Rezoning of Land for Proposed Residential Subdivision Palm Cove on North West Shore of Sylvan Lake

Summer Village of Sunbreaker Cove
c/o Summer Village Office
90B Hewlett Park Landing
Sylvan Lake, Alberta
T4S 1W2
November 25, 2010

Reeve Wigmore and Council
Lacombe County
R.R. #3
Lacombe, AB
T4L 2N3

Dear Reeve and Councilors:

Re:  Bylaw No. 1128/10 Rezoning of Land for Proposed Residential Subdivision Palm Cove on North West Shore of Sylvan Lake

First of all, I would like to thank the County of Lacombe for providing this forum which allows the public to make submissions to you.  In my few short months as Mayor of the Summer Village of Sunbreaker Cove, this will be my second such Public Hearing submission.  As with the first, this submission has the full support of Sunbreaker Cove Council.

I have read the Palm Cove Concept Plan prepared by Qualico Communities and their Consultants, and I attended the Public Open House regarding this proposal held in Sylvan Lake on August 28, 2010.  In addition, over the last few months I have developed some familiarity with:

  1. The Sylvan Lake Management Plan:  2000 Update (SLMP), and
  2. The Sylvan Lake Public Access Study – Findings and Recommendations (Third Draft) dated January 20, 2003, and
  3. Lacombe County’s Draft Sylvan Lake Area Structure Plan (ASP) dated June 18, 2010.

As most of you are aware, the Summer Village of Sunbreaker Cove is one of the eight municipalities within the province of Alberta with some part of its municipal boundaries on the shoreline of Sylvan Lake.  Consequently, our community has a significant vested interest in any proposed developments that might impact the Sylvan Lake watershed.  By way of reference, our community is located immediately to the east of the eastern boundary of the proposed Palm Cove Development.  Our residents are understandingly concerned about the potential negative impact to the environment and the quality of life we currently enjoy.  They are concerned that much of what makes Sylvan Lake so special might be lost forever should this development be allowed to proceed.  It is based on these principles that we are making our submission.

The Palm Cove Concept Plan makes for very interesting reading.  The Qualico Communities team and their Consultants have been very thorough in their assessment of this area as a proposed site for future development.  It would be difficult if not impossible to find flaws in the science undertaken by their engineers, biologists, and planners.  In discussion with one of their biologists, I learned that site investigations were conducted in each of the four seasons, and for this, Stantec Consulting Ltd. should be commended.  However, we must recognize that their research, particularly pertaining to the environment, is really only a snapshot in time.

As the neighbouring community to this proposed development, and the community most likely to be adversely affected by this proposal, we have two major concerns.



With respect to environmental matters, our residents are deeply concerned about the ability of this very fragile area to sustain this type of development.  These concerns can be broadly categorized into 3 topics as follows:



Map 4 of the Sylvan Lake Management Plan 2000 Update which outlines the locations of ENVIRONMENTALLY SENSITIVE AREAS is attached for reference.  That map clearly illustrates that the northwest corner of Sylvan Lake (Palm Cove) and the extreme west end of Sylvan Lake as being a Key Fisheries Habitat.  The entire Palm Cove Concept Plan area is immediately adjacent to one of these Key Fisheries Habitats.

I believe it is important to remind COUNCIL of developments that have already been approved or are pending in the subject area in the northwest corner and west end of Sylvan Lake.

a) At the west end, two developments have already been approved.  Agricultural land has already been cleared for development and forest cover removed.  It appears that roads, and much of the related infrastructure are already in place.

b) I understand that a third development in this area is pending.

c) To the north of our Summer Village, there are plans in place for a 515 lot RV development referred to as the Skyy Country Development.

These developments will significantly increase boat and other RV traffic in this scientifically defined Key Fisheries Habitat area.  Undoubtedly, this Key Fisheries Habitat will be negatively impacted and possibly destroyed.  I don’t believe these are the long term plans for Sylvan Lake.



Once again, I refer to Map 4 of the Sylvan Lake Management Plan 2000 Update.  The area of the proposed Palm Cove development is located almost exactly over the horizontal hachures on this map depicting an ENVIRONMENTALLY SENSITIVE AREA as being Key Ungulate Habitat in Section 34-39-2 W5M.  I would also like to draw your attention to the fact that the horizontal hachures (Key Ungulate Habitat) abut directly to the blackened Key Fisheries Habitat.


I now refer you to Figure 5 of the ASP.  This figure illustrates some of the more significant Environmental Features of the Sylvan Lake watershed.  Figure 5 is quite similar to the previous Map 4 though it is a bit more difficult to recognize some of the depicted Environmental Features.  I have included this Figure in my submission for 2 purposes:

a) It places the proposed Palm Cove development area in perspective with other areas of the Sylvan Lake watershed.  I believe it is fairly obvious to anyone that the west end of Sylvan Lake, and in particular the northwest corner of the lake where the Palm Cove development is proposed are perhaps the most vulnerable to any development, and in particular to the scope of development contemplated in the Palm Cove Concept Plan.

b) The second purpose for using this Figure is to illustrate how in just 10 years the Key Ungulate Habitat area on the extreme west end has been altered with the removal of natural forest cover.  Obviously, the west end development that is occurring has already had a significant negative impact on one of the few remaining Key Ungulate Habitat areas in the watershed.  A simple comparison of the features of Map 4 with the features of Figure 5 illustrate this clearly.

The importance of natural forest cover to the health of the lake is not in doubt as has been stated many times in the SLMP and the ASP.  From my perspective, it is difficult if not impossible to justify the further removal of any natural forest cover particularly in this area of the Sylvan Lake watershed.



Please refer to Figure 4.3PUBLIC ACCESS SITES E & F of the Draft Sylvan Lake ASP.  Protective Notations (PNT) are located along virtually the entire shoreline of the proposed development area.  In addition, there are two onshore site areas designated as E & F.  These are what have been referred to in the Draft Sylvan Lake ASP as “Minor Public Access Site 2 (within ESA)”.


The ESA designation has the meaning Environmentally Sensitive Areas.  Further definition of Sites E & F according to the draft Sylvan Lake ASP follows:

1. Site E is within or adjacent to two different types of environmentally sensitive areas (as identified in the SLMP); key waterfowl habitat and key fisheries habitat.  Protective Notations (PNT) exist on the shoreline of this proposed public access site, as illustrated in Figure 4.3. The shoreline of Site E shall remain its current, natural state and shall not be altered.

2. Site F is within or adjacent to three different types of environmentally sensitive areas (as identified in the SLMP): key ungulate habitat, key waterfowl habitat and key fisheries habitat.  Protective Notations (PNT) exist on the shoreline of this proposed public access site, as illustrated in Figure 4.3.  Appropriate measures will need to be taken to mitigate the impacts on the said ESAs.  Furthermore, the shoreline of Site F shall remain in its current, natural state and shall not be altered.

These riparian zones, and the potential damage that could be incurred should the proposed Palm Cove development be allowed to proceed is our third major area of concern with respect to the likelihood of negative impact on the environment.

Though I am here today representing the residents of our community, I am also here for very personal reasons.  My family and I have been coming to Sylvan Lake for more than 30 years.  Earlier in this submission, I referred to the Stantec Consultants work as being done in a snapshot in time, albeit over all 4 seasons.  Here are a few of my observations based on 30 years.

i. Since the forested area on the west end has been disturbed, the fishing in that area of the lake has been very poor.  In my opinion, and I’m not a biologist, the Key Fisheries Habitat in this area has already been damaged.

ii. We no longer see deer and the occasional moose in this area of the watershed.

iii. The bald eagles that seemed to be regular guests in this area have not been around for 2 years.

iv. We no longer see osprey.

v. The pelicans who used to grace us with their presence at this end of the lake did not return this summer, at least we did not see them.

As a long term visitor to the lake, I sincerely hope that what I’ve personally witnessed over 30 years is a part of some long term cycle, which I would not claim to understand.  Put another way, I hope that the seemingly non-stop development that has occurred and is proposed has not already caused irreparable damage to what scientists have referred to in Map 4 as ENVIRONMENTALLY SENSITIVE AREAS.


The second major concern I have regarding the Palm Cove Concept Plan should perhaps be more aptly titled “Understanding the Politics of Development”, or “Confusion Surrounding Development Planning”.


As most of you are aware, I am relatively new to this process, having just been elected this past summer.  I’m still trying to understand the complete meanings of and differences for terms such as First, Second, and Third Readings, Public Hearings, IDPs, IPPs, ASPs, and Concept Plans to name a few.  More importantly, I don’t understand the relative rank or importance of these acronyms and how if at all they relate to what I understand to be integral to planning in Alberta, namely the Alberta Land Stewardship Act, and Land Use Framework or LUF.

Because of my lack of understanding and confusion, I feel a bit intimidated much like the fool trying to guess which shell the pea is under.  Let me try to explain.

On page 9 of the Palm Cove Concept Plan it states:

“Although the ASP is not yet a statutory planning document, this Concept Plan has been prepared with regard to all of the policies contained in the draft Area Structure Plan”.


This seems pretty straight forward.  All of the ASP policies are to be adopted.


Earlier in the Concept Plan, it refers to the SLMP as being “an integral part of the hierarchy of statutory planning documents” used in the preparation of the Palm Cove Concept Plan.  From my perspective, this is a good thing because I understand that the SLMP was initially developed by the 8 municipalities adjacent to the Sylvan Lake shoreline.  Agreement when achieved is a good thing.

In essence, it appears that both the SLMP and the ASP are to be key cornerstone documents, and comprise much of the foundation upon which the Concept Plan was developed.  Unfortunately, it appears that such is not the case which leads to my confusion, and my lack of understanding of the development process.  Here are two examples:


Much of the science referred to regarding the environment in the SLMP and the ASP describes the importance of natural tree cover or forested areas as being vital to the health of the lake.  One of the studies states that up to 90% of the drainage basin has already been cleared of forest cover and arguably as few as 1452 acres remain.

Exhibit 2 of the Palm Cove Concept Plan is an Aerial Photograph of the proposed development area, and Exhibit 3 defines some of the Physical Features of the same area.  Clearly, the majority of the Concept Plan area is forest cover or what Exhibit 3 refers to as Tree Cover.  Now with reference to Exhibit 9, it appears to me that the entire proposed initial stage of development (59 lots) is totally within the boundaries of what has been described as Tree Cover on Exhibit 3.

If you boil all of this down, it can be summarized as follows:

  • Tree cover and forested areas are essential to the health of the lake.
  • Up to 90% of original forest cover has been destroyed and only 1452 acres remain.
  • Lacombe County has developed an ASP which in part states … conservation of remaining forested areas around the lake is a priority of this ASP.
  • The Palm Cove Concept Plan proposes onshore development covering virtually all of the remaining forest cover in their approximate 320 acre parcel.

Frankly, I’m having a great deal of difficulty connecting the dots.  If we accept the science as fact and Lacombe County’s position regarding the ASP as being sincere, there is absolutely no way this Concept Plan should proceed as it essentially eliminates one entire area of what little forest cover remains.



At the top of page 8 of the Palm Cove Concept Plan, it states under Policy Directions:

“High priority will be given to the development of new public boat launch for lake users”


Figure 6 entitled Development Concept identifies approximately where this Boat Launch might be located.  Also identified shown on Figure 6 is the approximate location of a Public Beach.

Now I’d like to refer you back to Figure 4.3: Public Access Sites E & F as submitted with the ASPSites E & F have been defined in the ASP as Minor Public Access Sites 2 within Environmentally Sensitive Areas.

Some of the characteristics of Minor Public Access Sites 2 (within ESA) are as follows:

  • Natural edge along lake shore shall be retained (shoreline will not be altered)
  • This form of public lake access will not include boat launching (motorized boats), beach and beach/shoreline swimming area, permanent pier or dock, unrestricted access to the shoreline.

Once again, I’m not able to connect the dots, as it seems to me we have an ASP that says no boat launch and no beach and beach/shoreline swimming areas.  Yet still, we’re presented with a Concept Plan for one of the most environmentally sensitive areas in the entire Sylvan Lake watershed that conceptually provides for both of these features.  I don’t get it!

As referred to earlier, it appears that the SLMP and the ASP were to be integral to the Palm Cove Concept Plan.  However, it seems to me that rather than being integral to the plan that they have been completely ignored.

Thus, the Politics of Development is my second major concern with respect to this proposal. It appears to me that the majority of research and science accumulated in the Sylvan Lake watershed for many years has been totally disregarded once a developer came knocking.  I ask myself why? And I remain confused and frustrated.

Frankly, given the science that has been done in the entire Sylvan Lake watershed, and more recently in this area of the lake, I’d be both surprised and disappointed if either the federal or provincial government stewards responsible for environmental protection would allow this development to proceed.

In closing, I would like to make a couple more comments about what I’ve referred to above as the Politics of Development and the difficulties I’m having in understanding the process.  I understand that the Palm Cove Concept Plan received some number of readings in Council before the approval of their ASP.  I also understand that there are some who believe that this Concept Plan should be exempt from being developed in accordance with the ASP.  In my opinion, should this be true, it is a total abrogation of good governance.

The ASP is intended to be a model adopted by Lacombe County that is to guide future development of the Sylvan Lake watershed within the County’s boundaries.  I submit that not only should the County follow that model, it should embrace it.  To deviate from that model, and put the ASP on the shelf because of the timing of various Concept Plan readings in my opinion is both irresponsible and makes a mockery of the entire planning process.  It makes a layman like me question both the legitimacy and sincerity of any documents produced that pertain to development.

This new County Council has an opportunity to go beyond WHAT CAN BE DONE and move into the realm of WHAT SHOULD BE DONE, and I urge you to act responsibly.

Thank you again for your time this evening.

Respectfully submitted,

Bill Carr

Mayor, SV of Sunbreaker Cove



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