PKOLS – Mount Douglas Conservancy

Unfortunately, there has been a heating tank oil spill near Tyndall Sports Field, which is part of the Douglas Creek watershed. Saanich crews are aware and have responded by placing oil booms within the surrounding storm drain system and at the weir pond at Douglas Creek. The spilled oil will remain in the pipes until there is enough rainfall in the region to flush out the storm drains. At that time, you may see an oil slick in the weir pond at Douglas Creek.

Although the weir is designed to hold and trap pollutants that would otherwise make their way downstream, high levels of stormwater runoff frequently overflow the weir, sending the pollutants downstream regardless. A photo series from October 2011 documenting this exact scenario following a previous oil spill is available on our website:

Oil spills, regardless of the time of year, pose a significant threat to the health of Douglas Creek. In winter, there is heightened concern about the contamination of this critical habitat and the potential risk to the survival of incubating salmonid eggs.
We will update with further information if/when it becomes available.

April 4, 2024, Open House on the Telecommunications Tower Upgrade 4:30 to 6:00 pm, Gordon Head Lawn Bowling Club.

Saanich intends to install a 40-metre tall tower in the centre of the Churchill Drive summit parking lot. We are unclear as to why there was a sudden change in plans but find this idea problematic.

Our Society was not informed of the tower replacement until several months after vendors were invited to view potential sites and submit bids. There has been no consultation.

The original RFP specified the replacement tower was to be located within 6 metres of the existing tower. At some point it was erroneously thought a road from the summit parking lot to the existing tower location was necessary. Road construction costs along with the environmental damages and tree loss prompted Saanich to change the RFP to specify the parking lot location. This was flawed thinking in that the existing tower was installed without a road and the parking lot location was based on a 6 metre error in the underground building location plus a tower height exceeding the P9 zone height restrictions.

We had hoped that a meeting with Saanich regarding the replacement tower location might be productive. Instead, we came out of the meeting with the impression that the probability of Saanich installing the tower in the middle of the Churchill summit parking lot is most likely unless there is a loud public outcry. We need letters sent! Here are some points:The aesthetics of this tower within the PKOLS-Mount Douglas natural park is paramount.

• The replacement tower can be installed near the existing tower just like the existing tower was installed, no access road necessary.
• Trees hide the existing and any nearby replacement tower from the summit parking lot.
• Any summit parking lot location will be an eyesore from every angle.
• The installation costs for either the summit or the parking lot location are comparable.
• The installation funds are from a reserve fund collected over the past 32 years from tower user rental fees. No municipal taxes are involved.
• This is a 50 year decision, the expected life of the replacement tower. It needs to be right!
• The parking lot location will likely eliminate half the existing parking locations.

We want Saanich to reconsider the location near the existing tower as originally specified in the RFP without including a new access road as was done when constructing the current tower.

Flawed Thinking

The original RFP specified the replacement tower was to be located within 6 metres of the existing tower. At some point, it was erroneously thought a road from the summit parking lot to the current tower location was necessary. Road construction costs, environmental damages, and tree loss prompted Saanich to change the RFP to specify the parking lot location. This was flawed thinking because the existing tower was installed without a road. The parking lot location was based on a 6-metre error in the underground building location, plus a tower height exceeding the P9 zone height restrictions.

The photograph on the left shows how materials were moved to and from the existing site in the past. The same method used to install the tower.

Obscuring the View

Don’t let this view be obscured!

• Proposed New Tower on PKOLS Problematic
• We support a New Tower Next to the Existing One.
• Saanich’s Guiding principles regarding the tower
• Our letter to members
• Our Letter To Council_2024-02-12
• Our Letter To Council_2024-02-21

Your Help is Urgently Needed. Click here to find out how

References

• Undated notice was posted by Saanich about the tower replacement
• Undated details on the rational for the tower replacement
• Federal Government regulations on communication equipment
• Saanich open house announcement to provide information on the tower replacement
• The tender award document was posted June 13th, 2023.
• PKOLS – Mount Douglas Communication System Historical War Use, by Jerry Proc
• CREST (Capital Region Emergency Services Telecommunications) system.
• Request to remove the requirement for staff to seek further direction from the Council for the communication tower. Dated Oct 20, 2023
• PKOLS – Mount Douglas, Tender Notification, dated June 14, 2023
• PKOLS communication tower location… article in Captial Daily, April 3, 2024

Saanich is in the final stages of awarding a Request for Proposal contract to construct a 40 m tower (10 m taller than the existing tower) in the centre of the Churchill Drive summit parking lot. It likely will eliminate up to half of the existing parking, will be a major eyesore dominating the Churchill approach to the summit, dominating the view from the summit trail, let alone from most of Saanich. The tower’s aesthetics in this natural park setting do not appear as a consideration in the RFP.

Saanich has proceeded without informing our Society or the public. The few details we know were obtained by registering as a vendor and reading the RFP. 

The only hope is if you and everyone else write a letter in protest IMMEDIATLY! There is no reason why this replacement tower can’t be located next to the existing tower. 

The original Request for Proposal stated: “The new mast or tower must be as close to the existing tower as possible, no further than 6m or 20ft of the existing tower.”

A Geotechnical engineering report examining the existing tower base stated: “the existing foundation is capable of providing stable, long term support to the monopole structure“ and found no issues with the underlying rock. (However the tower itself is overloaded and undersized.)

An excellent possible new tower location could be just south of the existing tower, on a similar rock base allowing for similar anchors. There would be no tree damage and little if any environmental damage.

Someone (consultant or Saanich?) felt a new access road from the summit parking to the summit must be constructed despite the existing tower base and another similar base being installed on that summit, no road necessary. Of course this road would require loss of trees and severe environmental damage as well as significant additional cost. The tree loss, environmental damage and cost is being used as the rationale for moving the site from the summit to the middle of the parking lot in an update to the RFP. But a road is not needed!

It isn’t clear if there would be additional cost at this summit location without the road since the tower would be 10 m shorter, the cabling is already in place, whereas the parking lot location requires a new hole in the building wall and trenching for the cables and worse, it will likely require blasting, a potential risk to the existing underground building integrity.

The life expectancy of this tower is 50 years. The difference in cost, if any, shrinks when amortized over 50 years. NOTE: Tower replacement money does not come from taxes. Instead tower rental fees have been kept in a reserve fund for the past 32 years and are expected to cover the tower replacement cost.

Our Society accepts the need for tower replacement and understands as soon as the new tower is operational, the existing tower will be removed. We support a location next to the existing tower but have a major objection to the parking lot location.

Please write to

Angila.Bains@saanich.ca

With copies to

mayor@saanich.ca
council@saanich.ca
susan.brice@saanich.ca
judy.brownoff@saanich.ca
nathalie.chambers@saanich.ca
zac.devries@saanich.ca
karen.harper@saanich.ca
teale.phelps.bondaroff@saanich.ca
colin.plant@saanich.ca
mena.westhaver@saanich.ca

The PKOLS-Mount Douglas Conservancy supports the replacement of the tower.

We ask Council to request staff to reconsider the proposed tower installation locations near the summit in terms of no need for a new access road being required and reducing the negative visibility of this structure on the natural aesthetics of PKOLS from within and beyond the Park.

The current and future tower will be visible from most of Saanich, and, therefore, care needs to be taken to ensure it aesthetically fits into the landscape of the park as best as possible. Like any good designer/architect / builder, Saanich needs to consider both form, character and function.

From Saanich’s website the following is highlighted about Mount Douglas:

“The Park Charter, approved by Council in 1992, assists in guiding the management of the park:

‘The lands known as Mount Douglas Park are hereby reserved in perpetuity for the protection and preservation of the natural environment for the inspiration, use and enjoyment of the public.’”

We submit the following background information:

1. The current tower, to ensure minimal impacts on the park, was limited to Cellular, CREST and Municipal services only. There is no commercial use. The new tower needs to reflect that especially if more users are being contemplated and it is the reason the proposed tower is larger and more visible. 
2. The agreement to consult with PKOLS-Mount Douglas Conservancy has yet to occur. We did have a brief “information meeting” about a press release that contained (unfortunately) inaccurate information. So, collaboration and consultation has yet to occur. 
3. Information on each potential location for the tower was not offered during the meeting, making consultation impossible. 
4. The Conservancy has a long history of supporting staff with Park decisions, including proposing the current underground communications building and present tower location. 

It is likely, given what we observed during the last installation, that the cheapest and best location for the tower is near the existing tower. This location was ruled out by staff, who were under the impression that a road would have to be built. The necessity of such a road must be questioned. In 1990, Saanich originally planned to build the communications building on that summit, no road necessary. A short time later, Saanich constructed two separate communications tower bases on that summit, no road necessary.

Finally, in 2016, the old unused for 26 years tower base was removed using a crane, no road necessary. In other action, our Society hired a heavy lift helicopter to transport Saanich’s largest chipper from the summit parking lot to the middle of the park and later pick it up, no road necessary. There are lots of possibilities!

Our understanding is that the tower will be 40 metres high with a 6 metre high four bay dipole mounted on top of the tower, similar to the existing tower, making a combined height of 46 metres. This would be in contravention of the P9 Communication and Open Space zoning which limits the height to 42 metres. Our Society does not support any changes or exceptions to this P9 zone.

If the new tower were located next to the existing tower which is approximately 10 metres higher than the parking lot, the tower could be 10 metres shorter, the same height as the existing tower, a cost savings and significant aesthetics advantage . The cable routing would be easier and cheaper than the suggested parking lot location which requires a new hole in the building wall and a new trench leading to the tower base, which would also save more money.

What really concerns us.

1. The better summit site next to the existing tower was ruled out by the incorrect necessity for a new access road from the parking lot to the east summit.
2. Any proposed parking lot potential sites were based on a 6 metre building location error.
3. Any proposed parking lot potential sites, because of the building location error, would likely remove much of the already limited parking.
4. Any parking lot location is 10 metres lower than the current location, hence requires a 10 metre higher tower. This exceeds the P9 zone restriction.
5. In this pristine natural park, overall aesthetics is an essential consideration, but unfortunately site aesthetics does not appear to be even considered.

The PKOLS-Mount Douglas Conservancy therefore requests the summit location just south of the existing tower be reevaluated through collaboration and consultation, and an open discussion with our Society. Thank you.

Saanich is planning to erect a taller tower well into the current parking lot. This is to replace the tower you see on the left. The image below, drawn to scale, would show the tower dominating the approach, blocking multiple parking spots, and interfering with the approach to the view platform. In addition, moving the tower down from its current spot would mean it would have to be considerably more significant than the current tower. Aesthetically, it would create a worse blot on the pristine natural park than the current tower, which is sequestered behind a blind of trees. Replacing the tower next to the existing tower would mean a smaller tower, which would be much cheaper.

Currently, there is no public consultation with interested groups and much of the information being offered in the newspaper by Saanich is inaccurate. Given that this is the largest protected natural park in Saanich, public consultation is essential.

Protecting designated natural park areas from cell tower protrusions is an issue across Canada. In the Niagra Escarpment Plan the following protections are in place, these are similar to what Saanich Council has put in place for the existing tower.

The role of the Niagara Escarpment Commission (NEC) is to uphold the purpose of the
Niagara Escarpment Plan, which is to maintain the Niagara Escarpment and lands in its
vicinity substantially as a continuous natural environment, and to ensure that only such
development occurs as is compatible with that natural environment. The objectives of
the Plan include maintaining and enhancing the open landscape character of the
Niagara Escarpment by preserving the natural scenery, and protecting unique
ecological and historic areas. In order to fulfil these objectives, the NEC must assess
the visual and environmental impact of any development proposal within the Niagara
Escarpment Plan (NEP) Area.
Given the prominence of radiocommunication towers and antennas on the landscape,
the NEC expects a proponent to take all reasonable steps to avoid the NEP Area.
Where this is not possible, the proponent should minimize the visual impacts on the
Escarpment’s attractive features, scenery.

We will send updates as we receive more information using our membership lists.

For full view click here: Dogs-as-agents-of-disturbance-Michael-A.-Weston-and-Theodore-Stankowich

The Salish Sea archipelago, in which the Saanich Peninsula is included, is an enormously biodiverse region that supports unique mega flora with diverse topographies and microclimates. Throughout this unique ecological zone, there are populations of rare species that vary from area to area.

The following article in the Rain Coast Conservation Foundation talks about how, for both Washington State and BC, the Olympic Mountains shadow has created what they call a “profound amount of micro-habitat diversity in this area.” In the San Juan Islands alone, with only 0.26% of the landmass of Washington, it supports 30% of the native plant species. The same is true of the British Columbia side of the border.

The article speaks to the need, in times of our climate devolution, how important it is to protect this area’s species from extinction.

In June of this year, the Environmental Protection Tribunal of Canada clarified an issue of dogs running at large within a migratory bird sanctuary. An individual was fined for having their dog off-leash in Cadboro Bay, which is in the Migratory Bird Sanctuary. The claimant argued that the dog had not harmed anything. The tribunal found this argument had no merit and upheld the finding. This is backed by multiple studies indicating migratory birds have a severe response when dogs are within 100m, whether on or off-leash. As a consequence of this response, they often fail to nest and sometimes burn so much energy in avoiding the danger that they abandon their nest. The outcome of dogs within migratory bird sanctuaries is almost always the plummeting of species within the area.