Dear Editor:

WATER LICENCE TRANSFER NOW, IS THE CART NOT BEFORE THE HORSE?
It has been an interesting week in which, on the one hand, we learned much of the Union Bay Improvement District’s (UBID) water user’s views towards Minister Chong’s dictate to transfer their licence directly to the CSRD for her recently mandated Regional Water Supply System (RWSS). And, on the other hand, we read of the recent wisdom given to local politicians on sustainable development for the equally mandated Regional Growth Plan (RGP). But is there not an irony here, i.e. what work has been done to accurately explain, analyze, match and justify the licence transfer for the RWSS or RGP? And, what about any potential sustainability challenges that may exist for the general public, commerce, industry, agriculture, mining, aquaculture, municipalities and all other direct beneficiaries? In this day and age, with so much knowledge and information available to the general public and stakeholders, they will no longer accept having to have blind faith in, and the lack of any interventions or participation to, outcomes that directly affect their futures.

So, where is the verifying evidence for a viable RWSS? Does it include, for example: an MoE water licence allocation model to test the supplies under back-to-back drought years; the recently published “Comox Valley Water Reference Guide” found at www.vancouverislandwaterwatchcoalition.ca for issues and data analyses; analyses of the proposed inter-basin transfers of water; any exponential effluent discharge estimates from the new diversions; issues analyses; stakeholder analyses; a Master Plan and so on and so forth? Tuning up our fragile world merits this and more.

Last week’s UBID public meeting, convened by UBID, highlighted an abundance of collective wisdom and consensus in the meeting’s rise to seriously question the immediate need for transferring its legal water licence for the RWSS-to-be. The RWSS would not be the first large project to go astray amongst political expediencies and, so, the question was, for what and why now? In most places now, such a significant water supply system project, to be funded locally, nationally and/or internationally, would never be successfully approached without stringent checks and estimates on:

•the viability of adequate water sourcing (here we have already seemed to drift from Langley Lake (unproven) to Van Lakes to Comox Lake supplies in search of adequate water resources. Where next ask,groundwater, desalination?;
•The technical and economic feasibility of benefits over costs; and
•A joint Federal/Provincial Environmental Impact Assessment serving all relevant jurisdictions and, hopefully, with a public hearing to accurately determine the balance of public interest for all social, economic and environmental considerations of the RWSS project. And, that is to say nothing of any potential show-stoppers that an EIA hearing may turn up against any aspect of the ultimate development, such as the raising of dam levels.

Perhaps this work has all been done. If so, why is it not being discussed openly?

If not, with UBID discovering that it is to hand over its legal water licence authorization now, without any of the above data or information being proven, something in the process seems more than a little undemocratic and one in which the cart is right in front of the horse. Projects done like this in the developing world, have been laughed out of town and, of course, the funding agencies followed them. Are we not higher up there with our quality standards in this relatively rich part of the world? I am sure that no-one wants to see any of the Comox Valley sold down the river. Someone, please tell me that this letter is all without foundation, and why.

Rodney Jones, Water Resources Engineer (retired), Fanny Bay.