Pedon Environmental Consulting 46637 Montana Drive Chilliwack, BC V2P 6L9

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May 23, 2013 Ron Zaruk Norm-Ron Construction Ltd. 5880-268th Street Aldergrove, BC V4W 1V6 Dear Mr. Zaruk

Re: Non-compliant Fill Opinion Letter

Norm-Ron Construction Ltd. (Norm-Ron) retained Pedon Environmental Consulting (Pedon) to

prepare a letter concerning the addition of fill at 25528 and 25476 73rd Avenue, Langley, BC (the

Site). This letter reviews the conclusions in a report prepared by EvEco Consultants Ltd.1 (the

EvEco report) and provides a professional opinion concerning potential improvement to

agricultural capability that can be achieved by adding fill.

Site History and Project Overview

The Agricultural Land Commission (ALC) refused an application to place fill on the Site. In the

meantime, the Township of Langley (TOL) had permitted filling on the Site. The Site was prepared

to receive fill and some fill was imported to the Site before the project was stopped. Currently,

the Site is not receiving fill nor have the limitations identified in the EvEco Report been improved.

The fill proposal was to place 14 200 m³ of fill over a 2.1 ha fill footprint to alleviate topographic

and drainage limitations in order to facilitate using the site for horse pasture and a horse stable.

1 EvEco Consultants Ltd. 2010. Soils and Agricultural Assessment – Proposed Fill Site 25528 and 25476 73 Avenue, Langley, BC.

Non-compliant Fill Opinion Letter 13-108

Norm-Ron Construction Ltd. May 23, 2013

Page 2 of 4

Pedon Environmental Consulting

EvEvo Report Summary

The EvEco report documents the results of a detailed survey of Site soils and a determination of

the Land Capability for Agriculture of the property. EvEco correlated the soils on the property to

the Scat and Whatcom soil series and determined that the agricultural capability of the fill site

was 50% Class 4 with excess water and topographic limitations and 50% Class 3 with topographic

limitations. The improved agricultural capability for the site, assuming that fill placement

proceeded according to the recommendations, was Class 2, although no specific limitation was

identified.

The recommendations for placing fill were made with the intention of improving the identified

topographic and drainage limitations without introducing limitations associated with adding fill

unsuited for agriculture. A fill implementation plan was developed to guide fill placement at the

site while ensuring agricultural values were protected.

The EvEco report describes regional drainage in the form of creeks and drainage ditches.

Recommendations for diverting water adhere to Fisheries and Oceans Canada (DFO) requests to

protect West Creek to the south of the fill site. The report lacks an assessment of potential

negative effects that fill placement may have on regional hydrology.

Soil Management Recommendations

General soil management recommendations2 were developed for Fraser Valley soils to provide

guidelines for improving common limitations to agriculture. The following section summarizes

the recommendations for Scat and Whatcom soils, the soils that EvEco described at the Site.

Scat soils are poorly drained, slowly pervious, and have compacted subsurface layers that create

perched watertables. Agricultural use is limited by poor drainage and the compact subsoil.

Management inputs recommended to alleviate these limitations include installing subsurface soil

drains, routine subsoiling to increase rooting depth and increase the effectiveness of the

subsurface drains, and excavation to provide a drainage outlet.

2 Bertrand et al., 1991. Soil Management Handbook for the Lower Fraser Valley. BC Ministry of Agriculture, Fisheries, and Food.

Non-compliant Fill Opinion Letter 13-108

Norm-Ron Construction Ltd. May 23, 2013

Page 3 of 4

Pedon Environmental Consulting

Whatcom soils develop from a medium-textured eolian veneer that overlies dense glaciomarine

sediments. Since Whatcom soils develop from two parent materials, drainage properties are

inconsistent with depth. The surface, in eolian sediments, is moderately well- to well-drained and

the subsurface, in glaciomarine sediments, is poorly drained. The limitations to agricultural use

include a shallow rooting zone where the eolian sediments are thin and erosion in places where

slope gradients are steeper than 5%. Management inputs recommended for theses soils include

implementing erosion control practices (i.e., cover cropping), installing subsurface soil drains,

irrigations, and subsoiling.

Since adding fill is not a commonly accepted agricultural management practice it is not

recommended as a management input for improving drainage or topographic limitations.

However, adding fill is a method can improve both topographic and drainage limitations. It should

be considered as a reasonable option at this Site since filling, if done correctly, will address both

identified agricultural limitations.

Opinion

The pairing of topographic and drainage limitations is difficult to improve. Levelling the land using

in situ soil will not address the drainage limitation caused by the impervious glaciomarine parent

material but it will alleviate topographic constraints. Installing subsurface soil drains will not be

effective for improving drainage limitations since it will be difficult to construct outlets with

sufficient freeboard for gravity drains. Creating a network of drainage ditches to divert runoff will

be ineffective since the undulating microtopography is complex and it is likely that small areas

would not be easily connected to ditches.

There is no generally accepted improvement for topographic limitations except land levelling or

adding fill. In this case, if the site is levelled, the dense subsoil will remain and will create a

perched water table leading to poor drainage conditions and consequent restricted agricultural

use.

Adding fill, providing it is done according to the EvEco plan, should improve both topographic and

drainage limitations. Elevating the surface will increase the rooting depth which will reduce

drainage limitations. The fill will be graded across the footprint to create a simple, gentle slope

that does not present a limitation to agriculture. In addition, the gentle slope will act to direct

surface runoff away from agricultural areas of the Site, further improving drainage.