Unfortunate staff report – response 4

This post is the fourth in a series of responses to a November 2008 Richmond staff report on the Garden City Lands. If you are new to the topic, you may wish to begin by scrolling down to earlier posts in the series for background information.

Most of the staff report is devoted to “measures the City is prepared to undertake in Richmond to further benefit agriculture in the remainder of the Agricultural Land Reserve” (p. 1) in support of the Garden City Lands ALR-exclusion application. Because the application has “very little chance of approval” (p. 2), the project manager (Randy Fasan of Canada Lands Company CLC) and City staff under his direction have apparently given up on their other flimsy arguments for ALR-exclusion and put their eggs in one basket, supposed benefit to agriculture in the ALR in Richmond.

The Garden City Lands speculators, Musqueam-CLC, would pocket hundreds of millions of dollars from City rezoning enabled by ALR exclusion of the lands. The proposal is presumably intended to compensate the ALR for the loss of the 136 acres of prime farmland. However, what is being offered in the new proposal is a pittance, with almost nothing coming from the Musqueam-CLC if one examines closely. In ancy case, the compensation for lost ALR land is not something appropriate like putting equivalent land into the ALR.

I also suspect that there is little or no substance to even the pittance that is being offered. Certainly we found that to be the case when investigating the net benefit to agriculture in what was proposed in the April 2008 application. The “agricultural endowment fund” turned out to be an unfunded vague idea. It was essentially a hoax, as explained in Save Garden City, pages 35–41. Furthermore, it was far more likely to hinder agriculture than to help it.

Try looking over the proposals in the staff report to see what you think. In the first set of proposals, I see some proposals that look good enough but that have no natural link to the Garden City Lands. Here are my reactions:

·        It may be useful to help the ALC with enforcement of the ALR regulation, although I would think that enforcement is better done by Agricultural Land Commission staff, perhaps with City staff serving as extra eyes and ears. Mixing city bylaws with the ALR regulation sounds like a tangled way to squander staff time. Furthermore, in principle, I doubt that Richmond taxpayers want the city-level government to be unnecessarily taking on provincial-level expenses.

·        Coordinating placement of clean fill to ALR sites sounds fine, even though it is inconsistent with the claim in the application’s Appendix 1 that the clean fill on part of the Garden City Lands hinders the lands’ suitability for agriculture.

·        Increased soil production by the City on a cost recovery basis seems like common sense if (and it’s a big IF) that kind of entrepreneurial undertaking can’t be handled by the private sector. However, encouraging local soil production is the sort of thing that the citizens would expect their city to be doing to improve agricultural capability because it’s the right thing to do. It shouldn’t be done so that the good thing can be rewarded with a get-out-of-jail-free card to use after destroying the prime farmland that the citizens value so much.

It is possible that some of the above steps should be undertaken, but that should happen only if they are found, through a rigorous analysis of costs and benefits, to be worthwhile in their own right. Whatever the results of the cost-benefit analysis, it is hard to envision how they could become a justification for paving ALR land.

The second set of proposals is related to improved drainage and irrigation in East Richmond. That has been overdue for decades. It has been in Section 2.1, Agriculture, in the Official Community Plan for almost ten years and in the Agricultural Viability Strategy for over five years. Now that a program is finally being implemented, the staff report is implicitly threatening to stop the program unless the Garden City Lands are removed from the ALR. That is incredibly disgusting.

The next two sets of proposals look to me like numerous ways to meddle with the private property rights of owners of small properties in the ALR. It all reads like a script for a regulatory romp in bureaucratic paradise, which would simultaneously be the small ALR property owners’ nightmare. If any of the proposals are useful, they should be retained after careful study and consultation. However, they are most certainly not something to be rushed into. 

In particular, the proposed replotting that isn’t really replotting (p. 6) smells fishy. The theory of the scheme is that it will result in owners voluntarily letting their property be manipulated in ways that would be legally impossible with a straightforward replotting program. That might happen in a few ways, but common sense says that most people won’t voluntarily give up rights that protect the value of their assets. The proposal smells to me like jeopardizing our citizens’ property rights to appease the Agricultural Land Commission (if it would accept such a thing).

As it happens, many of the leaders in the struggle to save the Garden City Lands have the revival of small farming in Richmond as one of their goals. It can be best accomplished if the lands are not lost.

Next, the unfortunate staff report lists urban agriculture proposals. Again thanks largely to a lot of the people who are working to save the Garden City Lands, they are already in progress. Urban agriculture progress in Richmond can continue to be accomplished far better if the lands are saved than if they are paved.

The final proposal is for a Garden City Lands MOU to bridge between a conditional approval from the commission and a final approval when all the conditions have been satisfied. Given the mess that the City has got into with the existing Garden City Lands MOU, do we really need another MOU? That makes as much sense as doing everything possible to get a property out of the ALR, thereby increasing the value by hundreds of millions of dollars, and then trying to buy it to put it back in the ALR. Not surprisingly, the two suggestions came from the same source: City staff engaged in the CLC project to get the Garden City Lands out of the ALR.


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