The first map above is what  the Games submitted to NPCA on September 29, 2021 that “outlined the scope of the project”; as requested by the NPCA for the permit approval process.  Identified as “Schedule B – The Project, Mountain Bike Course ,it also included the features for the course, numbered to correlate to the map.   To the best of our knowledge none of the locations in the pictures used were taken in the actual area as shown on the map, especially features 5 – 11 because there were no trails in those areas

Of note, regarding the scope of work package, is that both Figure 1 — Mountain Bike Course (Map) for the 2022 Canada Summer Games and Figure 2. Features That Will Be Used for the Proposed Mountain Bike Course, are identified with the Energy Cycling Club and not the Niagara Trail Maintenance Association, which was not  formally established until June 15, 2021.

It was  this package of information for the “scope of the project” that the NPCA used and referenced right up until October 18, 2021 when documents show that the NPCA was satisfied and ready to approve the permit application.  It was not until an NPCA staff person joined us for a walk of the entire course (at the time), on October 20, 2021 that new maps and supporting documents were then provided.  

The second map, to the right above, shows (approximately) what were existing trails before July, 2021, when work began, resulting in new trails cut in previously untouched parts of the ravine.  

The Trail System

The trail system in the ravine (marked as the “Existing Trail” on the Games Proposed Race Course) originally ran just along the main Creek to up to Lockhart Drive. The ravine slopes were untouched, with valuable forest. Not too long ago a few rogue mountain bike trails were added at the south end. With the new racecourse for the Games the ravine is being transformed with the addition of  a great many new mountain bike trails/track and features throughout the entire ravine. 

The first site visit for the permit was on Oct 4, 2021.  The very next day an NPCA  staff person stated “The trail has been altered by hand, albeit minor. It is not noticeable as vegetation has barely been disturbed. No new trails have been constructed; they are existing. I am of the opinion that this can be supported under Policy.”

On Oct 7, 2021 a senior Games official sent an email to NPCA Planning Ecologist with a description of the scope of “the works”, and information regarding the agreement between OPG and the Games.

“… this Agreement includes a description of the work and site plan including all areas where trail improvements are occurring. 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.” 

This letter is likely why the Permitted Works at the top of the final approved Permit is itself so misleading.  It states: “The “Permitted Works” under the permit are “works undertaken for the purpose of Phase One: Trail Maintenance and Mountain Bike Features for Canada Games”

Those statements do not describe most of the racecourse or the work that has actually been done.  Much of the racecourse has involved the construction of totally new trails and features.  If the “scope of works” was so simple and minimal why did the contractors for the Games, the NTMA have to dedicate over 1,000 of volunteer hours just up to December, 2021. See article.

The Games permit application near the end of the process finally acknowledged the construction of new trails. The Mayor of St. Catharines publicly confirmed that the racecourse was the creation of a new trail system. 

 NPCA believed that the racecourse was being built on existing trails, because that is what they were told by the racecourse vested interests.  Their opinion was not based upon data.  The FOI materials include few photos, and none of the most fragile and difficult to access upper slopes.

Given the late date (post construction) and cursory evaluation, NPCA would not have understood how extensively the new construction was impacting the ravine and its ecology. There was removal of extensive groundcover (seedlings, saplings, moss, etc.), relocation of many rocks, deep bench-cutting close to fragile mature trees (root damage and soil destabilization), digging out of large amounts of soil without regard for erosion, and disruption of wildlife habitat and paths. Because project vested interests did not apply for a required permit in advance, all of this destruction occurred months before NPCA’s involvement.  Instead of treating the unauthorized construction as cause for concern,  NPCA simply accepted the word of the construction interests that no damage was resulting.  Would they do the same with a new shopping mall?  The NPCA did not fulfil its function in this case.

Other than a site visit on October 20, 2021 dealing with an official complaint from a member of our group, NPCA did not make any attempts to obtain detailed information about the trail system from the long-time residents who have deep familiarity with the ravine.  Local residents know that the north and south sections of the ravine in the upper slopes were not previously connected by human trails.  They know that extensive areas of habitat for the nesting and travel of a great diversity of wildlife have been converted into new trails and mountain bike features.  Areas on the slopes that were untouched are now full of wide, slippery, muddy trails. NPCA did not seem to care.

It also appears that NPCA did not consider the planned post-construction use of this new trail system (which the Mayor of St. Catharines stated was for “many, many, many more people”), for racing and competitive racing events, or the negative impacts on wildlife and other trail users from frequent trail maintenance and using powerful gas blowers to keep the tracks dry for racing.

We have valid concerns that the new trail system is so extensive that it will result in large areas of the ravine becoming another wasted expanse of packed dirt similar to the area at the beginning of the racecourse at Lockhart Drive. (see Photo) 

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