January 12, 2020

Dear Mayor and Council:

We would like to share some comments for your consideration related to both the staff report on Councillor Justice’s motion on curbing sprawl and the staff report on the Integrated Climate Action Plan. We see these as highly related.

We would first like to thank Councillor Justice for initiating this process and conversation, and to thank North Cowichan staff for their work on both the report on his motion and on the Integrated Climate Action Plan. These are complex and urgent issues and we appreciate people’s willingness to engage.

The two reports are related because sprawl is the number one municipal climate challenge. Outside of industrial emissions that are regulated by higher levels of government, the largest local source of emissions comes from transportation. These emissions are driven by our urban form. Every new approval of development where people are more likely to get in their cars than to take transit, bike, or walk, adds new emissions at a time when science tells us we must be rapidly cutting emissions or face an essentially unlivable future as we see on display today in Australia.

As a first principle of climate action, we must stop making things worse. This is why we fully support the intent of Councillor Justice’s motion. Waiting until the OCP is complete to end sprawl will allow for many months of potential new approvals that take us in the wrong direction. Hitting climate targets is already hard enough without adding to the challenge. Council has acknowledged that climate change is a crisis. Local government needs to be acting on this crisis with all the urgency and timeliness they can muster.

We offer the following comments on the staff report on Councillor Justice’s motion:

• In general, the staff report is clear on a number of fronts in that a) Council is within its authority to pass such a motion; b) that even if the motion passes, there is still significant latitude for the approving officer to consider applications; and that c) the motion does not mean an ‘end to development’ both considering b) and also that there are still significant lands not influenced by the motion. In sum, these points deflate much of the public criticism of the motion.

• It is unclear in the staff report whether a 30-minute walking distance represents a one-way or return trip, but if the former, that is not a reasonable measure of reality. Given the choice between a one-hour return walking trip and driving, the vast majority of people will just get in their cars. This point highlights the need to integrate other options into this conversation such as transit routes that are facilitated with more density, and bike infrastructure.

• In the discussion on potential impact on land supply we are struck by the assumption that the future will be much like the past. We understand the utility of this assumption in a “speculative” exercise to establish some sort of baseline, but we note that the climate crisis means that the future will be nothing like the past, both in terms of our operating environment and policy environment. The large cuts in emissions that are needed will mean entirely different ways of operating and a likely dramatic curtailment in the construction of new single-family residential units in favour of attached and multi-story dwellings.

• We are sympathetic to applicants who are well advanced in their application process, who have invested significantly. It appears that the latitude still afforded to the approving officer under this motion could allow such advanced applications to continue. We do not believe that this concern should get in the way of the overall motion. Perhaps language can be included to the effect that existing applications advanced to a certain stage related to non-recoverable and significant investment are afforded latitude by the approving officer.

We offer the following comments on the staff report on the Integrated Climate Action Plan:

• Again, we appreciate the start of this process and the fact that the staff report does a good job of outlining the various potential areas of municipal climate action. We see this potentially lining up well with the 10-point checklist we developed for this purpose and would welcome a dialogue with staff and council as this process unfolds.

• We note that the municipality’s existing target of an 80% emissions reduction by 2050 is assumed in the report. The current science and indeed much policy – including Canadian federal policy – is either already targeted to reduce emissions to net-zero by 2050, or quickly moving there. More importantly, given that policy accountability tends to fall away the farther away a target is, we believe there must be interim targets that drive shorter-term decision making. A 2030 target of halving emissions is in line with the current science and with council’s acknowledgement of a climate emergency.

• We support the recommended direction of having staff develop options and costing for various climate measures, but are concerned about a potential “shopping list” approach coming to council to pick and choose from according to the whims of the day, rather than an evidence-based plan aimed to have the broadest impact. An integrated plan with specific measurable targets by policy area such as the one the City of Vancouver staff produced and which was adopted by council wholesale and unanimously. We therefore believe that the council should ask staff for an integrated plan with specific measurable targets by policy area.

• While we agree with the staff report that the focus should be on reducing transportation emissions, again we return to the fact that the biggest municipal driver of such emissions is urban form. However, this appears as a weak sub-bullet to “develop walkable neighbourhoods and amenities” in the document. We believe this is insufficient. We recommend instead that a seventh strategy be added to the list, and that it be the first in line reflecting its importance – “End urban sprawl and encourage dense development close to services.” Measures beyond just tightening urban containment boundaries will need to be considered to meet this objective.

• Finally, we recommend a timeline be added to produce an integrated plan and that council monitor progress on this timeline closely. The climate emergency resolution was passed July 17, 2019. That resolution asked for an “integrated climate strategy” in 90 days. Instead, it has been 180 days and we have only a staff report that envisions making a strategy. Other local governments have moved much more quickly from inception to execution in their climate action. This is what the crisis requires.

Thank you for considering this feedback.

Yours sincerely,

Jane Kilthei, Director, on behalf of One Cowichan