Opening Remarks:

Human trails through woods are beneficial to the public, but new trails must be weighed against any negative impacts to the environment.  In the case of the racecourse the extensive alteration of the ravine throughout its slopes and valleys is very significant.  No one would approve of the construction of a building in the middle of this ravine, however, allowing alterations of a more limited nature throughout the entire ravine with multiple new trail systems can be even more destructive.  The ecological effects of building the racecourse, holding the Games, and then continued competitive use of the racecourse in the legacy phase will be profound.  The ravine will be destroyed and the consequences will not be reversible.

We made a presentation to the NPCA Board on November 19, 2021.  The NPCA staff person responsible for approving the permit frequently referred to the permit approval as  “based on the information that was provided”.  The information in this case was inaccurate, misleading and incomplete, and approvals were granted in a hastily manner. The result is that the permit process was inadequate and the discussion of the racecourse by the NPCA Board members at the November meeting was not based on sufficient data. As the Chair for that Board meeting stated: Not knowing about this until recently, we find ourselves with one hand tied behind our back in a way”

There are more than sufficient reasons to cancel this permit. There were always other areas more suitable and environmentally friendly to use for the racecourse.  We are destroying one of the last remaining urban ravine woodland ecosystems to build an outdoor athletic facility.  This is wrong.  The NPCA should recognize that the ravine is not a racecourse, and reaffirm its role in protecting the environment. The ravine is not a racecourse.

Introduction to Our Summary

We have read the numerous pages of Freedom of Information (FOI) documents that we requested and received from NPCA that relate to the Permit granted to the Games for the racecourse construction. These suggest a very cursory permit process. No studies were conducted, the environmental importance of this specific ravine was not discussed, misleading and incomplete information was relied upon, and certain approvals of the racecourse were decided from the outset without sufficient information.

 The “Permitted Works” description for the permit are works undertaken for the purpose of : Phase One: Trail Maintenance and Mountain Bike Features for Canada Games”

The description of the Permitted Works for this permit is misleading.  The work is much more than maintenance and features.  It is the construction of a new trail system, for racing.  This has been publicly stated, more recently, by the Mayor of St. Catharines and senior officials with the Games.

For a list of the unique features of the ravine where this racecourse is located, making it unsuitable for a racecourse, and our reasons why a permit should not have been granted by the NPCA,       Click here.

We will be sharing specific details regarding our claims in this section of the website, some of which will be forthcoming as we acquire more documentation and validations thereof.  

We believe that a permit should not have been approved for the reasons given below. Moreover, we will be advocating that the permit be cancelled in accordance with NPCA policy, as stated in its permit authorization:

Cancellation:  The NPCA may cancel this Permit or add to or amend any of the conditions included herewith, at any time and without prior notice, if the NPCA determines that:

  • the works are not in conformity with the Permit
  • the information presented to obtain the Permit was materially false or misleading; or
  • the works or method of construction used in the work are having or will have detrimental impacts on the environment.

Issues Raised by Our Review of the FOI Documents

In our opinion the FOI documents strongly suggest that NPCA staff erred in the following ways:

  1. They did not do any environmental studies. Instead, they relied almost entirely upon a natural areas inventory study provided by the Games.   That inventory study did not cover most of the racecourse area in the ravine.  Again, there was (and is) no environmental assessment of the project area.
  2. The racecourse project was described as “safety and other minor improvements” of existing trails. NPCA’s permit consideration occurred only after the project was mostly complete, and was based upon post-construction viewing of the racecourse. Therefore, NPCA could not discriminate between trails that had been pre-existing, and new trails cut in violation of the stated limitations of the project.  NPCA simply accepted the misleading description (all pre existing trails) provided by the racecourse supporters.  In fact, most of the racecourse in the ravine is new construction.  We have extensive photographic documentation of this.
  3. They did not sufficiently consider the impacts of racecourse construction, competitive trail use and ongoing trail maintenance on wildlife.
  4. They did not evaluate the particularly damaging impacts of competitive cycling (both during the Games and the legacy phase) on the ecosystem. Competitive cycling is much more environmentally stressful than recreational cycling.
  5. They were unquestioning in their reliance upon Application information from project vested interests. This information was incomplete, misleading, and deliberately inaccurate. NPCA did not adequately weigh information provided by City residents and other trail users. Moreover, they did not seem to accept what was presented to them by local residents and as such, did not investigate our claims or ask for substantiating or additional details. 
  6. They did not use the appropriate care that should have been applied to this area, which is designated as a Significant Woodland, potential ESA, and important biodiversity corridor.
  7. They failed to consider that racecourse construction is the conversion of a conservation area to a dedicated athletic facility.
  8. They allowed themselves to be subjected to political pressure to approve the permit.

We believe that the cumulative negative effects of the construction and use of the racecourse will be devastating to plants and wildlife and will increase erosion and slope instability in the ravine. This should have disqualified the racecourse from receiving a permit.

These effects are destroying the very thing that draws so many walkers, runners, nature lovers, casual cyclists and other passive users to this beautiful and beneficial ravine. 

We have categorized the more significant statements by NPCA staff in the FOI documents, and the misleading and incorrect information provided by the Games.  The categories we have established to share this information are as follows, with links to each separate section. 

Regarding the Trail System

Ecological Impacts

Environmental Study – Plants and Wildlife

Erosion

Proposed Revegetation Plan

Racing and Passive Recreation Use

A Questionable Permit: Summary

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