Immediately after their first site visit, without knowing the extent of new trails and without receiving all relevant information (not provided until Oct. 25, 2021), key NPCA staff appeared to have essentially approved the permit, on Oct 4 and 5, 2021. Then on October 18, 2021, this approval was given:
NPCA Planning Ecologist:
“NPCA staff have reviewed the information provided in the Works Memo, Site Plan, and Decew Natural Areas Report in conjunction with a site visit completed October 4, 2021 and are satisfied that the proposed works will not have a negative impact on the ecological function of the work area.”
The information that was provided was outdated, incomplete and misleading. In addition, we have no official information about that first site visit. Where was it located? Who was in attendance?
1.0 Regarding the Works Memo:
A letter from the Games on Oct 7, 2021 stated that the Games had a license agreement with OPG for this work: “This work includes the repair or replacement of existing trail features (such as minor bridges), where necessary additional trail features (such as minor bridges to avoid wet areas, trimming & maintenance along existing trails, removal of garbage and debris, and trail grooming for user safety”).
That description of “the work” was incomplete and misleading and the Games only applied for a work permit from the NPCA after more than 4 months of work on the trails. The description does not mention the many new trails, the new bridges and ramps opening up untouched areas on the slopes, the construction of new mountain bike features and the alteration of natural features. It does not mention the cutting of tree roots or removal of many saplings and seedlings, or the deep bench cutting, the removal of significant amounts of soil, moss and other groundcover. It does not mention the conversion of wildlife paths into racing track.
2.0 Regarding The Site Plan:
A Project Description was provided to NPCA by the Games as follows:
” Phase One consists of clearing and clean-up of most of the trails to be used for the Mountain Bike Course. These trails are identified in yellow (1,400 m. loop) and black (2,000 m. section) on Figure 1. Several features will also be installed along these trails. These features are identified in Figure 2 below and the locations where they will be installed are identified in Figure 1. This Phase One work is planned to take place between July 22, 2021 and August 31, 2022.
This description was incomplete and misleading and did not show the true extent of the racecourse or the extent of the use of the upper slopes of the ravine.
3.0 The DeCew Natural Areas Inventory Report (see here):
The area studied in the DeCew Report referenced above does NOT include most of the racecourse in the ravine (see map).
Although it appears that preliminary approval of the permit was essentially given by October 18, 2021, further information was required from the Games after an NPCA Regulations Officer walked the entire course with a local resident on October 20, 2022. This prompted a site visit on On October 25, 2021, that included (about) 14 non-NPCA individuals from the Games, NTMA, OPG and the City, including, based on what we were told, the Mayor of St. Catharines? Immediately following that final site visit, the Games provided NPCA with a memo and new mapping to identify the layout of the course and its features, and which parts were new or existing trails.
Some of the information in these documents is inaccurate. However, the Games did acknowledge that they were constructing new racing trails, including on wildlife paths. The Games needed to include wildlife paths because so much of the area for the racecourse in the ravine is lacking in human trails. However, the conversion of wildlife paths into racing trails, by definition, results in a negative impact to ecological function.
Many of the wildlife paths in this ravine are part of wildlife corridors that connect the ravine with other parts of the Twelve Mile Creek and the Niagara Escarpment. The importance of wildlife corridors and valleyland biodiversity are both noted by NPCA in its Policy Document (section 6.1.3):
“It is also important to recognize that valleylands have important ecological functions. Some valleylands connect natural areas over large distances, providing corridors for terrestrial, aquatic and avian species. Valleylands can also promote biodiversity, as they have the ability to support a diverse range of habitats resulting from microclimate variations. Accordingly, the policy framework for regulating development in and near valleylands considers aspects related to the erosion hazard and also potential for adverse impacts on ecological features and functions associated with the valleyland (in these instances, the policies refer to the conservation of land).”
Throughout the approval process, the NPCA continued to refer to the Natural Areas Inventory study even though it did not cover most of the racecourse in the ravine. In addition, at no point did they refer to the important new information that new trails were built and that wildlife paths were considered existing trails. No further studies were done.
We believe that the NPCA conclusions on ecological impacts were premature, and not well founded. NPCA staff did not have sufficient information to make any conclusions regarding ecological function