LETTERS: Arguments against the Todsen application

In February 2021 QB resident Susan Lloyd submitted the following letter to the first Public Hearing of the Todsen / Happach OCP and Zoning amendments application. Her thoughtful concerns remain valid and applicable to the second Public Hearing scheduled for 10:00 AM July 7, 2021. — Editor

RE: Public Hearing – 850 Eaglecrest Drive/2075 Island Highway – OCP and Zoning Amendments

I am a resident of Eaglecrest and am opposed to the Official Community Plan (OCP) and zoning amendment applications to permit a 16-parcel subdivision on a portion of the above property.

I am not opposed to providing increased diversity in housing types in the Eaglecrest area in the future, but there is no compelling need for these new lots in the Eaglecrest area at this time as there are lots in the area that remain undeveloped, and there are broader implications relating to “Estate Residential” lands beyond this particular application.

In late 2019, staff considered this application and recommended to Council that it be refused. By memo to Council dated October 23, 2019, the Director of Planning stated “This application would certainly provide a boost to the local building industry by creating new construction opportunities. However, staff cannot support this application, as it conflicts with most of the Town’s policies regarding residential development and does not meet any of the housing needs that are specifically identified in the OCP. Furthermore, this change would be inconsistent within the Town’s longstanding commitment to comprehensive planning.” He recommended that “If Council does wish to explore alternative uses for the area, it would be better to initiate a comprehensive plan for the entire estate properties area..”. While the application at issue has been modified slightly since 2019, these fundamental issues remain.

Since that time, Council resolved that a comprehensive land use development design plan (including considering appropriate urban densification and public recreational amenities) be undertaken to provide direction for future developments within the Estate Residential lands as part of the review process for the OCP. Respectfully, that is the wrong approach. It appears that the Town is making an exception for this particular development when there is no compelling reason to do so. Approving this application is not consistent with the long-terms plans supported by the community in the OCP. The Town should address this as part of the next OCP review or, at the very least, upon completion of a comprehensive plan for the Estate Residential lots in this area. It is necessary work that needs to be done.

The Estate Residential lots are the last remaining large tracts of land within the Town and have long been protected from development as reinforced in the current OCP. Unless there has been a change in circumstances that would warrant it, which does not appear to be the case, the OCP should be respected and not amended in this way. The balance should weigh in favour of protecting the public interest and not the interest of a private land owner who purchased the property approximately 5 years ago with full knowledge of the importance of these lots to the community and the restrictions on development.

If Council resolves to move forward with approval of the amendments, it will be setting a precedent and sending a signal that it is open to development of Estate Residential lands beyond this particular application. How will the Town deal with the next development application for another parcel in the Estate Residential lands? Will it require that the strategic planning work be undertaken and be part of the next OCP process before considering any other applications? Council’s approach should be clarified so that all residents understand what development may be contemplated and everyone is treated in a fair manner.

I am troubled by some comments reported in the media and in Council minutes that suggest that Council feels that the developer in this case has waited long enough and shouldn’t have to wait any longer for this approval, or until after the next OCP review. A property owner is entitled to have its application dealt with. However, any person who purchases land, in particular land that is restricted from development, has no right to expect that the Town will alter those restrictions to allow development and Council should not feel obligated. The Town should be discouraging people from buying up tracts of land for speculation.                 

In addition to the above concerns, I provide comments on additional concerns below. Chief among them, however, is the issue of traffic and the intersection of Country Club Road and the highway. This intersection has been identified as a problem for years and continues to get worse. While the traffic study provided by the developer indicates that the incremental traffic will not make a substantial difference, I note that it does not contemplate the increased traffic that will come from the golf course lots [Cottages at Eaglecrest] and has estimated traffic volumes based on a conservative growth estimate. The study does confirm that the intersection performs poorly now, that traffic will be added, and that other modes of transportation (e.g. transit) are not viable options. It also makes several references to the planned roundabout and that it will improve traffic movement. In my view, no new developments should be approved in this area until this issue is addressed and a roundabout or other traffic control mechanism is put in place.

In addition to cars, there is a need for a safe route for bikes and pedestrians to cross the highway to take advantage of, and connect to, other trails and bike paths, and to take the bus. That should be incorporated into any plan for traffic at this intersection.

My additional comments are:

Land/Lot Supply: The developer was asked to provide a land inventory and supply analysis that assesses the need for additional land to be included within the Urban Containment Boundary and has declined to do so, providing cash in lieu. Respectfully, I can understand why they would not want to complete it as I suspect it would not be favorable to this application. If Council considers that it is necessary to approve this development now and not wait until comprehensive planning has been completed, then there should be a requirement that the housing actually be provided and not be held for speculation or as inventory to be developed over an extended time period. The situation that currently exists on the adjacent golf course property, where an 18-lot subdivision was approved several years ago and not one lot has been offered for sale to the public, should be avoided. I suggest that Council consider mechanisms to encourage, firstly, that the developer completes the servicing and creation of the legal lots, and offers them for sale within a specified period; and, secondly, that the ultimate purchasers be required to construct homes on the lots within a reasonable time, such as 2-3 years.

I also suggest that if the intent is to provide diversity in housing, the area does not need any more houses over 2,500 square feet; 1,800 to 2,000 square feet would be better.

Community Amenities: Community amenities from this development now appear to be largely cash to the Town. While an independent appraisal has been provided to value the lift to Council, the report shows that there are few, if any, true comparables to this development and the value per acre used in the calculation appears low. I encourage Council to independently confirm this value, if possible.

There are few amenities being provided to benefit the local community. There will no longer be a park area, and the main trail being proposed is dependent on the developer obtaining a right of way from the owners of the golf course for use of a portion of the cart path that may never be obtained. There are few community amenities in the Eaglecrest area and this should be addressed in the long-term planning for this area. A large number of people regularly walk and bike on the roads as there are no sidewalks, no bike paths, or trails, and enhancements in this regard are needed.

Traffic: Traffic has been a concern and a roundabout at the intersection at Country Club Road and the highway was proposed years ago. It should be a requirement that this long-standing and deteriorating traffic situation be addressed before this area is opened up further for development. The traffic study indicates that the current intersection at Country Club Drive and the highway is operating poorly. While the study concludes that the impact of this development would be minimal, one has to view this considering the study parameters: i) it was conducted on Thursday, October 1st for 2 hours that day; ii) in forecasting traffic in the future, Watt Consulting Group rejected the BC Ministry of Transportation & Infrastructure estimated 4.2% growth per year in this area and opted for a more conservative rate of 2.3% growth; and iii) the study does not take into account the increased traffic to result from the approved 18-lot subdivision on the golf course lands.

I hope these comments are useful and thank you for the opportunity to provide input.


Susan Lloyd, Qualicum Beach

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