Town of Gibsons
474 South Fletcher Road
Gibsons, BC
March 27, 2010
Dear Mayor and Council,
I am writing today to express my concern that, in regard to environmental values of the
Gospel Rock Neighborhood Plan area, the “refinement committee” is not achieving the
standard of care rightfully and reasonably expected by the public. I refer especially to the
refinement committee’s decision to only bring forward options that allow waterfront
development. In other words, the refinement committee is proposing to put housing on
one of the rarest and most threatened ecosystems in coastal British Columbia.
According to the terms of reference for the Gospel Rock Environmental Assessment
Study, the purpose of the study was, among various objectives, to identify ecological
values and I quote:
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broader areas that should be considered for retention and /or protection due to
significant ecological values (italics mine throughout )
identification of smaller, high ecological and environmental areas that should be
considered for retention and/or protection
measures required to maintain the ecological value and diversity of this area
factors that can or are likely to influence the feasibility of the above.
The terms of reference further specified use of the province’s Biogeoclimatic Ecological
Classification (BEC) system for identification forest ecosystems, site types and plant
communities. The site types were to be mapped and their conservation status described
with reference to the Conservation Data Center’s Red list (threatened and endangered)
and Blue list (management concern) and also to the Sensitive Ecosysten Inventory (SEI).
The results of these considerations were provided in the report from Keystone Wildlife
Research Limited dated October 2007 (pages 7 and 13). The Gospel Rock forest above
and below Gower Point Road is the dry Douglas Fir – Arbutus ecosystem (Coastal
Western Hemlock extra-dry maritime) of which very little is protected and very little can
be protected. Furthermore, the forest still standing at Gospel Rock is predominately of the
“02” site type which is the host site of an endangered (Red-listed) plant community. Also
recognized in the Keystone study are seven other site types present in the planning area
of extreme conservation concern status. The sensitive nature of the Gospel Rock forested
lands is also regonized in the Sensitive Ecosystem Inventory. Ecologically speaking, the
Gospel Rock forest, right down to the water’s edge, is irreplaceable and of extreme high
value for conservation.
Unfortunately, the authors of the Gospel Rock Neighbourhood Area Blocks 6 and 7:
Environmental Assessment Sudy Final Report entirely dismissed the above information
from the Keystone report as outside the realm of legal requirement and therefore only a
matter of voluntary or negotiated concession. Authors Larson and van Poppelen are well
outside the study’s terms of reference with this conclusion. They are also entirely
incorrect. The Town of Gibsons, like all municipalities in BC, has statutory authority to
determine which land uses within the Town’s boundaries are in the public interest. The
questions put forward in the terms of reference relate to ecological values and the Town’s
public commitment to environmental stewardship. Furthurmore, Gospel Rock property
owners either agreed to the terms of reference for the Environmental Assessment Study
(Glen Bryson) or made no objection.
The faults of the Final Report were known and discussed by the Select Committee. This
was presumably part of their decision to recommend against waterfront development. The
refinement committee is, in my opinion, clearly negligent to only recognize minimum
legal requirements. Such a position may lead directly to an enormously ignorant decision
to allow housing as an acceptable land use on the Gospel Rock waterfront.
For your information, my use of the word negligent relates to the definition cited in the
Ombudsman’s Principles of Administrative Justice 2004, i.e., neglegence is the failure to
achieve the standard of care reasonably expected by the public
I ask you to remember the public’s overwhelming support for protection of ecological
values throughout the planning process. This was especially noteworthy in the results of
the Town’s questionnaire. We are not asking council to do anything that the public is
opposed to. On the contrary, by any measure we have, the public rightfully expects the
Town to practice stewardship that is based on sound scienctific evaluation and not just on
minimum legal obligations.
Thank you for your consideration of these important issues.
Sincerely,
Daniel Bouman, Executive Director
SCCA