates roadways and residential-dwelling use in the areas of
high geotechnical hazard in the Seward creekways, but includes no accompanying
geotechnical report. Therefore, the GRLUC is
NOT CONSISTENT with Council’s OCP policy.
OCP 4.2 ENVIRONMENTAL PROTECTION

Council’s Policy (CP) 1: “Protect environmentally sensitive areas, riparian areas and
marine habitat, including creeks, wetlands, forested and critical habitat areas from
unsustainable development and land alterations….”
page 24
GRLUC: No setbacks for or protection of the creeks on Block 6 or for wetland/pond/lake
in the northern sector are referred to in the GRLUC. The Land Use Concept also
recommends land alteration to the forest below Gower Point Road, a provincially
documented environmentally sensitive area, to allow for residential development. In
addition, development uses seem to be situated below the crest of the ridge on Block 7
(see LUC page 80) deep into DPA2 zone. For any or all of these reasons, the GRLUC is
NOT CONSISTENT with Council’s OCP policy.

CP 2: “Conduct a thorough field survey and mapping exercise to determine which
additional lands and shorelines are environmentally sensitive and should be
protected through a development permit. This may include the ocean shoreline, the
ravines or Charman and Gibsons Creeks, vegetative communities, watershed areas,
eagle nesting areas, alligator lizard habitat areas, and other areas that have high
scenic and cultural values.”
Page 24
GRLUC: The GRLUC does not include any mention of meeting this stipulation. The
Town has not undertaken this study and mapping, and the environmental reports
attached fail to locate mammalian, reptile and bird habitats. So areas of alligator lizard
habitat and other sensitive communities in the plan area are not yet determined and
mapped. This study must be done before land use decisions are made. Therefore, the
GRLUC is
NOT CONSISTENT with Council’s OCP policy.
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
CP 5: “Ensure that land designated as Greenbelt is used to direct community
development away from lands that have unstable slopes, poor soil permeability,
subject to flooding, or areas with significant flora and fauna. These areas may be
used for trail access or public utility corridors….”
page 25
GRLUC: The land use concept neither respects nor plans to maintain the Greenbelt
designations as they apply to the two areas of forest land below Gower Point Road,
areas which have been documented to have unstable slopes (rock fall hazard zone) and
poor soil permeability as well as significant flora (see above item). Therefore, the
GRLUC is
NOT CONSISTENT with Council’s OCP policy.
Note: It has been argued that the forest below Gower Point Road (GPR) is not part of
the area of environmental sensitivity—purportedly because of the differences between
the two sections of forest—and that therefore some parts of it can be removed from
DPA2 or the Greenbelt designation area with no deleterious effect. It must be clarified
that the area below GPR is not included in DPA2 and/or Greenbelt only because of the
rarity of its ecosystems; rather, the designation has been applied because of its
excessively steep slopes and proven instability. (See OCP pages 25, 107.) The
engineering rationale was that development uses, beyond the limits of 2h:1v, pose too
great a risk to the sensitive ecosystems below.
Because the DPA2 designation uses gradient to define its boundaries, no environmental
report can speak to the parameters of this restriction. Greenbelt designations were
placed on sensitive ravine and steep bluff land originally (early 1990s) to limit
disturbance—particularly to restrict tree removal, as the trees have been proven to
provide stability to the shattered granite slopes. (Some on Council will remember
bringing suit against irresponsible tree cutting in Charman Creek. Greenbelt and DPA
designations were used to prove Council’s right to restrict, and the Town’s benefit in
restricting, tree removal in such an environmentally sensitive and geotechnically
challenged area.)
Both areas of forest below Gower Point Road are areas of documented rock fall hazard.
It has also been documented for the Town that rock fall is a conditional hazard, and that
whatever tree cover remains contributes to the stability of the slopes and the diminution
of hazards.
DISCUSSION
“The Greenbelt designation largely prohibits most types of land alterations….”
Page 24
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The lower forest on the southern slope on Block 7 right down to the water, two upper
clearings and one lower, and both creekways on Block 6 are in Greenbelt designations
in the OCP. See Schedule A land use designations.
Refer also to the 1992 court case Valentine Lands vs. Gibsons where the court agreed
with the Town that the entire remaining forested slope (to the ocean’s edge) is too
unstable and hazardous to allow the owner to remove trees.
The Town argued in that court case that the slopes showed clear evidence of
geotechnical hazards, mainly rock fall/slide and leaning, angled trees, and that the trees
were integral to slope stability. The judge agreed that Council had acted in good faith in
enacting bylaws restricting uses on these slopes.
This understanding of the need for the slopes to be treed clearly informed Councils’
choices in all of the municipal “vehicles” included in subsequent OCPs.
An engineering study for the Town proved this area is also one of “conditional hazard,”
that is, if trees were to be removed, and surface disturbed, the risk of rock fall and slide
is increased. The Thurber study, which recommended the Town’s DPA zones,
characterized the lands below Gower Point Road along the foreshore as a Rock Fall
Hazard Zone since any disturbance of this area could dislodge broken rock and cause
damage to both the environment and human activity below. That geotechnical study of
both hazards in and the biosphere of the Town is the backbone of the OCP adopted
1993 and remains one of the documents foundational to the present OCP (2005).
Council’s position remains that no trees can be removed from any part of the Greenbelt
zone of Block 7. Removal of a dangerous or diseased tree can only be approved
following recommendation by a professional.
The Town states in the OCP (2005) that they should devise a tree-cutting bylaw. In the
meantime, however, within the OCP, the Greenbelt designation was applied across the
Town based on Thurber’s combined biosphere/geotechnical recommendations.
If an environmental consultant report were to recommend removal of one or some trees
on the slope of Block 7, no removal of the stump/s would be permitted, as the land is in
DPA2 with too steep a gradient to allow for disturbance to soil cover or natural drainage
patterns.
The entire DPA2 area has a fragile drainage system, dependant on rainfall and rapid
dispersal through the cracked granite. Rainwater drains through the granite and “seeps”
out on the rock bluffs below Gower Point Road. These freshwater seeps have been
expert-identified for the Town as having high value for conservation. Any soil and or
ground disturbance anywhere on the slope above (particularly natural drainage
interruption, which could destroy the freshwater seep communities) jeopardizes the
Sensitive Ecosystems Inventory (SEI) systems below,
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None of the four environmental reports done for the Town has suggested there were
biological reasons for removing any trees in those two areas below the road. What the
reports document is that, although the SEI-designated trees below the road are not a
forest contiguous with the SEI-designated arbutus forest above, they are an essential
component of the ecosystem upon which the upper forest depends as the trees below
the road are the upper forest’s first line of defense from erosive maritime onshore effect.
The most recent of those reports documents how disruption of the natural drainage
system by the roadway has proved deleterious to the SEI forest, and presumably no
further drainage disruption should be tolerated.
ANALYSIS (cont’d)
GRLUC: In another conflict with CP 5, the draft land use concept allows for the
denaturing of the two Greenbelt waterways on Block 6. (See Schedule A land use
designations.) This denaturing includes diverting the water into closed, buried drainage
structures, and grading the ravines into housing development areas. Therefore, again
the GRLUC is
NOT CONSISTENT with Council’s OCP policy 5.
Note: Background documents from previous iterations of a development plan include
this information from the Ministry of the Environment (MOE):
Please be informed that our ministry is opposed to the filling of any
portions of the ravine and that authorization to eliminate stream channels
and/or gullies requires approval under Section 7 of the Water Act of British
Columbia.
OCP 4.3 STREAMSIDE SETBACKS

CP 1: “ Require an appropriate setback for new development along both sides of all
rivers, streams and wetlands, as outlined in the Riparian Act Regulations.”
Page 25

CP 6: “Prepare detailed Development Permit guidelines for the protection of
watercourses and rivers from development….”
Page 26
GRLUC: No setbacks along the creeks on Block 6, or the pond/lake/wetlands on the
northernmost land in the Plan area, are included in the land use concept. Therefore, the
GRLUC is
NOT CONSISTENT with Council’s OCP policy.
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GRLUC: The land use concept contains no detailed Development Permit guidelines to
protect watercourses (and rivers) from development. (Council should first prepare
guidelines, then embed them in the OCP, and finally ensure the GRLUC respects those
guidelines.)
It has been argued that no setbacks on Block 6 are required as this waterway does not
qualify as a stream because it is not a fish habitat (ref. the Provincial Riparian Act
Regulations). The OCP calls for setbacks even for wetlands (presumably fish-free
areas). It should also be noted that the wetland areas in the northern section of the
GRLUC area do not seem to have the required setbacks. Therefore, the GRLUC is
NOT CONSISTENT with Council’s OCP policy.
OCP SECTION 5.0 PARKS AND OUTDOOR RECREATION

CP 4.c: “Lands which are undevelopable due to steep slopes, bluffs, ravines or other
environmental constraints are not considered to be part of the required park
dedication.”
Page 30
GRLUC: The LUC shows “parkland” on the steep slope of Block 7, whereas the
required parkland must be elsewhere, on flatter, developable land. The LUC site
sections, page 80, indicate slope at >25% in a proposed park near the crest of the ridge.
This area is in DPA2 where no “uses,” including neighbourhood park, are allowed on
grades beyond 25%. Therefore the GRLUC is
NOT CONSISTENT with Council’s OCP policy.
GRLUC: The LUC has “eliminated” the two ravines along the watercourses on Block 6
in order for those Block 6 lands to be developed into roadways. As it is ravine land, and
in Greenbelt (and DPA1), it is to be considered undevelopable land not available for
housing or roadways. Therefore, the GRLUC is
NOT CONSISTENT with Council’s OCP policy.
GRLUC: The steep Greenbelt bluffs below Gower Point Road are indicated for cluster
development in the LUC. (They are also expert-identified as having high conservation
value.) Therefore, the GRLUC is
NOT CONSISTENT with Council’s OCP policy.
OCP 5.3 NEIGHBOURHOOD PARKS

CP 2: “Where possible, establish neighbourhood parks with a minimum size of at
least 1 ha, with the majority of the site being relatively flat, preferably in the range of
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1.5 to 2.0 ha. Where residential densities are increased, larger park sites or
additional neighbourhood parks may be warranted.”
Page 31
GRLUC: One parcel of “Parkland” on Block 7 is located on land that is both too steep
and too sensitive for neighbourhood park use, with steep gradients beyond 25%. As
DPA2 denies any use to areas beyond 25% gradient, the GRLUC is therefore
NOT CONSISTENT with Council’s OCP policy
It is interesting to note that Council, as stated in the OCP, has the statutory right and
power to require more than 5% park dedication where there is substantial increase to
density. The argument that certain proponents are “gifting” more than is required is
balanced by this statutory ability of Council to require greater than 5% dedication, as
density proposed in LUC is hugely increased over existing density.
OCP SECTION 6.0 COMMUNITY AND SOCIAL ISSUES

CO: “Recognize significant historical sites and encourage the efforts of property
owners to preserve these sites.”
Page 37
See discussion below 6.4.
OCP 6.4 HERITAGE PROTECTION

CP 4: “Ensure that where buildings, sites, plantings or structures of historical
significance are located on land to be redeveloped that the preservation of such
sites, buildings or structures shall be considered as part of the development
approval process.”
Page 40
GRLUC: Members of the community have identified the natural clearings (four of them)
as of significant recreational and historic value. Because the GRLUC lacks identification
and preservation of all these historic sites or areas, the GRLUC is therefore
NOT CONSISTENT with Council’s OCP policy.
One of the highlighted Smart Plan Goals of the OCP (see yellow box, page 25) is

Council Goal (CG): “Preserve all important and unique natural features, including
watercourses, landforms and habitats.”
Page 25
The “footprint” in granite is well known and well loved as a unique landform. It is likely
that a qualified professional geologist or geographer could prove it unique on the Coast,
and worthy of preservation. Seward Creek is firstly a wetland that then becomes two
tributary waterways. This watercourse has been identified for the Town as important for
13
conservation as wildlife habitat. The bluffs and gullies below Gower Point Road, as well
as the freshwater seeps near the tidal zone, have all been identified in a recent
environmental study by the Town to be important landforms and unique habitats with
high value for conservation.
GRLUC: The Land Use Concept is silent on this requirement to preserve these natural
features. In fact, the LUC plans for development uses in all these areas, except perhaps
the freshwater seeps, although development activity higher on the slope—as indicated
in the LUC—will clearly interrupt the subsurface water flow that charges these sensitive
freshwater ecosystems, resulting in the opposite of preservation. The LUC is therefore
NOT CONSISTENT with Council’s OCP goal.

CP 8: “Consult with the Heritage Conservation Branch to identify sites of
archaeological significance within the Town. Any applicant for development on or
near a known archaeological site should have an impact assessment prepared
according to the B.C. Archaeological Impact Assessment Guidelines.” Page 41
GRLUC: Both community history and members of the community speak to First Nations
traditional uses on Block 7. No Archaeological Impact Assessment has been prepared.
Therefore, the GRLUC is
NOT CONSISTENT with this Council OCP policy.
OCP SECTION 7.0 RESIDENTIAL
OCP 7.1 EXISTING NEIGHBOURHOODS

CP 8: “Shaw Road South/Gospel Rock…. Trail links along ravines are also
recommended; however, the creek banks must be protected….”
page 44
GRLUC: The plan does not stipulate any protection or maintenance of the trails along
Kullander/Seward waterways or of the banks of the ravines there or along the bank of
the Charman Creek ravine. Therefore, the GRLUC is
NOT CONSISTENT with this Council OCP policy.
OCP 7.4 MULTI-FAMILY HOUSING

CP 3: “Consider sites for higher density residential in the Upper Gibsons area that
are in proximity to commercial centres or major community facilities. These sites
should be compatible with adjacent land uses and have adequate access for the
increased population and traffic levels.”
Page 48
14
GRLUC: The map indicates areas of the highest density residential units in the entire
Town within isolated lands above Franklin Road, away from the Upper Gibsons area
and nowhere near commercial centres or major community facilities. Moreover, not only
does the LUC not address the increased traffic levels from proposed maximum density
development, the proponents are also unable to determine how or where sufficient
future access will be provided to the GRLUC area. This lack of road and traffic planning
does not fulfill the policy to “have adequate access.” Therefore, the GRLUC is
NOT CONSISTENT with Council’s policy.
OCP 7.6 FUTURE NEIGHBOURHOODS
--NEIGHBOURHOOD PLAN AREA

“The intention of the Neighbourhood Plan Area Designation is to ensure that the
undeveloped lands in Gibsons are developed in a phased and sustainable manner,
and that the Town of Gibsons and its residents are included in the future planning of
the area. The objective of the designation is to ensure a sustainable neighbourhood
plan is developed in conjunction with the Town and its residents prior to any
subdivision or development…”
page 52
It has been suggested that Council may pass a “generalized” plan and the missing
“detail” information will come in at rezoning and/or subdivision or some later time (for
example, the “detail” of future road connections which cannot now be established). This
suggestion, aimed at allowing for development to move forward, ignores the objective to
“ensure a…plan is developed…prior to any subdivision or development.” Suggesting all
the detail will be taken care of at some time in the future is clearly
NOT CONSISTENT with the stated objective of Council.
--GOSPEL ROCK’S NEIGHBOURHOOD PLAN AREA

CP 3: “In order to achieve the goals and objectives for land within a Neighbourhood
Plan Area designation, a comprehensive Neighbourhood Plan shall be required to
deal with the following issues:
CP 3a: “current area characteristics, including slope and environmentally
sensitive areas (vegetation, wildlife, watershed characteristics);
CP 3j: “ drainage analysis to ensure adequate disposal including on-site
retention and maintenance of the natural character of watercourses in the area;”
page 54
15
GRLUC: The intent is to use the watercourses on Block 6 for residential housing, roads
and driveways, not to maintain the natural character of this environmentally sensitive
area. Absent new geotechnical information directed to slope conditions, the Town must
still rely on Thurber’s work identifying the relative slope/gradients on the lands. In
addition, no drainage analysis is provided and no on-site retention planned. All the
environmentally sensitive areas in the plan area are, as yet, undetermined. The Town
recognizes this fact and requires a study to identify further these additional areas of
sensitivity in advance of adopting a neighbourhood plan. Therefore the GRLUC is
NOT CONSISTENT with Council’s policy.

CP 9: “In the Gospel Rock Neighbourhood Plan area all multi-family, commercial
and/or industrial development is subject to a development permit with respect to the
form and character of the buildings and site design.”
Page 55
GRLUC: The plan does not include designations of areas subject to development
permits for form, character and site designs. Therefore, the GRLUC is
NOT CONSISTENT with Council’s OCP policy.
OCP SECTION 8.0 UPPER GIBSONS
OCP 8.5 RURAL AND AGRICULTURAL LANDS

CP 4: “Minimize urban-rural conflicts with existing or potential future agricultural
operations along boundaries where non-agricultural lands within municipal
boundaries adjoin lands within the ALR. Efforts to minimize urban-rural conflicts
include:
CP 4a: “the designation of non-farm lands with land uses that are compatible with
farm use such as Greenbelt (e.g. designation along Gibsons Creek);
CP 4b: “the physical separation by a road or similar barrier between farm and
non-farm uses (e.g. Reed Rd, Payne Rd.); or
CP 4c: “suitable setback or buffering within non-farm areas (e.g. along the
western municipal boundary north and south of Charman Creek) including ALR
lands in the SCRD.”
Page 61
GRLUC: The LUC shows no evidence of a buffer as would be required where the
eventually relocated Shaw Road runs along Area E ALR lands. Therefore, the GRLUC
is
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NOT CONSISTENT with Council’s Policy.
OCP SECTION 11.0 TRANSPORTATION
OCP 11.1 ROADS

CP 13: “Require traffic impact studies for developments that are expected to create
operational problems associated with the safe and efficient movement of traffic,
pedestrians, bicycles and transit vehicles. Improvements identified as a result of the
study will be the responsibility of the developer and implemented as a condition of
site plan approval.”
Page 80
GRLUC: As the GRLUC cannot identify future accesses to the neighbourhood, it can be
reasonably argued that it qualifies as expected to have operational problems. Moreover,
the SCRD and residents of both Area E and Bayview Heights have documented their
concerns about traffic increases and traffic hazards. With no impact study, and no
improvements identified, the GRLUC is
NOT CONSISTENT with Council’s Policy.
Note: By using the GRLUC as the background document in preparing a final
neighbourhood plan, with improvements left unidentified, Council may be abnegating its
duty and its right to require that the developers build and pay for the improvements
necessary in the future. If, as proponents suggest, buildout is several decades down the
road, potential funding for new improvements required in the future could become the
Town’s responsibility. Matters are more complicated with a group of 11 separate
owners, some of whom have indicated they do not want any development of their lands
in their lifetimes. How will the Town allocate funding responsibility to these owners into
the future?
OCP SECTION 12.0 SERVICING
OCP 12.1 GROWTH MANAGEMENT AND THE PROVISION OF SERVICES

CP 1: “Require the land owner or developer in any development to provide the
following minimum level of services:
CP 1c: bicycle paths and trails (as required in Trail and Bicycle Network Master
Plan…)”
page 83
GRLUC: The Land Use Concept does not indicate any provision for the trail and bike
paths required from the Master Plan. Council commissioned an environmental study to
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accurately document the existing trails (aerial maps were used); however, the LUC has
not slated them for preservation. Therefore the GRLUC is
NOT CONSISTENT with Council’s policy.
OCP 12.4 STORM WATER DRAINAGE

CP 2: “Require that developers provide an overall drainage study and drainage plan
of the area proposed for development which maximizes on-site drainage control,
limits impervious areas, manages a wide range of runoff events and reduces runoff
through infiltration.”
Page 86
GRLUC: The LUC has not provided the required overall drainage study nor drainage
plan for the area. Background drainage work cannot be relied on as it is based on storm
water outfalls along the eastern and western boundaries of Block 7 into Georgia
Straight. Since no uses of the land are allowed (not even ones the municipality wants to
do) due to the steep grade, and since storm water outfall is a use, clearly the HollandBarr drainage plan cannot be relied upon as being the necessary drainage study. Other
OCP policies require that natural drainage systems be respected and maintained, not
graded and filled. No plan has shown what the proponents will do with the creek and
drainage water they intend to pipe off Block 6. With no access to Gower Point Road
from Block 6, with no connections in Area E to the Town storm sewer systems and with
no ability to increase flows in Seward Creek, drainage from Block 6 is fraught with
unresolved issues. The GRLUC, rather than offer an overall drainage program, seems
to identify an overall drainage problem. Therefore the GRLUC is
NOT CONSISTENT with Council’s OCP policy.
Note: The GRNP, in its earlier Holland-Barr incarnation, did identify the three separate
drainage catchment areas, including Seward Creek—which in this iteration will be
eliminated—but failed to create the required drainage plans that locate on-site retention
works including the above-listed limits.
SMART PLAN GOALS VIS-à-VIS GRLUC
The Town of Gibsons’ Official Community Plan highlights several goals in addition to the
policies and objectives the Town must adhere to. Here, we present a summary of
“Smart Plan Goals” from the OCP as they relate to the GRLUC.
From the OCP Part B 3.2 The Goals of a Smart Plan:
“The overall philosophy of sustainable development and the principles of Smart
Growth can be used to define specific goals and objectives for the Town of
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Gibsons. The community has been involved in a number of visioning exercises,
including the Gibsons-Naturally strategic plan exercise (2001)….”
“Listed below are some general goals that have been identified by the
community. More specific objectives are provided within each policy chapter.
The goals and objectives of the OCP are derived from the issues identified during
the planning process, and are used to formulate the policies of the Plan.”
Note: Only those OCP goals that pertain to a GRNP are listed below.

Grow in harmony with the natural surroundings and ecosystems.

Preserve all important and unique natural features, including watercourses,
landforms and habitats.

Respect the natural drainage of the overall area by ensuring that future
development does not negatively alter existing drainage patterns or water quality
of receiving watercourses.

Ensure that uses on the waterfront and harbour area do not negatively affect the
marine ecosystem and are compatible with upland uses.

Acknowledge the value of forested lands for their benefits to the community for
improvements to air quality, natural drainage and opportunities for recreation.

Provide a system of parks, trails and beach access points, and community
recreation facilities related to the natural amenities and changing demands of
community residents.
LIMITS TO ANALYSIS
Maps the committee and public have been working with have been small, poorly
reproduced, and vague as to identifying markers. When asked on several occasions,
the proponents’ representative has indicated that residential development proposed in
LUC is sufficiently landward of the crest of the ridge on Block 7. However, because of
the inadequate maps, the positioning of the development is hard to ascertain. It is
obviously a very important issue to the public since the question has been repeated at
many meetings.
If the public’s apprehension proves to be the case and proposed residential
development does penetrate below the ridge, as generally indicated in LUC attachment
5, the GRLUC would be in conflict with the OCP in several more areas.
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CONCLUSION
We can state definitively that the GRLUC presents many more conflicts with the Town
of Gibsons OCP than either of the previous proposals submitted.
We find sufficient evidence of conflicts that are in no way predicated on the use of
submitted mapping to say conclusively that the November 22, 2010, draft GRLUC fails
in major ways to meet the stipulations of the Town of Gibsons’ Official Community Plan,
its requirements, goals, objectives, guidelines and policies.
RECOMMENDATIONS
To bring any eventual Gospel Rock Neighbourhood Plan into conformity with the Official
Community Plan, we recommend that Council ensure that the LUC/GRNP includes, at a
minimum, commitments that the proponents, including the Town where applicable, will:
A. Supply the information the OCP requires of a Neighbourhood Plan, specifically:
1.
Undertake a complete drainage/ analysis and plan with details of on-site
retention works, limits to impervious surfacing, and plans for runoff reduction and
the siting of these in the plan area. This drainage plan must alter neither the
“natural drainage” systems of the overall area nor the waterways of the area. As
well, the drainage plan must not alter the three separate catchment systems,
north, east, and west, as identified in Holland Barr Figure 14.
2.
Have a habitat mapping study performed, with newly identified areas of critical
habitat protected from development with DPA setback areas, as recommended
by the Ministry of Environment, this mapping to include, but not be limited to: rare
or sensitive plant communities, nesting sites, perching/feeding/hunting trees for
raptors, snags and stumps for woodpeckers, bat habitat, alligator lizard habitat,
songbird feeding habitat trees, mammal habitat including all freshwater
accesses, wildlife trails and corridors, and freshwater seep plant communities.
3.
Have an Archaeological Assessment performed with input from the Squamish
First Nation including maps of and preservation plans for the sites identified.
4.
Identify the freshwater seeps, their surrounding plant communities, and the bluffs
and gullies below Gower Point Road, which have been newly identified as
sensitive ecological systems, and establish setbacks of 30m for each, as per
Ministry of Environment recommendations.
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5.
Map important and unique natural features (e.g., “footprint” and “stone circle”)
and draw up preservation plans including appropriate setbacks.
6.
Identify and arrange protection for sites of historical significance, like the natural
clearings, quartz cross and the slope west of the rock used historically by citizens
to gather for special religious worship, including the area historically used to
access the beaches below Gospel Rock itself and Secret Beach.
7.
Ensure forest preservation below Oceanmount through to Gospel Rock lands
(see OCP page 44), including identification and protection of raptor, bat,
woodpecker, and migratory bird habitat trees, and snags and stumps used by
both birds and mammals.
B. Avoid development uses or activity in areas of concern as defined in the OCP (and
other regulatory regimes), specifically:
8.
Designate for passive preservation, not active parkland, the land located in
polygon 82, also identified as the “bluffs to the east of the viewing site,”
implement measures to minimize deleterious pedestrian overuse, and include a
30m setback (as per provincial Ministry of Environment recommendations 2004
for “sensitive ecosystems”).
9.
Withdraw all development uses from DPA1 and -2 zones of Blocks 6 and 7.
10.
Withdraw plans for development uses in all Greenbelt areas.
11.
Plan no development uses of the waterways on Block 6 and include a setback
from development of 30m, as recommended by the BC Ministry of Environment
2004, around each of the tributaries.
12.
Undertake no uses at all on the marine backshore below Gower Point Road, and
acquire it for park.
13.
Include neighbourhood parkland dedications on flat land other than DPA1 or
DPA2 or Greenbelt areas.
14.
Maintain present trails along ravines, and where necessary, carry out the works
required to protect the banks from negative impacts of trail use.
Some of these requirements could negate each other. For instance, if the GRLUC
changes as it relates to Greenbelt areas (Schedule A), as it must, and removes
development plans on those lands, the geotechnical study for the ravines on Block 6
would be moot. No development is acceptable and therefore no geotech
recommendations for development would be needed.
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Nor would a DPA1 geotech be required for the steep slopes of Block 7 when DPA2
restrictions are applied, as the land, at >25% grades, is too steep for any development
uses. In other words, DPA2 would override DPA1 in this instance.
Similarly, if the proponents withdraw from Greenbelt and DPA1 and - 2 areas for the
entire slope of Block 7, the marine backshore area along the waterfront recently
identified as an essential buffer to the arbutus forest would be protected, as would the
foreshore freshwater seeps, their sensitive plant communities, and the bluffs and gullies
below the road, all recently identified by the Town as having high value for conservation.
ATTACHMENTS
A
Environmental Assessment of Proposed Development at Gibsons, BC by Tera
Planning (1991)
B
Letter 1: from Thomas Plath, Ministry of Environment, Lands and Parks, BC, to
Susan Stratis, Municipal Planner, Gibsons, June 1995
C
Letter 2: from Thomas Plath, Ministry of Environment, Lands and Parks, BC, to
Susan Stratis, Municipal Planner, Gibsons, October 1995
D
Letter 3: from Robert A. Edwards, P.Eng., Water Management, Ministry of
Environment, Lands and Parks, BC, to Marc Goodwin, Gower Point Road, June
1995
E
Letter 4: from Bennett, Parkes, Barristers and Solicitors, to the Attention of Ron
Yaworsky, Director, Special Projects, David Nairn and Associates Limited, North
Vancouver, June 1995
F
Map 1: Golder Associates Site Topography Slope Analysis (colour-coded legend,
double page), n.d.
G
Map 2: Geotechnical Hazards and Environmentally Sensitive Areas, DPAs, David
Nairn and Associates (double page), n.d.
H
Plant and Vegetation Assessment of the Gospel Rock Area, Gibsons, BC by
Terry T. McIntosh Ph.D., Biospherics Environmental Inc., 2007
I
Land Use Plan—Site Sections, Gospel Rock Land Use Concept, November
2010, annotated
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