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R.G. (Bob) Holtby, MSc, PAg. Principal

An Opinion on an Application for Non- Use on Lands within the Agricultural Land Reserve

Client: BK C&D Enterprise Ltd. Date: June 5, 2018

2533 Copper Ridge Drive, West Kelowna, BC, V4T 2X6, Phone: 250-707-4664, Cell: 250-804-1798, email: [email protected]

1.0 Introduction BK C&D Enterprise Ltd. owns three lots south of Revelstoke that they wish to develop for food production, a learning centre, nature interpretation centre and a wellness program. The lands are shown in Figure 1. Given a mix of farm and non-farm uses, the application is to allow the non-farm uses within the ALR. The applicants are considering consolidating the three parcels into one. Figure 1: Aerial View of Subject Parcels

Subject Parcels

The property descriptions are:  Lot 1 Section 14 Township 23 Range 2 West of the 6th Meridian Kootenay District Plan Nep19478; PID 017-455-081  Lot A Section 14 Township 23 Range 2 West of the 6th Meridian Kootenay District Plan 7485; PID 013-876-147  Lot 2 Section 14 Township 23 Range 2 West of the 6th Meridian Kootenay District Plan 7029; PID 014-246-546 An Opinion on an Application for Non-Farm Use Page 2 BK C&D Enterprises Ltd.

2.0 The Plan The applicants propose the following uses of the property as outlined in their Master Plan:1 With reference to the Williamson Lake Conceptual Master Plan Key, a diversity of amenities, activities and building types have been planned for uses that are permitted on lands designated as Agricultural Land Reserve. Three key themes of farm to table food production, a learning center and a wellness program define the sub-neighborhoods of this 26 acre site. Hydroponic / Aquaponic + Complex: The 'Farm to Table’ food production facility is accommodated in a hydroponic and attached aquaponic fish farm that will operate year-round. An outdoor garden is located adjacent the greenhouse for additional production during non- winter months. The site has been partially cleared of forest cover and the complex is to be designed as a landmark gateway building that is located adjacent to the main entrance off Airport Way to the west. Food produced from the aquaponic / hydroponic facility and adjacent seasonal garden will be consumed in the dining facilities that will support on-site programs. Surplus food will be sold locally to restaurants and at the ‘’s Market’ and donated to the local food-bank. Organic waste from the operations will be composted and sold for topsoil. Fish will be transferred to the on-site ponds that front the wellness center to mature. The fish may then be sold to local restaurants and markets, sold to stock private ponds, or donated to stock Williamson Lake in conjunction with the Freshwater Fisheries Society of BC. The facility will be available to school districts for educational programs, volunteers with the local food security program (Revelstoke Food Initiative) and open to the general public for educational tours during scheduled hours. Central Parking: A parking lot is located on the site adjacent to the main access road and along Airport Way. The parking lot will serve visitors who may only spend a few hours on site and visitors who spend extended periods participating in the many programs that will be offered year-round. The parking area will have extensive areas of landscaping to serve as a buffer to the adjacent lands. These landscape buffers will also incorporate sufficient areas for snow dump. Learning and Adventure Skills Centre: The Learning and Adventure Skills Centre is located adjacent the site’s northern boundary and the access road to Williamson’s Lake Civic Park. The site is gently sloping to the north with a second growth forest cover that is dense enough to create a buffer from the surrounding land uses.

1 BK C&D Enterprises Ltd., Conceptual Master Plan Design Rationale

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Buildings and outdoor gathering areas will be sited to preserve as much forest cover as possible. The Learning and Adventure Skills Centre consists of buildings that will accommodate students in various programs, a building that provides seminar rooms with a central atrium space and a common building with dining and lounge facilities. These buildings will be one story in height with small footprints that create an intimate campus blended into the forest. The architecture will express natural materials such as wood and stone. Extensive areas of glass will create a ‘free flowing space’ between the interior of the buildings and the forest. Produce and Crafts Confectionary: A confectionary is located to the east of the learning center and fronts the Williamsons Lake Park access road and access road to the Learning and Adventure Skills Centre parking. The confectionary will sell fresh produce and crafts from Williamson’s Lake Greenhouse, and . The store will also have an outdoor deck on the southwest corner for the consumption of coffee, tea and deli-oriented goods. Lodge, Lodge Out-Cabins + Pool: A main lodge will provide accommodations for guests involved in special programs that are offered in addition to those offered by the Learning and Adventure Skills Centre. The Lodge is located adjacent to Williamson Lake on sloping land that is not suited for . In addition to sleeping rooms, the Lodge will provide meeting/conference rooms, dining facilities, and spa/fitness and recreation facilities such as a gym, treatment rooms, and a outdoor terraced pool. Freestanding cabins are located to the north of the Lodge to diversify accommodation and may be used for both programs related to the Lodge and/or the Learning and Adventure Skills Centre. The cabins are oriented to families and small groups and will be accessible by footpath only. The architecture of the Lodge and cabins will express a contemporary style with gently sloping gable roofs, natural materials and large areas of glass to capture short distance views to the adjacent forest, lake, and outdoor amenities, and long- distance views to the surrounding peaks and glaciers. The Lodge will feature a floor to ceiling glass atrium on the east and west elevations that enables guests to view the lake from the arrival area to the west. Beach House + Gazebo: A ‘beach house’ will be located near the shoreline fronting the beach and a floating gazebo and wharf will be located on Williamsons Lake to the Northeast of the Lodge. These facilities will be accessible year-round to all guests and to private groups for special functions. Wellness Program Facilities: In addition to spa and wellness facilities such as treatment rooms and hydrotherapy facilities that will be in the Lodge and accessible to guests and the

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general public, facilities dedicated for the exclusive use of the wellness program are located to the south and west of the Lodge. These facilities consist of a dining and lounge facility, a center for group activities such as yoga, group meetings and instruction and 12 small retreat-oriented cabins The dining and lounge building and the cabins are located on sloping lands that are not suitable for agricultural use. The 12 cabins will be elevated on stilts to further reduce the impact of the footprints upon the sloping site. The center for group activities will be located in a water feature that consists of a series of interconnected ponds to be created in the field below the cabins. The aquiculture ponds will be stocked with fish from the onsite facility to mature further prior to being sold to the market or used in stocking programs. Administration and Maintenance Centre: The existing farmhouse and shop will be retained and serve as a transition to the rural residential lands on the adjacent property to the southwest. The farmhouse will serve as an overall administration center for operations of the programs even though some administration spaces will be required in the Learning Centre, Aquaponics and complex and Lodge. The existing shop will be upgraded to serve as a structure for the storage and maintenance of equipment and machinery associated with all indoor and outdoor operations. Employee Accommodations: On-site accommodations for 30 employees will be provided in two, two story buildings to the north of the administration and maintenance center. This location adjacent Airport Way provides privacy for the employees from guests and visitors to the site. One building will accommodate 10 employees on each story, while the second building will accommodate another 10 employees on the upper level. The rooms will offer double and single occupancy and will be similar to those available at the Learning Centre. Cafeteria style dining facilities for all employees, a lounge, laundry, and storage will be provided on the ground level of the second building. The administration and maintenance center and employee accommodations will be buffered from visitors by trees that are part of a re- vegetation program that will include other areas of the site. The land use is shown in Figure 2. The Hydroponic/Aquaponic and Garden Complex will qualify for Farm Use. The balance of the land uses need to be approved for Non-Farm Uses.

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Figure 2: Master Plan for the Subject Parcels

3.0 Qualifications I am a licensed Agrologist and have been a full member of the B.C. Institute of Agrologists since 1971 (except 2001-2002). I am a graduate from the University of British Columbia with a Bachelor of Science degree in 1967, specializing in Agriculture Economics, and a Master of Science degree in 1972, specializing in Farm Management. My thesis for my Master’s degree was entitled Resource Allocation for the Median Peace River Farm in British Columbia I have been involved in the work of the Agricultural Land Commission since 1974 when the reserve boundaries were proclaimed. At that time, I was District Agriculturist for the British Columbia Ministry of Agriculture in Prince George. In October 1978 I entered private practice and have provided professional opinions for clients who have sought amendments to the Agricultural Land Reserve boundaries, subdivision within the ALR, or who have needed assistance in compliance with requests from the Commission. I have also written and spoken of the need to address the unintended consequences of the provincial land use policy. All agricultural assessments, whether they are for feasibility or management purposes, start with the soils. Past that point one needs an understanding of science, and farm management to properly assess the farming potential of any site. I have demonstrated that understanding throughout my career.

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During my years in both public and private practice, Courts and Review Boards have accepted me as an expert regarding farming practices in British Columbia. Consequently, I feel qualified to provide an assessment of a proposal under the Agricultural Land Commission Act. My qualifications and experience allow me to comment on the value of agricultural land and the practices of farming on that land. While not formally trained in , I have been exposed to the principles of that discipline through short courses, field trips, and by accompanying pedologists during soils assessments. Consequently, I believe I am qualified to comment on the two main purposes of the Agricultural Land Commission. That is: to preserve agricultural land, and to encourage farming on agricultural land in collaboration with other communities of interest. I am currently a member of the Environmental Appeal Board and the Forest Appeals Commission. Following these appointments, I have received training in Administrative Law and the Rules of Natural Justice. Since the inception of the Application Portal, I have been identified in the application as the “Agent.” The reader should note that I do not act as an agent in the normal use of the term. That is, I have no fiduciary responsibility to the applicant. Section 3 of the Code of Ethics of the BC Institute of Agrologists includes the paragraph: • ensure that they provide an objective expert opinion and not an opinion that advocates for their client or employer or a particular partisan position. Given the complexity of the Portal, it is more expeditious for me to enter the data and forward correspondence than to expect the applicants to learn the procedure for what may be a one time process. I have requested that the Commission use the term “Consultant” rather than “Agent” as it more accurately describes the work performed. Given the refusal to amend the title, I am content in the understanding that I am acting in concert with the requirements of my profession whatever term is used. 4.0 Agricultural Capability of Subject Parcel The historical classification of the subject parcel is Class 2 limited by topography both unimproved (that is without ) and improved with irrigation. This classification is shown in Figure 3. As a review of this classification, Associated Environmental Consultants Ltd. was engaged by the applicant to conduct a formal survey and reclassification. The report, entitled “Agricultural Capability Assessment, Williamson Lake Retreat, Revelstoke, BC,” is attached to the application. The revised capability classifications are shown in Figure 4.

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Figure 3: Published Soil Classification of Subject Parcel

Subject Parcel

The findings are summarized as follows:2 The existing capability mapping indicates a rating of 100% Class 2T … mirroring the mapped soil distribution. The revised ratings are based on soil moisture limitations due to climate and soil texture (3A), climate limitations specific to freezing during the growing season (3C, subclass F) and subsoil stoniness in the homestead area (5P) and 20 to 50% in the subsoil in pockets of the forested area (4P, improved to 3P). The homestead and forested areas are reclassified to have an unimproved rating of 5PA (20%), 4PA (40%), and 3AC (40%) … The revised improved rating for the forested and homestead areas is 20% 5PA, 40% 3PA, and 40% 3AC. The hay fields are limited to 3AC.

2 Associated Environmental, Agricultural Capability Assessment, Williamson Lake Retreat, Revelstoke, BC, Page 11.

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Figure 4: Revised Capability Classifications for Subject Parcel3

When addressing agricultural suitability, the Report states:4 Overall, the property has relatively shallow topsoil for production (an average of 21 cm), underlain by rapidly draining material, which is gravelly in the forested and homestead areas, resulting in a low available water storage capacity and soil moisture deficit. In the forested and homestead areas, these limitations and freezing temperatures in the growing season reduce the likelihood of converting the forested and homestead areas to viable agricultural production. The above conclusion reflects the warning by the late G.G. Runka, P.Ag. in his 1973 monograph:5

3 Figure 4-1, Revised Capability, Ibid., Page 9 4 Ibid., Page 11

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Please remember that the agriculture capability classifications take into account the range of possible, and not productivity (i.e. yield/acre) of any crop. The conclusion of the report states:6 To put the forested area in production (59% of the property) would require extensive labour. Furthermore, it is not an area capable of high production over the long-term because the rapidly draining, sandy and gravelly subsoils with an average topsoil layer of 21 cm. to remove the forest and put this area into production may not be an economically viable option. The homestead area (20% of the property) could be used for agricultural production because the forest has been cleared, although crop types will be limited by soil moisture and climate. The proposal to use a portion of the property for food production will increase current agricultural production of suitable lands on the property. Education of the community (i.e. retreat attendees and school groups) about agricultural production (including seasonable produce, aquaculture and ) is an added benefit to the agricultural industry of the area. We suggest the proposed non-farm use be limited to areas of low suitability on the property (i.e. forested and/or homestead areas that are gravelly) to maintain maximum area of agriculturally suitable land. The plan of the applicants is consistent with these recommendations. The lower hay field area is proposed for the aquaculture ponds. I attended the onsite inspection conducted by Melanie Piorecky, P.Ag. on behalf Associated Engineering. I concur with her findings and conclusions. 5.0 Summary and Conclusions The purpose of the Agricultural Land Commission and the Reserve, as found in Section 6 of the Agricultural Land Commission Act is to: (a) to preserve agricultural land; (b) to encourage farming on agricultural land in collaboration with other communities of interest; The application proposes introducing non soil based farming (greenhouses, veritcal gardens, aquaculture ponds) into the less productive areas of the parcel and to use the higher rated lands for aquaculture ponds. As the Associated Engineering report suggests, there is a benefit to agriculture in the area by the educational aspects of the Centre. Much of the applicants proposed land uses are covered as permitted uses. Table 1 summarizes my understanding of the proposed uses against the farm and non-farm uses as listed in the Agricultural Land Reserve Use, Subdivision and Procedure Regulation.

5 G.G. Runka, P.Ag., Methodology, Land Capability for Agriculture, B.C. Land Inventory [CLI], Soil Survey Division, B.C. Department of Agriculture, Kelowna, B.C., January, 1973 6 Associated Engineering, Op. Cit., Page 12

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Land Use Allowed? Permitted Size Hydroponic/Aquaponic + Garden Farm Use No limit Complex Parking Section 2(3) Regs Section 3(5) No limit Regs Learning and Adventure Skills Agri-tourism; Section 3(1)(i) 100 m2/parcel Centre Regs Produce and Crafts Confectionary Section 2(2)(a) 300 m2

Lodge, Lodge Out-Cabins + Pool Needs Non-Farm Use Permit; 10 Dwelling Agri-tourism Units Beach House + Gazebo Needs Non-Farm Use Permit

Wellness Program Facilities Needs Non-Farm Use Permit

Administration and Maintenance Needs Non-Farm Use Permit; Centre Farm Use for Shop

Employee Accommodations Needs Non-Farm Use Permit

If the land were to be cleared and developed into agriculture as it is, its highest and best use would be forage crops. No owner of this property has made this development decision given the high cost of development against the low return. The applicants have proposed a comprehensive development plan that not only includes intensive agricultural development but includes programs to extend information on the intensive development. In my opinion, the proposal moves agricultural development in the Revelstoke area to a new, higher level and provides educational opportunities related to new advances in modern farming/greenhouse technologies. Most of the land use proposals leave the low arable land intact while developing other lands for intensive agricultural development. I remain available to discuss my findings and opinions in this report. Respectfully submitted,

R.G. (Bob) Holtby, P.Ag. June 5, 2018