• Regulation of the water supply, to ensure that all users contribute to conservation.
RECOMMENDATIONS:We support drip irrigation in our conservation ethic.
There is a need for a clear priority to support farmers in their efforts to grow food locally, reducing our carbon footprint by replacing imported food with local food supplies; and to produce programs to assist farmers to improve their water management practices as new technology is developed.


2 C COMMUNITIES
We would like to see some effort to regulate some form of conservation of water within the population. Double flush toilets and aerated shower heads could be mandated in all new construction. Motion activated faucets could also be mandated. All these new innovations should be encouraged, especially in government and other public buildings. In Nevada when just the toilets and shower heads were installed in a major hotel, water use was reduced by 50%. (SEE APPENDIX B)
RECOMMENDATIONS:
The practice of recharge of aquifers with treated wastewater should not be allowed. We have concerns about pharmaceuticals and other unfiltered chemical contaminants in the water that cannot be removed.
GGMS is against groundwater use on lawns.
Water saving utilities (e.g. low flush toilets) should be mandated in all new construction. Refit should be encouraged for all public buildings.
Education is needed within communities to alert people to the real danger of prolonged and frequent water shortages, the benefits of water conservation, and the part they can play to conserve and protect this precious resource.

3 GROWTH
Some have said that we grow or we perish. We question this statement. The place for growth in urban settings can be established through creating urban infill and in the best case scenario, creating neighborhoods within the urban landscape.
In the case of Salt Spring Island the Polis Project has written the “Soft Path Strategy for Salt Spring Island” (See Appendix B)
This approach addresses the need for planning for water conservation in a Gulf Island Community to allow for sustainable growth of the community.

3 A DEVELOPMENT
Water is already scarce, wells are going dry earlier and more often, and wells which historically were good all year are starting to fail. New wells drilled to service new development can severely affect older established wells and even cause them to go dry.
Most wells on Gulf Islands are clustered near the ocean boundary. Depletion of an aquifer can lead to salt water intrusion.
We would also like to see the rural areas planned with rural trained planners. Many urban planners are employed in rural development. This can lead to some very basic misunderstandings and errors in building sustainable rural communities.
Groundwater is referred to as the Natural Infrastructure of the rural landscape. We have neither the capacity nor the geology in many rural areas to support development in any concentrated form.
One option is to introduce a time factor into the building permit process. We could adopt a ratio of 1/5; that is: prove water for five homes and then allow the contractor to build 1 home and then wait for five years before another home can be built on that site.
Another option is to cap development at a certain level.
The best option is to adopt an ethic of environmental conservation. (SEE APPENDIX C)
Islands Trust Submission to Water Act Modernization – April 30, 2010
Page 4
“Water Conservation
Issue: Low and declining supplies of groundwater require careful management to
ensure all public and private needs can be met in a balanced way.
Recommendation:
Integrated rainwater catchment systems should be mandatory in all new construction on the gulf islands. Storage and re-use of grey-water should also be considered as a mandatory feature in areas of acute water shortage. Grey water / purple pipe systems must require backflow prevention valves. Education is needed within communities to alert people to the real danger of prolonged and frequent water shortages, the benefits of water conservation, and the part they can play to conserve and protect this precious resource.”

RECOMMENDATIONS:
The Islands Trust Areas should be classified as a slow development zone.
We need a clear statement of what development will be allowed based on present water stocks and taking into consideration the fact that in some areas the water table falls lower every year in the dry months. It recharges to the same levels in the wet months, but that ever declining water table in the dry months is an established trend and it concerns us.
Integrated water catchment systems should be mandatory in all new construction on the gulf islands.
We have 1800 developable properties on Gabriola. We need an approach like the Salt Spring study that relates water use to buildout capability. This is not possible with the old build-out plan obligations. All we can do now is regulate the allowed development. (Appendix B)
Storage and re-use of grey-water should also be considered as a mandatory feature in areas of acute water shortage.
Grey water/purple pipe systems must require backflow prevention valves.

3 B ILLEGAL SUITES
To create a situation where we have a number of illegal suites sanctioned means that we are stressing the capacity of our groundwater infrastructure. This is a situation where the well and septic which were designed for a one family dwelling are being stressed by the doubling of their use.
There is also the practice of guest buildings being used as a one family dwelling.
Any well that services more than one family dwelling is considered a water system.
To operate a water system you need to become a water system operator. You need to become qualified through government courses and maintain the system according to water system regulations. The maintenance required is two water tests at an accredited lab twice a month. You also need insurance because of possible water delivery shortages and water quality issues like water borne illness.
The Ministry of Health has indicated that any permit to add to a dwelling will trigger an onsite wastewater system assessment ($200.00) and that the upgrading or replacement of that system will probably be recommended by the MOH. Replacing Onsite Wastewater Systems costs from $15,000 to $40,000.

4 SPECIAL CASES: Areas held in trust for all BC citizens
There are areas in BC that are specifically dedicated to certain principles. We are thinking of the Agricultural Land Reserve (ALR) and The Islands Trust Area. Each area has this in common: they are held in trust for all BC citizens.
Water on the ALR should be prioritized for agricultural uses and not for commercial sale.
Some method of determining the extent of aquifers beneath ALR lands and the boundary for agricultural use and restrictions for non agricultural use should be applied to that aquifer. Water does not recognize the human determination of geography like lines on a map. The aquifer boundaries could be determined much like surface water boundaries.


5 REGULATE GROUNDWATER EXTRACTION AND USE
We think that the time has come for regulations that protect all water systems, groundwater in particular.
If you dam a stream the results are quite evident.
If you deplete an aquifer, the results are less obvious except to people whose wells are supplied by that aquifer, and who have no means of proof that this sudden depletion of water supply to their well is a result of third party interference.
There is no regulation for bulk groundwater pumped from the aquifer for sale.
The water thus removed is no longer available to recharge the aquifer from which it is taken. This happens in the dry season as other wells are diminished or depleted and the aquifer used for extraction is also under stress.

This is an excerpt from the Islands Trust Submission to Water Act Modernization
Consultation, April 30, 2010
“Bulk water extraction
Issue: The current system puts the burden of proof about water table damage on those who are affected, rather than on those responsible for large withdrawals. Local governments have little legal authority to manage bulk water extractions, even though they are threatening neighbouring residential water supplies.
Recommendation: Where there is high demand in relation to aquifer capacity, the threshold should be just above the volume required for normal domestic purposes. The threshold for what are considered “large” bulk water withdrawals should be based upon the characteristics of particular aquifers and the demand upon them, with a lower threshold for fractured bedrock aquifers. Some have suggested that the extraction of groundwater for sale should be prohibited altogether in the Islands Trust area.”
Further to this we have a position for consideration by the Islands Trust on bulk groundwater extraction requirements:

5 A GGMS POSITION on Bulk Groundwater Extraction

1 The first requirement for a permit for Bulk Groundwater Extraction is an independent assessment of the subject location for ground water availability by an independent, registered, professional engineer/geohydrologist who has a proven history of planning a community water supply and who has liability insurance to cover potential damages or short falls.

2 The perimeter limits of the subject aquifer shall be delineated by a similarly qualified professional engineer/hydro-geologist.

3 A dedicated monitoring well shall be in place on the subject aquifer for a minimum of one year before bulk groundwater extraction can take place. The monitoring well shall be capable of recording daily baseline groundwater/aquifer levels and these shall be recorded in a log. This log shall be a reporting tool to the agency that oversees the extraction permit.

4 All residents shall be notified one year in advance of application to extract bulk groundwater, to provide existing residents an opportunity to establish pre-existing groundwater conditions in their residential wells.

5 No single source bulk groundwater extraction shall be permitted as a long term supply.

6 Until these issues are satisfactorily resolved in the Islands Trust Area, emergency deliveries of bulk groundwater shall be supplied from existing municipal sources on Vancouver Island in order to protect the sustainability of gulf island aquifers.
7 For sustainability issues regarding food security there shall be no bulk groundwater extraction from the ALR for non-agricultural use.

Submitted by Jeremy Baker, GGMS Board

RECOMMENDATIONS:
Bulk groundwater extraction for sale should not be an approved practice in the Islands Trust area.
There should be no bulk groundwater extraction from the Agricultural Land Reserve for non-agricultural use.

6 STORMWATER MANAGEMENT
6 A Ditches
Ditches are dug with large machines from the Ministry of Highways that uproot any plant life in them. This plant life would slow the water flow enough so that more time could be allowed for stormwater to enter the ground and recharge the local aquifers.

RECOMMENDATION:
Plant life in ditches should be replaced to slow stormwater flow along the ditches.
6 B PERMEABLE SURFACES
In as much as it is feasible, the owner of every property upon such
property being developed shall and must provide for soil infiltration of
rainwater that runs off of any non-permeable surface created by development.
Channeling of these waters to stormwater ditches off of the property shall only
be allowed upon proving that the local soils will not allow for infiltration
for all or some portion of the water. That portion that can be absorbed onsite,
shall be.
Ed Hoeppner, HORNBY ISLAND
RECOMMENDATION:
Permeable areas should be maintained as much as possible.