TSS’s Position on the Proposed Lifting of the NSSWD Moratorium on New Connections

Maxwell Lake - North salt Spring Water District Watershed - Salt Spring Island

Transition Salt Spring has been consulting with the North Salt Spring Water District and the Island Trust regarding the NSSWD’s proposal to lift its water moratorium policy. Transition Salt Spring has offered conditional support of this proposal.

Our position as posted on the Salt Spring Exchange on October 22, 2024 and our letter to the NSSWD with recommendations are detailed below.

Transition Salt Spring Supports Lifting of Water Moratorium


Walk through Ganges any night, and you’ll find a quiet, largely empty village. The low population in our village core is puzzling, given that compact towns promote efficient public infrastructure and reduce emissions.


The scattered rural development we see in our own community, by comparison, results in fewer trees to lower summer temperatures and soak up carbon, and higher carbon emissions due to the transportation required to move people and goods back and forth from those our scattered dwellings.

Additionally, behind locations like Country Grocer, you’ll see fifth-wheel RVs occupied by island workers unable to find suitable housing nearby. This reflects our community’s failure to plan for diverse housing options.


The moratorium imposed by North Salt Spring Waterworks District (NSSWD) in 2014 was initially justified due to concerns about unsustainable water withdrawals from St. Mary Lake. However, it has hindered the development of compact, environmentally friendly multifamily units in areas close to jobs and services, exacerbating our housing crisis and promoting inefficient rural growth.


We now have a crucial opportunity to rectify these issues by supporting NSSWD’s proposal to lift the moratorium, potentially allowing up to 300 multifamily units in their service area, including Ganges. Transition Salt Spring is happy to support this proposed lifting of the moratorium. This could revitalize our village core, fostering a lively, diverse, and equitable community where people from various backgrounds can live and work in a walkable environment.


Transition Salt Spring’s support is conditional. The Islands Trust is key, as it governs land use and zoning decisions. The Trust must implement policies to ensure the housing our community urgently needs can be developed in the village core.


The current review of the Local Trust Committee’s Official Community Plan offers a chance to prioritize housing affordability and climate action. These goals can coexist if approached thoughtfully.


Our stance on lifting the moratorium may shift based on two factors: the Islands Trust’s directives regarding the new connections and NSSWD’s response to incoming applications. We will look for a comprehensive monitoring plan, a multi-year water conservation strategy, and enhanced climate modeling to address extreme weather risks, as detailed in our letter to NSSWD.


We anticipate a public dialogue with NSSWD and the Trust that balances housing equity, ecosystem protection, and climate action.


Transition Salt Spring is opting for a qualified yes, having invested significant volunteer hours in research and discussion. We appreciate the NSSWD board’s thoughtful decision-making process. Their approach is cautious and incremental, ensuring there will be opportunities to adapt as circumstances evolve.


NSSWD’s careful monitoring will allow for adjustments as needed. We have outlined reservations and recommendations in a detailed letter, which, with the Islands Trust’s support, could strengthen the NSSWD proposal for well-situated connections.


By following this cautious path, we can achieve important housing and environmental goals. We look forward to collaborating with stakeholders, NSSWD, and the Islands Trust in the coming months to ensure the best outcomes.

Our letter to the NSSWD and the details of the conditions are detailed below.

Transition Salt Spring’s Position on Lifting the Moratorium

Transition Salt Spring (TSS) believes that equitable, affordable housing can be responsibly developed on Salt Spring while protecting our most vulnerable natural resources. Based on the scientific research done by NSSWD, we support their proposal to make new water connections available on the existing Maxwell Lake system. After this proposal is approved, it will be incumbent on the Islands Trust to prioritise the limited number of available new connections for the types of housing most urgently needed in our village cores to build a more resilient and diverse community. It will be further incumbent on NSSWD to continue to stress test its models on an ongoing basis using data that more accurately reflects local conditions and likely climate change impacts, while fully integrating water conservation strategies into its business model.

Questions & Recommendations

Following are the final revised questions TSS asked in our meeting with you on October 11th.

The questions are followed by recommendations. 

1. IPCC Scenarios

What was the rationale for choosing SSP2 (medium) and SSP5 (very high)? And did KWL account for any uncertainty or confidence levels associated with the scenario chosen, and how did that influence their conclusions?  SSP2 is regarded as representing business as usual and indications are that emissions are already on track to well exceed this scenario and is therefore not a credible scenario. While SSP5 (very high) may seem extreme it could also offer NSSWD a prudent upper level benchmark to stress test the consultant’s conclusions thereby inspiring greater professional and public confidence that the District has covered all its bases.  

We would also like to note that IPCC scenarios are well known to be a challenging mix of current science and political consensus. As such they consistently provide low ball scenarios which do not align with actual events. What’s more, the IPCC continues to ignore the potential for nonlinear change and feedback loops. The failure to do so adds to the inaccuracy of the forecasts to date and heightens risks for decision makers the world over who are basing large infrastructure spends on overly conservative climate models. As a final note, models tend to employ averages and do not account for extreme events.  In the case of NSSWD this likely means extreme heat events contributing to algae blooms, or extreme rain events contributing to turbidity and sedimentation.

Recommendation i: We greatly appreciate the thoroughness of the consultant’s work, though TSS recommends adopting SSP3 and SSP5 as the most prudent models for modelling surface water sufficiency rather than SSP2 and 5. For reasons elaborated above, SSP2 is no longer a credible or realistic baseline.  We further recommend against blending these two models in the analysis since a prudent forecast should account for and illustrate potential extremes in each of the SSPs.  Ideally, TSS would like to see a model run with only the SSP5 for comparison.

Recommendation ii: We would encourage NSSWD to account for extreme events in its modelling since there is a high likelihood of these outlier events which do not get adequately accounted for if the SSP models are blended. 

2. Conservation Potential Study

Given the high degree of climate model variability – successive generations of IPCC reports are producing increasingly dire forecasts as we fail to act and as the models improve – it becomes more important than ever for NSSWD to follow the lead of many jurisdictions (both neighbouring and not) in developing a conservation strategy which can serve as a buffer for known IPCC data modelling issues by quantifying the potential for demand side management policies, programs and price signals to contribute to supply availability for new connections. 

Recommendation: TSS recommends that the NSSWD develop a conservation strategy starting in 2025 which includes rates, rebates, education and other instruments to bring demand down, particularly among its top conservation-resistant users.  We would also strongly encourage NSSWD to integrate conservation potential analyses into supply availability modelling. 

3. Weather Data Sources

We noted that the study relies on Saanichton and James Island weather data and some local data from and between St. Mary Lake and Lake Maxwell.  Can you explain the methodology used in a bit more detail to help us understand the assessment that additional supply is available?  Are there any assumptions KWL made about regional climate impacts on precipitation patterns and water availability specific to Salt Spring Island? In reviewing the study, we wondered if the Vancouver Island data adequately accounts for local factors like elevation and micro climate at the elevation of Maxwell, for example. And we may have missed this, but can you describe the local weather datasets in terms of years gathered, monitoring frequency, etc.?  

Recommendation: Because of the known microclimates of higher elevation areas like the Maxwell Creek watershed, we recommend checking the modelling used in the draft report against more specific data. To help with this task, TSS would like to offer three years of weather data from this watershed for use by KWL to validate their results.

4. Rippon and Larmour Creek Data

Can you explain what is in the inflow data noted in the consultant’s report?  For example, period(s) that the data captures, frequency of collection, and methodology used.  It wasn’t clear from the study how the assessment of supply from Larmour and Rippon Creeks were calculated though it does note that “one water-year of reliable data… available for Rippon Creek”.  If it would be useful, TSS has three years of flow data that we would be happy to share that could be used to validate findings.  Mark Boysen volunteered to check with KWL to better understand the datasets used for this modelling.

Recommendation: We recommend that additional data be used, such as the three years of flow data from TSS, to validate findings about Creek water volume contributions, subject to confirmation about which datasets have already been integrated. 

5. Water Quality Assessment

We did not note any information on water quality variability risks and a related management plan.  Increasingly, extreme rainfall events are forecast for the region meaning that water quality entering Maxwell, for example, may be significantly degraded in quality at times of peak flow.  We were wondering if the presence of the proposed Maxwell WTP makes turbidity inflow irrelevant to potable water quality. 

Recommendation: While the Maxwell WTP seems likely to have the capacity to deal with large inflows of sediment, turbidity and other contaminants, there needs to be a plan to manage downstream turbidity outflows from where Lake Maxwell empties into Maxwell Creek down to saltwater habitats east of Erskine Point.  This points to the ongoing value of undertaking modest nature-based improvements that are being undertaken by TSS through CARL. Further, since the KML report did not integrate significant content on water quality, it will be important to identify mitigation strategies given the potential for extreme weather events creating substantial contaminated inflows and outflows.  It is also worth pointing out that extreme events may lead to increased costs to dewatering filtered sludge from the Maxwell WTP and that it could be beneficial to use low cost upstream methods like those recommended by CARL to help mitigate heavy flows during extreme weather events.

6. Additional Supply Finding

Given the finding from the staff report indicating a forecasted increased supply in Lake Maxwell since the moratorium was put in place 10 years ago, what proportion of the increased supply is attributable to each of the following stated determinants/variables: an updated climate model, updated accuracy of flawed historical data and infrastructure improvements.

Recommendation: If practical, can KWL run the analysis required to show the percentage attribution of each of the three stated factors that are driving an increase in forecasted water supply from Lake Mt. Maxwell in order to reveal the sensitivity of the historical and current model.