Browsing the archives for the Bio Diversity tag.

Offer to Purchase Sent to Urbandale

South March Highlands

December 30, 2010

Mr. Sachs & Ms. Jarvis,

Since it is now evident that Ottawa City Council is currently unwilling to add any value in protecting the South March Highlands, we are extending this offer to work directly with you in this regard. The South March Highlands – Carp River Conservation Inc. is the legal entity that represents the interests of over 6,000 individuals who are committed to being stewards of Ottawa’s Great Forest – the South March Highlands.

We suspect that you may not have been fully aware of the environmental significance of this area when you originally purchased the lands north of Kizell Wetland and Beaver Pond from Genstar in Sept 2000. We are confident that by working together, we can create a win-win solution to this situation.

By now you are no doubt aware that the South March Highlands is an old-growth forest, home to 20 documented Species-at-Risk, has the highest floristic diversity and densest bio-diversity in Ottawa, and contains several archaeological sites that are twice the age of the Egyptian pyramids. You are also aware that there is substantial community resistance to your development plans and that Algonquin spiritual leaders consider this area to be ancient, unique, and a very special sacred space.

According to the Nature Conservancy of Canada, unlike the tax provisions for donating land directly to a municipality, an individual or corporation that donates land to a charitable land trust may obtain a tax credit equal to 100% of the market value of that land.

We are willing to establish a charity for that purpose if you are willing to donate all remaining undeveloped land that you own in the South March Highlands. At the point when you are ready to wind up the corporate operation of KNL, any remaining tax credit may be fully monetized by selling the corporation to a third party, such as an income trust looking to shelter earnings as they roll-over into a corporate entity.

Furthermore, we propose to name the resulting park, the “Urbandale Conservation Forest” (or a similar name of your choosing) so that you may leverage significant, positive, and very green, branding benefits in recognition of your generosity. Our marketing experts will work with you on signage and branding opportunities accordingly. We will also support you in a media campaign to ensure that branding benefits are maximized. When leveraged into our existing Stewardship Plan for the area, which emphasizes eco-tourism involving an audience measured in millions of people, we believe that this will be of significant branding value to you.

Should you wish to monetize some of your current investment now, we are also prepared to optionally enter into a long-term purchase agreement for “Phase 9.” This would enable you to obtain a tax credit for donating land west of Goulborne Forced Road (GFR) as described above, as well as receive annual payments for the land east of GFR and north of Beaver Pond.

In this scenario, we would establish the charity so that it can receive community donations, and pursuant to the 40% Agreement which runs on title with the land, purchase the 60% of developable land at fair market value and the 40% at no cost (as you did when you purchased the lands). You would facilitate this purchase via a vendor-take-back mortgage at 6% over 30 years.

Since some lead time would be necessary to establish the cash flow for the charity, depending on the agreed purchase price, the first couple of annual payments may need to be balloon payments. Nonetheless, since city records show the assessed value of the land for tax purposes is only $6 million, it is evident that KNL paid less than that for that land and you would receive more than double your investment plus the 6% payout.

If you wish to explore this option, we can provide further details of how we will raise the funds for purchase and we can discuss the methodology for fair market valuation.

We believe that the above represents a fair outcome for you in what otherwise is an increasingly difficult situation. We hope that in considering this offer, you reflect on the merits of taking a long-term view of the benefits from enhancing your eco-stature and brand over a status quo course of action that appears likely to significantly damage it. We believe that you will conclude that it is better business to work with a community than to continue to fight against it and we trust that, together, we can both start the new year on a positive note.

Sincerely,

Paul Renaud
South March Highlands – Carp River Conservation Inc.

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Species Loss in South March Highlands

South March Highlands

Species-at-Risk (SAR) are classified based on the risk of extinction due to declining population within geographic areas.  As populations decline and vanish, the species’ classification increases until the species is either recovered (saved) or ultimately goes extinct.

This is not a theoretical risk.  According to the Committee on the Status of Endangered Wildlife in Canada (COSEWIC), there are 13 species that once existed in Canada and are now extinct and a further 23 species that no longer exist in the wild in Canada (but exist elsewhere).

The loss of bio-diversity can readily be seen in the South March Highlands (SMH) as evidenced by the SMH Conservation Forest Natural Environment Assessment [Brunton 2008].

Click on the tabs below to see how real the risk is and why it the SMH should not be further developed.

Extirpated

The following 11 species are already believed to be extirpated (previously observed and no longer present in the SMH) as a result of development that has occured to-date in the SMH:

  1. Cathcart’s Woodsia
  2. Oregon Woodsia
  3. Spiny Coon-tail
  4. Adder’s-tongue Fern
  5. Back’s Sedge
  6. Large Duckweed
  7. Long-spurred Violet
  8. Showy Orchis
  9. Southern Arrow-wood
  10. Strawberry-blight
  11. Virginia Spring Beauty

Endangered

The following 3 species have been observed in the SMH and are Endangered both provincially and nationally:

  1. American Ginseng (a plant known to exist in SMH and once thought to be extirpated, subsequently re-discovered in 2009 when surveying for Terry Fox Drive Extension and subsequently extirpated in 2010 to make way for the road)
  2. Butternut (the SMH is one of the few locations in North America with some healthy, disease resistant trees)
  3. Loggerhead Shrike (possibly extirpated as there are no recent observations of this bird)

Threatened

The following 8 species have been observed in the SMH and are Threatened:

  1. Blanding’s Turtle (Ontario & Quebec)
  2. Whip-poor-will (All provinces east of Alberta)
  3. Golden Winged Warbler (Ontario & Quebec)
  4. Western Chorus Frog (this species is listed Federally for Ontario & Quebec but not yet listed under Ontario SARO)
  5. Eastern Musk Turtle (Ontario & Quebec and possibly extirpated in the SMH as there are no recent observations)
  6. Olive Sided Flycatcher (All Provinces)
  7. Chimney Swift (Ontario)
  8. Bobolink (Ontario)

Special Concern

The following 9 species have been observed in the SMH and are of Special Concern:

  1. Bridle Shiner (a small fish observed in Shirley’s Brook and Kizell Pond)
  2. Short Eared Owl
  3. Black Tern
  4. Common Nighthawk
  5. Snapping Turtle
  6. Eastern Milksnake
  7. Monarch Butterfly
  8. Bald Eagle
  9. Red Headed Woodpecker

SAR Candidates

These additional 18 species have been observed in the SMH and are on the COSEWIC Candidate List for Ontario:

  1. Evening Grosbeak (high-priority)
  2. Eastern Wood Peewee (high-priority)
  3. Wood Thrush (high-priority)
  4. Bank Swallow (high-priority)
  5. American Bullfrog (mid-priority)
  6. American Kestrel (mid-priority)
  7. Belted-Kingfisher (mid-priority)
  8. Eastern Red-Backed Salamander (mid-priority)
  9. Field Sparrow (mid-priority)
  10. Blue-Spotted Salamander (low priority)
  11. American Toad (low priority)
  12. Bluntnose Minnow (low priority)
  13. Boreal Chickadee (low priority)
  14. Killdeer (low priority)
  15. Midland Painted Turtle (low priority)
  16. Northern Two-Lined Salamander  (low priority)
  17. Green Frog  (low priority)
  18. Wood Frog  (low priority)
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Terry Fox Drive & South March Highlands Overview

South March Highlands

This posting uses tabs.  Be sure to click on all of them to see the whole article.

SMH

The South March Highlands (SMH) has been described as a “wild island” of natural landscape within the City of Ottawa.

No other major city in the world  literally includes a vigorous old growth forest with as much bio-diversity that includes endangered species.  The closest is Vancouver’s Stanley Park which is 1/3 the size and contains ½ the variety of vascular plants compared to the SMH.

The SMH  is rated as a Provincially Significant Area of Natural and Scientific Interest (ANSI) for both its Life Science value (895 hectares) and is also ANSI rated for its unique Wetland Complex (114 hectares).  A double rating is very rare in Ontario and speaks to the ecological significance of the area to the Province.

SMH has been rated by scientists as the “most important reservoir of  ecological potential” in the City of Ottawa because it has the densest bio-diversity of any area in Ottawa and provides resources for the renewal of depleted natural areas elsewhere.  There are 10 distinct habitats within the SMH that are home to  17 species-at-risk (SAR) and the largest deer wintering yard (925 hectares) in the City of Ottawa.

The hydrology of SMH is integral to both the Carp River as well as to the Shirley’s Bay wetland complex in the Greenbelt.  Two subwatersheds that have headwaters in SMH feed both ends of Shirley’sBay wetlands in the National Capital Greenbelt.

The SMH is geologically unique in the City of Ottawa and supports over 440 species of vegetation, including: 64 Regionally Significant, 50 Locally Significant, 6 Provincially Rare, and 2 Nationally Endangered species of vascular plant life.  This habitat is crucial for 164 species of bird, including 136 species that breed in this area, 9 bird SAR, and the 30 Regionally Significant species of bird that inhabit this ecosystem.

Yet, even though the Regional and City Official Plans have officially “protected” the SMH since 1972, less than 1/3 of the original area remains. 

TFD 2000-2005 

In 2000 the City prepared an Environmental Study Report (ESR) that recommended that  Terry Fox Drive (TFD) be routed through the centre of this fragile ecosystem.  This choice had the highest ecological impact of the 4 alternative routes considered in the study and completely ignored the results of the 3 public criteria workshops that consistently rated ecological impact as the most important evaluation criteria for the City to use. 

Two of the four reasons for choosing the environmentally worst option were to mitigate the impact that TFD would have on future development within the area – development that was not approved at that time, and on lands that were not zoned for urban expansion at that time.

In 2004, at the request of residents, a Special Study of the NEA zoning was conducted that improved the protective zoning of lands south of the proposed road.  However, later that year an EA Addendum was prepared that was used to justify an expansion of the urban boundary. 

An EA Addendum is required whenever there has been a material change to either the planning or environmental context for a project.  The Notice of Completion was filed for this Addendum on January 2005.  A Notice of Completion creates the only opportunity for interested parties to formally intervene in the EA process and they only have 30 days to file a formal appeal (called a Part II Order Request).

A Part II Order Request was filed by a land developer that was not resolved until January 2007 after a private deal was struck with the City that relocated the Goulbourn Forced Road (GFR) & TFD intersection so that it would provide easier access within the subdivision that the developer was planning.  Note that a  subdivision plan had not received even a draft approval at that point in time. 

This deal had the effect that GFR could no longer serve as a conduit for south bound traffic along 2nd Line Road (part of the original justification for the TFD extension).  The City has adopted the position that changing the intersection is not a material change to the EA Addendum even though GFR is the boundary of the project scoped by the 2005 EA Addendum.

Meanwhile, the developers (KNL/Urbandale) challenged  the 2004 NEA zoning and obtained an Ontario Municipal Board (OMB) ruling in 2005 that approved a draft plan of subdivision for development within half of the SMH. 

Neither of the 2000 or 2005 “environmental” assessments, nor the OMB, addressed the ecological impact of both the road and urban development.  The Special Study’s scope was restricted by the City to a narrow area and did not examine the holistic impact of road and urban development on the SMH.

TFD 2006-2010

In 2006, the City of Ottawa made amendments to the Official Plan that effectively creates the TFD roadway as the outer edge of the western urban boundary. Inside the curve of TFD, areas previously identified as Natural Environment Area were changed to General Urban Area or to Urban Natural Feature. In effect most of the forested area was re-zoned to general urban use inside the arc of TDFE, while outside the roadway arc lands remained zoned as conservation forest, agricultural or greenbelt rural. 

In 2007, after public challenge, the OMB upheld the change to urban boundary.  The City then prepared another EA Addendum in 2007 but has never filed Notice of Completion for it.   In order to accelerate qualification for federal Infrastructure Funding, the City adopted the position that it did not need to complete the 2007 EA Addendum even though there have been two OMB rulings affecting zoning since 2005 Notice of Completion.

In 2007, Ontario became the leading jurisdiction in North America for SAR protection when it passed the Endangered Species Act (ESA).  Even though there is no impact analysis on SAR  in any of the 2000 ESR, 2005 EA Addendum, or the unfiled 2007 EA Addendum, the City has taken the position that the passage of ESA does not constitute a material change to the environmental planning context. 

The unpublished EA Addendum in 2007 provided for changes to rail-grade separation.  But  when the City accelerated the project for 2010 construction, it decided to incorporate the design for a raised rail crossing but not implement the bridge until later.   Use of the raised-crossing design  with level-crossing implementation will not only violate Transport Canada regulations for train line-of-sight safety, but also pose serious risks to human safety.  Without public review, there is no opportunity to ensure the safety of this rail crossing.

In 2008, the Minister of Environment (MoE) issued an order setting conditions regarding the approval of the Carp River Restoration Plan (CRRP), 1 km of which overlaps with, and is hydraulically interconnected to the management of drainage for TFD.  In 2009, flooding in the Carp River watershed affected 1500 homes. 

According to the 2005 EA, TFD will impact the floodplain storage area by over 45,000 cubic metres – significantly exacerbating the risk of flooding since the impact of the road was analyzed using an assumption that peak flows would be 30- 40% less than what it is now understood to be.

According to the 2009 TFD Storm Water and Floodplain Management Report, the construction of TFD “directly impacts the Carp River floodplain”. 

In 2010, as a result of the discovery of questionable parameters used by the City for hydraulic modeling of the Carp River flood levels, the MoE required that CRRP be regulated as a sewage works requiring approval under the Ontario Water Resources Act. 

Yet, even though there is a 1km overlap between TFD and the CRRP, and even though it is now known that the storm culverts planned for TFD are insufficient for the task, there has been no re-examination of the design impact of TFD storm water management on the setting of Carp River grades.

In 2010, to qualify for federal funding, the City completed two Canada Environmental Assessment Agency (CEAA) Screening Studies for different parts of TFD that cross through the SMH.  The City subdivided the project into two parts (A & B) so that they could meet federal deadlines for approvals for Infrastructure Funds. 

Despite the fact that both the content and depth of these CEAA studies are larger than the original Provincial EAs, the City chose to perform those studies without public review and input.  

 

Mitigation Denial

The City’s CEAA studies rely heavily on environmental mitigation plans for which there has been minimal to no scientific basis. 

  • Eco-passageways proposed as mitigation for turtle habitat fragmentation are regarded as experimental by the scientific community and there is no scientific evidence that they will even be used by turtles.  
  • The size and location of eco-passageways were determined on the basis of least project cost and a 3-month long winter study of wildlife movement (when many mammals and all amphibians and reptiles are hibernating). 
  • Vegetation studies have been piece meal and have never holistically examined the entire SMH context. 
  • Herpetofauna (reptile & amphibian) studies for the road were based on a random-walk that only conducted a single sample of the area, except for the salamander study which was required to be performed in greater depth by the CEAA. 
  • Fisheries studies have been cursory, never exceeding 2 days in length. 
  • Despite the fact that Blanding’s turtle, a SAR, has been repeatedly observed in SMH since at least 1991, there has never been a radio-telemetry study of their movement. 
  • Even though the Monarch Butterfly, a SAR, has been observed in SMH there has never been an insect study.

The Part B CEAA Study contains material changes to the planned re-alignment of Shirley’s Brook.  Over the past 10 years, 5 different re-alignments of Shirley’s Brook (depending on which EA is referenced) have been proposed – even though previous studies determined that re-habilitation of the brook was not necessary.  None of these changes examined the collateral impact on drainage and floodplain requirements, nor did they examine the collateral impact on SAR.

The fisheries impact analysis presented in the CEAA Part B Study conveniently omits the presence of a SAR, Bridle Shiner, at the location impacted by the various re-alignments of Shirley’s Brook.   The effect of omitting this information results in a material reduction in the risk assessment for fish habitat. 

To-date the Dept of Fisheries and Oceans has declined to revisit their approval of this project because Bridle Shiner isn’t listed for the SMH in their SAR database. Yet separate studies conducted by the City of Ottawa in each of  1998, 1999, and 2000 confirm the presence of Bridle Shiner in SMH.

Meanwhile the City, Ontario MNR, and Environment Canada continue to ignore the uncharacteristic and increasingly blunt warnings from scientists about the serious fragmentation of habitat caused by TFD. 

  • The 2004 Special Study determined that the extension of TFD will sever the eco-connectivity of the SMH to the extent that it is called a “Berlin Wall” by Dan Brunton, the foremost scientific authority on the area.  
  • The leading turtle scientist in Canada, Ron Brooks, has declared that, regardless of the proposed mitigation measures, building the road will eradicate the entire population of Blanding’s turtle
  • The City of Ottawa’s expert Forest and Greenspace Advisory Committee passed a unanimous resolution expressing “grave concerns about the ecological damage caused by the TFD extension”, denouncing the proposed mitigation measures as seriously inadequate and expressing concern over the failure of the City to protect the area. 
  • The Ottawa Field Naturalists, Canadian Bio-Diversity Institute, Greenbelt Coalition, Riverkeeper, Ecology Ottawa, Sierra Club, Save Our Greenspace, and several other ecological and community groups have endorsed a statement that the road should be abandoned.

No Reason

The justification for the road evaporated with the tech bubble in 2001. 

  • The City’s Auditor General in 2007 found that the population projections used to justify it and several other projects were unrealistic and unreasonable since actual growth has been 80% less than forecasted. 
  • City Management agreed with the AG’s findings and undertook to review all existing growth-related plans and programs. 
  • In 2008 the City reduced the forecast in the Transportation Master Plan but failed to update the TFD traffic study (used to justify the increase in scope of the project in the 2005 EA). 
  • The City has never obtained Council approval to continue with a project that no longer fills an economic need. 
  • The City’s Transportation Master Plan, 2008, continues to assert without justification that the rationale for the TFD expansion project is that it “Accommodates the vehicular capacity deficiencies for growth areas in Kanata“.

Meanwhile, in 2010 another developer (Richcraft) as applied to the OMB to have the lands outside of the arc of TFD zoned for urban development – yet again using the road to justify the push of the urban boundary westward.  This application is currently being reviewed by the OMB and is opposed by community and ecological groups.

The Municipal Class EA Process is unambiguous in requiring that an EA Addendum must be prepared whenever there has been a 5-year lapse of time between filing the Notice of Completion and the commencement of construction.  Notice of Completion for the 2005 EA was filed January, 2005 and project construction for Parts A & B did not commence until April 2010. 

The City holds the position that the 5-year limit applies only to the 2000 ESR for which construction started in 2003 south of the area scoped in the 2005 EA Addendum.  This position conveniently ignores the fact that, by definition, a subsequent EA Addendum represents a material change in scope to the project.  To assert that the 2005 EA Addendum does not reset the lapse-of-time clock defies any reasonable interpretation of Ontario’s Environmental Assessment process.

Ontario’s MoE staff have concluded that, under the Municipal Class EA Process, it is up to the proponent to decide whether an EA Addendum is necessary.  Consequently, the MoE has to-date declined to require the City to update its 2005 EA. 

Ontario’s Environmental Bill of Rights (EBR) provides that Ontario residents can expect that government ministries will protect their environmental rights.  The responsibilities of each Ministry in this regard are specified in a Statement of Environmental Values.

The MoE’s reluctance to require the City to update its 2005 EA appears to be in contravention of that Ministry’s Statement of Environmental Values that states, in part, “The ministry works to protect, restore and enhance the natural environment by: Undertaking compliance and enforcement actions to ensure consistency with environmental laws

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Acer Nigurm Requiem

South March Highlands

Sadly none of you, nor anyone else, will ever see the 200-year old Black Maple (Acer Nigrum) that was in the way of this road.  It was clear-cut along with a significant stand of tall White Pine (100 feet) and other Black Maples. 

The Black Sugar Maple is very uncommon in Ontario and is only found in southern Ontario.

Located at N45’15.231” / W75’55.492”, this unmistakable tree was originally surveyed by Daniel Brunton in 1992 and was identified by a photograph in a City-sponsored study as a significant feature in the NEA lands at that time. 

For it to be this age meant that it had survived the great forest fire of 1870 that devastated the Ottawa Valley.  Sadly it could not survive our City’s greedy feast at the federal pork barrel.

This ancient tree once stood over 75 feet tall, had a circumference of 10’9” (328 cm) and a diameter of 3’7” (109 cm).  A well known local botanist, Martha Webber, analyzed the rings to verify the age of the tree to be well over 200 years old and confirmed that it was perfectly healthy prior to being destroyed.

If not the oldest tree in the City of Ottawa, it would have been one of the oldest. The oldest trees in the Dominion Arboretum are date back only to 1889.

Old trees are important, not only for their heritage and historical significance, but also for their bio-diversity.  The genetic makeup of ancient trees includes disease-resistant chromosones that play a critical role in protecting the local eco-system.

A “younger” Black Maple nearby was also destroyed.  That tree had a circumference of 7’5” (226 cm) and a diameter of 30” (76 cm).  Ms. Webber verified the age to be well over 120 years old. 

This tree, as old as Confederation, was on the edge of the roadway, in perfect health, and could easily have been retained.  In fact the City has a by-law that is supposed to protect trees having a diameter of greater than 50 cm.

The City project staff responsible for this irresponsible act were well aware of this tree and had been instructed by the City Councillor, Marianne Wilkinson, to try to retain it.  Subsequent email confirms that the tree was destroyed without her authorization. 

If this is an example of how the City will protects it’s natural and historical heritage in a Conservation Forest, then the City of Ottawa must immediately transfer stewardship of its parks and forests to the NCC.  That trees of this value were so recklessly cut down – in a Conservation Forest is completely unacceptable.

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Citizen Article Whitewashes TFD

South March Highlands

On April 17, 2010,The Ottawa Citizen published an article called  “Critter Patrol on Terry Fox“.

Unfortunately this article presents a one-sided and whitewashed description of what is really going on.    Here is some important errata:

  1. It presents information from “The experts….”, creating the impression that there is no expertise among the hundreds who oppose this road. In fact, there are many experts in opposition including well-known botanists, biologists, turtle experts, civil engineers, etc.  All of the expert scientific information about this area, conveniently suppressed by City, raises signficant concerns about any development in this area has been compiled by eminent regional experts. The article is an insult to all of those experts.
  2. It fails to highlight that there are in fact 17 Species-at-Risk identified as being impacted by this road and nowhere in the article is the environmentally sensitive nature of this area discussed. 
    • The City’s own South March Conservation Plan states that this is the most densely bio-diverse area in the City of Ottawa and that  “The Conservation Forest represents one of the most important reservoirs of ecological potential in the City of Ottawa, providing resources for the renewal of depleted natural areas elsewhere as well as encouraging diversification within established habitats.”
    • In addition to providing habitat for 17 Species-at-Risk, it is home to 423 native species of vascular plants, including 41 Regionally Significant species, 134 bird species, over 50 fish & mammal species, and uncounted reptiles and insects.  These “critters” depend on over 30 differentiated ecotypes of vegetation that comprise 10 distinct habitats – all packed into an area less than 6 square Km – and all within City limits. 
    • The bio-diversity of this area has been designated as a Provincially Significant Area of Natural and Scientific Interest (ANSI) by Ontario’s Ministry of Natural Resources.
  3. It quotes the project manager, Mr. Mike Flainek, whitewashing history by stating “The City of Ottawa from Day 1 has made some very conscious decisions to make sure that environmental impacts have been, first of all, managed, and second of all, reduced.”. 
    • The Citizen did not question how this statement could be true when at the outset of planning the road the City selected the worst possible routing for it as measured by environmental impact (based on the City’s own evaluation of alternatives).   The route chosen is in fact 5x worse than the environmentally best alternative which is simply to fix up Goulbourn Forced Road.  Using GFR instead of bulldozing a Conservation Forest for TFD will save $47 M in taxpayer’s money since the upgrade work for GFR is already scheduled at a cost of $18 M. 
    • The Citizen also did not question why the City is building a 4-lane road when a 2-lane road will suffice (assuming that the current routing).  According to the planning assumptions used for this road, employment growth for the West area was to more than double between 2001 and 2011. 
    • In reality, the employment numbers available in North Kanata between the 2001 and 2006 censuses reveal employment growth has been less than 20%. With the recession and troubles in the high-tech sector, there would have been no where near the anticipated employment growth since 2006.  The extra $10 M in cost and environmental impact of a 4-lane road is not necessary.
  4. The “experts” are quoted as saying, “When the turtles come out of hibernation over the next two weeks …”.  How can these “experts” not know that the turtles are already out of hibernation and have been seen basking in the sun for several weeks?  Perhaps these photos taken on the Easter weekend in the South March Highlands should be added to the identification wall of their trailer.  There is a photo of a Blanding’s in the photoset.
  5. Evidently we are to believe that “The fencing around the construction site … should keep the Blanding’s turtule out during road work.”  A visual inspection of the area readily identifies many gaps in this Maginot Line that turtles will never cross.
  6. A more serious inaccuracy is the assertion that “To help protect the turtles in the longer term, a permenant fence will line both sides of the roadway throughout the forested area.”  In reality, the CEAA Screening Study states that the fence is only on one side of the road because the forest will be destroyed by development on the other side.  The Citizen also did not question how this fencing will be used to prevent turtles from crossing at intersections or on the transecting collectors such as GFR and 2nd Line where there are no fences planned.  Perhaps the City is planning to train the turtles to use the culverts, but I doubt it.
  7. The article states “…they’re a threatened species protected by provincial law” but fails to mention that both the turtles and their nesting sites are protected by both provincial and federal law.  The Citizen did not question how the City will avoid destroying nesting sites when they have not taken the time to do a turtle study to determine where those sites are. 
  8. One has to wonder about how the City has chosen the location for the environmental crossings discussed in the article when, according to minutes of the City transportation committeee, the only wildlife movement study done by the City was a 3-month long winter study.  Those “experts” must be really smart to be able to use a study done when both frogs and turtles are hibernating.
  9. The article observes that the City may be chasing $32 M in federal funding.  It is too bad that the Citizen didn’t note that federal funding still comes out of the same taxpayer’s pockets as municipal.  Left pocket or right pocket, the buck stops with the taxpayer.

Notwithstanding the whitewash, it’s time to stop this madness and revisit the real question of (a) is this road still needed at all, and (b) if so is it in the right place?

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