Environmental Study – Plants and Wildlife
NPCA did not do any environmental studies of the racecourse area. That should be stated upfront and made clear.
Moreover, on September 10, 2021, Ontario Power Generation (OPG) stated in response to our community concerns that “the Games are permitted to make improvements to existing trails to improve safety for cyclists and recreational users.” An environmental analysis or “Environmental Assessment” has not been completed by OPG specific to this area of Twelve Mile Creek”.
This was shared with NPCA staff in October, 2021.
Despite this fact, during our presentation to the NPCA Board on November 19, 2021 an NPCA staff person summarized the findings of NPCA during the permit review, that included multiple references to the DeCEW FALLS GENERATING STATION NATURAL AREAS UPDATE 2019 report.
HOWEVER, it is very important to note that this study did NOT include most of the racecourse area in the ravine. It does include one small area of established, existing trails near Lockhart Drive. There is also a reference in the study to one map that contains the remainder of the area but this is old and limited data used for location mapping and is not the area studied. See attached Map showing the area of this study in relation to the area where the racecourse has been constructed.
To view the actual Map as published in the report itself, pg. 7, with our note showing where the racecourse is being built in relation to the study area — Click here
Here is one portion of the conversation at the November 19, 2021 Board Meeting that discusses that study:
Question: Board Member
Do our valleyland policies provide an option to ask for an environmental impact study and if so under what criteria?
Answer: NPCA (staff)
“There’s no specific requirement for an environmental impact assessment or study. However, in this case, there was a natural area inventory that was completed by OPG for this area that was submitted”
Other similar questions were raised to which the staff person gave answers which referenced the DeCew Study as supporting the racecourse trails locations. This is very puzzling as there was no inventory for most of the racecourse in the ravine. Given extensive flora and fauna in the area, including numerous protected species, a proper study should have been completed.
We have reviewed the study and although it cannot be used as the NPCA staff person has suggested, it does have some very interesting findings. These indicate that this greenbelt area near the DeCew power plant is unusually biodiverse, and this demonstrates the need for a proper environmental assessment of the entire racecourse area adjacent to the study area.
There is no mention in the FOI materials of either the abundance or biodiversity of plant and animal life in this ravine. The ravine slopes are particularly important in that they host indigenous species that are under attack in more visited areas. The entire ravine ecosystem is threatened by the steady stream of racers that we are told will flood the area, both before and after the Games.
There is no evidence that the Games met the condition in the permit requiring contacting Ontario Ministry of Environment, Conservation and Parks, and Environment Canada, about Species at Risk and the Migratory Birds Convention Act. We are aware of numerous relevant species in this ravine. And, we found it interesting that the DeCew Inventory Report recommended that a bird study be undertaken in the DeCew area.
The conditions of the ravine work permit require that the work not have “detrimental impacts on the environment”.
Given that no one has made any assessment of detrimental impacts, we see no evidence that this racecourse can demonstrate it will meet that condition, as set by the NPCA.
Why was a permit issued?