Some thoughts from a SOFT-CV member about a large new housing development at 2555 Cumberland Road
We write regarding the cumulative loss of forest cover in the Piercy Creek watershed that threatens this hydrologically sensitive area (HSA). The intense clearing of trees impacts aquifer health and water flow into creeks, exacerbating the drought and flooding that affect local salmon. Several months ago, a representative of SOFT spoke with Courtenay planner Mike Grimsrud about our concerns, including the proposed forest clearing and development at 2555 Cumberland Road.
We urge Council to coordinate with the adjoining Electoral Districts of the Comox Valley to conduct a meaningful study of the Piercy Creek watershed, before any further rezoning and development is considered for the area.
The Loss of Trees and the Degradation of Wetlands in the Piercy Creek watershed area:
· The long-term effects of tree clearing. What often appears, at first blush, to be significant tree retention often masks the death and continued removal of ‘unsafe’ trees within a few years. At 2555 Cumberland Road, for example, as much as 85% of the trees in border edges ‘retention’ areas (235 of the 276 trees identified) and ALL the mature trees in the retained northern and eastern five m. buffer borders would likely be lost in the proposed development. This huge long-term loss would continue to adversely affect the property wetlands and the wider Piercy Creek area.
· The loss of area trees could increase stormwater run-off, affecting the health of Piercy Creek and potentially leading to long-term problems for the City. As much as 26,784,000 litres of projected additional water could flow off the 2555 Cumberland Road development (as projected for a 100-year 24-hour storm event).
· The loss of wildlife corridors and connection to other habitats.
· The Need for a Holistic Area Plan for the Piercy Creek watershed. Have definitive species lists or planned wildlife corridors been identified for long-term planning for this Environmentally Sensitive Area (ESA)?
The long term effects of tree clearing
Long-term effects of area forest clearing are inevitable. For example, proposed development at 2555 Cumberland Road would remove a total of 9102 mature trees for the development areas, with 4806 mature trees retained. The arborist report notes, “An assessment was completed of the proposed forest edges that will be created once the development site is cleared ... The most stable trees have been identified for retention along the proposed forest edges. A complete inventory of these edge trees is provided in Appendix 1.” [1]
But Appendix 1 notes that trees of medium, low or nil value (224 in total) will either be removed, modified for wildlife, or likely to experience failure within 5 years (p. 63).
Thus, of the 276 trees identified in the ‘saved’ forest edge, 224 medium, low or nil trees would be removed, modified or likely to die in the next 5 years. Eleven more high value trees would be removed due to development – a total of 235 of the edge trees gone within five years, leaving only 41 trees standing– an 85% loss! Such widespread tree loss in the edges would have a profound effect on the wetlands.
In addition, further tree loss will occur as the report acknowledges that all of the mature trees in the northern and eastern 5 m. buffer borders must be removed (p. 26). How many weren’t documented. These losses appear to be in addition to the forest edge trees to be removed or likely to die (Appendix A).
Moreover, how would development affect the existing ‘no build’ 25 m tree border running along Comox Logging Road? Will the increased strain of higher winds and more storms due to climate change or water table changes affect these trees, sandwiched as they would be between Comox Logging Road and a new strip of housing? If the trees die, who would be responsible?
In total it’s probable that at least well over 9300 mature trees would be lost off the acreage. The narrow dimensions of some of the green corridors likely would exacerbate this problem. How would Courtenay’s 3:1 tree replacement ratio and tree removal fees be implemented and spent for 27,900 trees? Would the developer post a bond for tree maintenance for the next decade, or would that cost burden taxpayers? The report recommends consistent monitoring of trees, as well as possible irrigation, fertilizer and mulch.
The loss of area trees could increase stormwater run-off, affecting the health of Piercy Creek and potentially leading to long-term problems for the City. As much as 26,784,000 litres of projected additional water could flow off the 2555 Cumberland Road development (as projected for a 100-year 24-hour storm event).
At the proposed Cumberland Road site, for example, the runoff could affect the health of the wetlands proposed to be saved, with issues such as soil erosion and nutrient leaching. The rapid runoff of stormwater into the city’s infrastructure could prevent the slow infiltration of that water into the soil and later, into Piercy Creek or down into the aquifer. The document (Desktop Hydrogeological Assessment)[2] notes: “The model results show that the developed areas would increase peak runoff rates from 142 to 295 L/s for a 10-year 24-hour storm event and from 195 to 505 L/s for a 100-year 24-hour storm event. Peak runoff is estimated to occur approximately 1hr after the peak rainfall intensity during the design storm. Increased runoff will persist …up to 6 hours … A registered civil engineer should provide further analysis on how the planned rain gardens, bioswales, green spaces, watercourses, wetlands, and ditch will effectively manage the additional runoff …” (p 14)
On page 16, the report notes that a future design would assess whether the on-site wetlands could detain these additional stormwater flows. A series of control mechanisms –detention chambers, outlet structures, controlled spillways, etc., may be required, including a drastic proposal to inject ‘clean’ stormwater into underlying Aquifer #951.
If in a 10-year storm, 153 litres/second extra would be moving across this lot for 24 hours, (153 x 86,400 (seconds in 24 hours), it would mean 13,219,200 MORE litres, PLUS an undetermined amount of extra water for up to six hours afterword. Should this water fall in much less than 24 hours, it would be a significant strain on the infrastructure.
For the 100-year rain, it would be 310 litres per second or 26,784,000 (310 x 86,400) litres in 24 hours, PLUS an undetermined amount of runoff for six additional hours.
And this is without further clearing of any more trees in other parts of the Piercy Creek watershed, at a time when climate change is increasing both storm intensity and frequency. Would such drainage changes make already existing area neighbourhoods more prone to flooding, and would Courtenay City be liable?
The Global Facility for Disaster Reduction and Recovery (GFDRR) notes,
“ The most common misconception is that a 100-year flood will only occur once per century, but that is not true. There is a small probability that such an intense event could occur every year. If a 100-year flood happened last year, it can happen again before the next century, or even this year. It is also possible for such an event to not occur within a 100-year period. …As a recent example, the city of Houston, Texas, USA, has experienced 500-year floods three years in a row, including one caused by Hurricane Harvey, which has prompted a revision of the city’s zoning regulations to account for changes in the flood drainage basins around Houston.”[3]
As well, what are the effects of the wash of chemicals into these wetlands, including the infamous 6PPD-Q chemical leaching off tires? Will there be a ban in the development on pesticides, fertilizers, car wash, moss removers, etc., deposited on lawns, driveway and roads, washing into the wetlands or down the storm drain into Piercy Creek?
With perhaps well over a thousand people and their pets living in the new subdivision, how much protection would be afforded the conservation areas? Will dog walkers and pedestrians dump dog excrement and garbage, beat paths through protected areas and splash in the wetlands with flea collars leaching toxic ‘forever’ PFAS chemicals, while domestic cats hunt rapaciously?
The Need for an Holistic Area Plan for the Piercy Creek watershed
Before any more development occurs, there is a critical need for an area plan to produce the species and habitat data for such an environmentally sensitive area, and protect what remains of the wetlands and forested areas of the Piercy Creek watershed. In their letter to Council of February 25 2025 (REFERRAL-RZ000089-2555 CUMBERLAND RD) the Comox Valley Conservation Partnership (CVCP) called for a meaningful species list.
It is difficult to work for no net loss of habitat function without a full species report. The Cumberland Road proposal’s report notes the possibility of Western Screech Owl, a threatened species, on the property. Why would that not have been ascertained? Even without a species survey, the environmental report acknowledges that two provincially blue-listed species, northern red-legged frog and western toad, and four species of salamanders are likely living on the Cumberland Road site. (p. 40 Environmental). Northern Red-legged Frogs disperse up to five km from wetland into moist forest, and overwinter underground. (p 62). Where would they find that forest cover in the proposed development?
Plants - For example, at the 2555 Cumberland site, three ecological communities at risk as recognized by the BC Conservation Data Centre were recorded[4]. The CVCP has called for more accurate mapping of the trembling aspen sites on the site, some slated for destruction (p.28 Arborist report). In this Environmentally Sensitive Areas (ESA), surely all the stands of trembling aspen should be saved.
Birds - The documents notes the property provides rich habitat for an abundance of both resident and migratory birds (p 37), including ‘ high-value nesting areas for songbirds.” Yet despite this admission, “Bird surveys were not completed during this study and the site visit was conducted outside of the nesting season.”
The report also notes, “Potential impacts to bird species can be avoided by timing tree removals to be outside of the nesting season (March 1st – August 31st). There is an abundance of nesting habitat in adjacent natural areas and impacts to bird nesting habitat are anticipated to be minimal.” (p.56)
But care in saving a nest tree while occupied, then promptly logging it thereafter, means the nest tree won’t be there next year, thus permanently impacting the bird species. Moreover, the supposition that there are plenty of other trees ignores the fact that this development alone would permanently remove roughly 9300 trees from the Piercy Creek watershed. Indeed, when wildlife loses habitat, it is forced into already occupied territory, where it will either drive out the current occupant or be driven out, with an inevitable population decline.
Aquatic Species - The documents state, “… the overall impact of the proposed development to aquatic habitat is expected to be low because the majority of the on-site natural aquatic features will be preserved and protected.”[5]
But the CVCP has cast doubt on the delineation of the water features on this property, writing,
“Did the proponent use the USACE [Wetland Delineation]methodology? This is now the provincial standard for wetland delineation and tends to identify larger areas for protection. The methodology section in the Environmental Impact Assessment (EIA) is vague, making it unclear whether this more rigorous approach was used.”
Moreover, the environmental report noted, “In September 2025, “… The Province could not confirm support for the proposed stream protection approach because the report did not include the full RAPR assessment report.” (p 7).
If wetland 1 and 2 are proposed to be conserved, what is the plan for Wetlands 3 and 4? If watercourse 1 through 4 are to be protected, 5 and 6 are proposed to be filled and replaced by a roadside bioswale, what about watercourses 7-9, shown in earlier maps? (p 23, CVRD report). A roadside ditch, filled with garbage and chemical wash from the road and isolated by traffic that presents a danger to wildlife, is surely not compensation for a ditch in the middle of a forest filled with clean water. And what of the creatures now living in the watercourses, as they are filled? What of the creatures hibernating in the forest soil when construction begins?
(From CVRD Staff Report)
A compensation rates of 1:1 for watercourses ( p 55) is an outdated concept in an age of climate change and a provincial wetland loss of as much as 85% in urban areas. If we have two wetlands, and we save one to develop the other, we still lose a wetland, hardly ‘no net loss’. We note the strong objections of the MPWS and CVN to this inadequate rate of compensation. Increasingly, compensation rates are now a bare minimum of 2:1, usually 3:1, and only when there is absolutely no way to avoid the wetland destruction through re-design, etc. It could be argued that in the Piercy Creek watershed, with its myriad of supporting wetlands, the bare requirement for any development would be designing to save and ensure the health of all a property’s wetlands.
We are concerned that area development is severing wildlife corridors. For example, if development occurs on the 2555 Cumberland site, how would wildlife access nearby Capes Park? The proposed northern roads, primarily the one parallel to Comox Logging Road, would further inhibit wildlife from crossing into other wooded area still remaining, including the wetland diagonally across Comox Logging Road. Is this wetland threatened with future development?
Finally, we worry that this development is not following the Courtenay Urban Forest Strategy recommendations. A Courtenay staff report says 33% (4.1 ha of a 12.2 ha site) of the site is zoned for park or conservation, but this would include a children’s playground, swales running along a busy roadway and small groomed parks and walkways surrounded by housing – essentially landscaping.[6] The proponent states that 31% of the property would be preserved as natural habitat (https://www.2555cumberland.ca/
But when we consider the amount of that natural area that is open water in wetland, it means that substantially less than 31% of the property is remaining forested. Courtenay’s Urban Forest Strategy aims for 34-40% tree canopy. All development in the Piercy Creek watershed should conserve a minimum of 40% of tree cover. In an age of climate change and widespread habitat and biodiversity loss, minimum standards are no longer appropriate.
For Council to make informed decisions, we urge a delay to any further development approval in the Piercy Creek watershed until a comprehensive area plan, including meaningful species surveys and environmental features planning and protection, has been done.
Thank you for your kind attention to our concerns. We look forward to hearing from you.
Cc:
· Sacha O’Regan, Ecosystems Biologist, Ministry of Water, Land, and Resource Stewardship (WLRS)
· Aaron Purdy – RAPR Biologist, Aquatic Ecosystems Branch, WLRS
· Stephen Tessovitch – Fisheries and Oceans Canada (DFO)
· Comox Valley Conservation Partnership (CVCP)
· Comox Valley Nature (CVN)
[1] Arborist and Windthrow Likelihood Assessment Report, Diamond Head, 2026, p 22 and 27, 33
[2] Desktop Hydrogeological assessment
2555 Cumberland Road, Courtenay, BC
AE Project No. 4958, December 2025
[4] P. 43 Environmental Overview and Impact Assessment for
2555 Cumberland Road, Courtenay, BC, Diamond Head
[5] P. 4, Desktop Hydrogeological assessment
2555 Cumberland Road, Courtenay, BC
AE Project No. 4958, December 2025
[6] P. 3 - City staff report, Staff Report - March 25, 2026 Page 3 of 15 Zoning – Amendment Bylaw No. 3192 (2555 Cumberland Rd)
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