Forum submits concerns and solutions regarding land development to SCRD

On 14 November 2022, the Halfmoon Bay Community Development Forum (CDF) sent this to the SCRD: 

Submission to the Sunshine Coast Regional District



Established in September 2022, the Halfmoon Bay Community Development Forum aims to uphold the vision and goals (1) presented in the Official Community Plan (OCP). The Forum serves as a focal point for the residents of Halfmoon Bay on significant issues related to land use and community development. It is a group of volunteers who aim to stay informed of and engage on issues that affect the way our community develops. One role of the Forum is to liaise with various levels of government and other community groups on issues of concern.

Through this submission, the Forum is providing input to current and upcoming SCRD planning initiatives that will guide the development of the Halfmoon Bay community over the coming years. The following problem statements and possible solutions are the outcome of observations and research by several residents during the last two years regarding the impacts of land alteration and development in our community and along the broader Sunshine Coast.


We are aware that the SCRD has several important initiatives underway for 2022-23:

  • Regional Growth Baseline: a report including mapping of potential growth areas and strategic recommendations (2) will be presented to the Board in Q1 of 2023. It is not yet known if this will include recommending the development of a regional growth strategy.
  • Climate Action Plan: the SCRD Climate Risk Assessment Report was presented to the Committee of the Whole on 26 May 2022. A SCRD community climate action plan will be prepared, and community consultations are now on-going.
  • Water strategy: developing a 5-year Water Strategy. The public consultation period closed in June 2022, and a draft Water Strategy will be available in early 2023.
  • Halfmoon Bay OCP: the process to update the seven OCPs under the SCRD will be discussed at the Board in Q4 of 2022 and begin in 2023. A key decision will be whether to roll these up into a single OCP for rural areas, for both harmonization and administrative purposes.

As these plans and policies are being developed, we ask the SCRD to consider the following problems and possible solutions that the Forum has been researching and discussing.



1.Potential negative impacts of land clearing practices

The impacts of climate change and extreme weather events, together with insufficiently regulated and monitored private land development, are resulting in costly damage to public infrastructure and private property. Residents are also concerned about the cumulative damage to ecosystems in Halfmoon Bay.
      1. In recent years, several multi-acre lots have been completely cleared before the approval of a subdivision or development, and irrespective of potential impacts on neighboring property, infrastructure and the environment.
      2. Natural, unaltered ecosystems soak up rainwater. On the contrary, excessive removal of trees and vegetation, combined with insufficient ‘grey’ infrastructure (pipes, ditches, and culverts) can result in flooding, erosion of natural watercourses, degradation of natural ecosystems, and damage to public and private property. It appears that the stormwater management requirements of the Ministry of Transportation and Infrastructure (MoTI) and the SCRD are inadequate to mitigate the risks of and manage the liabilities related to stormwater runoff damage.
      3. MoTI and the SCRD do not appear to consider the cumulative impact of land clearing and permanent conversion on communities and the environment when considering individual development applications.
      4. The SCRD does not appear to have ‘minimum’ standards for technical reports, lacks some of the technical expertise needed to vet these, and lacks transparent mechanisms to accommodate a community request for an independent peer review. Given increased risks related to climate change and the growing number of large development proposals, there is a need for more rigorous and vetted expert assessments to accompany these proposals.

2. Insufficient protection of Halfmoon Bay’s Sensitive Ecosystems

      1. Halfmoon Bay is in the Coastal Douglas-fir Biogeoclimatic zone, which contains at-risk Coastal Douglas-fir and associated ecosystems. The SCRD is a member of The Coastal Douglas-fir and Associated Ecosystems Conservation Partnership (CDFCP) and a signatory to a Statement of Cooperation, which commits it to “cooperation and partnership for conservation of Coastal Douglas-fir and Associated Ecosystems”. Recent and proposed clearing of multi-acre forested properties for the purposes of development appears to conflict with the SCRD’s commitment to conserve these important ecosystems.
      2. The Sensitive Ecosystem Inventory for the Sunshine Coast (2005) is out of date. This dataset requires updating to track progress toward the objectives in the OCP and to inform new policy directions.

Possible solutions to consider for (1) and (2)

      1. Work with partners to update the Sensitive Ecosystem Inventory for the Sunshine Coast. The CDFCP has federal funding to improve mapping in Southwestern B.C., and members of the Forum are advocating for the Sunshine Coast to be the first pilot area. An updated Inventory of the most sensitive, rare, and ecologically fragile ecosystems on the Sunshine Coast would help to prioritize which ecosystems to protect.
      2. Review and modernize environmental Development Permit Areas (eDPAs) in Halfmoon Bay. Expand the coverage of eDPAs, require permits before land is altered, and implement measures to improve protections for at-risk ecosystems (among other objectives).
      3. Review the outdated 1991 SCRD tree cutting bylaw in conjunction with the above.
      4. Require an assessment of cumulative impacts as part of a development approval process.
      5. Adopt a Sunshine Coast-wide bylaw on stormwater management requirements.
      6. Conduct a natural assets/ecosystem services assessment for the whole SCRD region. Require proponents to assess the change in ecosystem services associated with their proposed development and implement measures to minimize or offset ecosystem loss.
      7. Develop minimum standards for the content and quality of expert studies provided by developers, and an expert process for vetting them. Determine the trigger and funding mechanisms for peer review.

3. Insufficient oversight, penalties, and community feedback

      1. Some penalties are not severe enough to deter developers and property owners (e.g. tree cutting, outdoor water use during emergency restrictions).
      2. The lack of a feedback loop to residents on the status of complaints has caused frustration and confusion in the community about progress and outcomes.

Possible solutions to consider for (3)

      1. Compare relevant SCRD penalties against provincial legislation to ensure they are currently set at the maximum allowed. Where the SCRD’s experience is that the penalties are an insufficient deterrent, request an amendment to provincial legislation to raise the ceiling. 
      2. Provide online access to active zoning or development applications to help residents understand what is being requested or has been approved (ex. Regional District of Okanagan-Similkameen, and Nanaimo Regional District 
      3. Introduce an on-line tracking tool for bylaw infraction complaints, like those in some other jurisdictions (ex. Vancouver

Recognizing that the “Possible Solutions” offered in this document are not comprehensive, we look forward to discussing these and other ideas. As a group of concerned citizens who care deeply about our community, the Forum hopes to work with
the SCRD to ensure that Halfmoon Bay develops sustainably and continues to be Rural By Nature.

(1) See pp. iii-v of the 2014 OCP. The vision is: “We preserve our rural community character, exceptional quality of life and abundant recreational opportunities. We protect and live in harmony with our natural environment and its diverse habitats. We encourage sustainable, social and economic growth while respecting our heritage.”

(2) Ref. SCRD EAS Committee agenda of 17 November 2022 (p. 2)