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LETTER: Independent third party review essential for 800 Canmore

Editor: It is unfortunate there was not a proper independent third party review of the proposed 800 3rd Avenue Canmore development available with the other documents posted online in advance of the May 24 public hearing on bylaws 2022-09 and 2022-10.

Editor:

It is unfortunate there was not a proper independent third party review of the proposed 800 3rd Avenue Canmore development available with the other documents posted online in advance of the May 24 public hearing on bylaws 2022-09 and 2022-10.

Both Bylaws are significant as they would require amendments and/or contravene six policies in Canmore’s 2016 Municipal Development Plan (MDP) and two amendments to our 2018-22 land use bylaw, including MDP Policy 4.2.11 which would disallow this development in the South Canmore Local Habitat Patch (SCLHP) which was provincially designated in 1992.

While the third-party review was presented to council in the May 3, 2022 agenda, it was not easily accessible to those making submissions to the hearing.

In addition, the exit for wildlife from the Three Sisters Across Valley Corridor is through the SCLHP, where development is already squeezing access to the Bow Flats Regional Habitat Patch. And Elk Island is an important elk calving area.

Ironically, the third-party review is also one of the MDP policies that this development would contravene, where Policy 18.2.15, states that “Whenever an EIS is prepared, the Town will contract a qualified professional(s) to conduct an independent third party review of the EIS.”

Rather than providing a third-party review that is divorced from the financial interest of the developer, the Town allowed a collaborative review of the developer’s EIS. As stated by the owners: “The Concept was directly shaped by the outcomes and findings of the Environmental Impact Statement and iterative changes to the design were completed in collaboration with the Town of Canmore Planning Department and the third-party reviewer of the EIS.”

The review was carried out by MSES (Management and Solutions in Environmental Science). They state, in what they refer to as a memo, that they “worked with the Town to develop the ToR (Terms of Reference) and reviewed the first draft of the EIS” and reviewed the final draft of the developer’s EIS, while clearly distinguishing their own recommendations from both the developer’s initial and later improved versions.

In their conclusion, MSES provided their independent assessment of the cumulative impact of this development, which reads:

While the EIS predicts the proposed Project will have negligible impacts on cumulative effects, we do not agree that the cumulative effects will be negligible. Other environmental assessments in the region highlight the concerning current state of cumulative effects on wildlife corridors and that existing conditions are only going to get worsen in the future (TSMV, 2020). We understand that this is a small project, but – 80 per cent of the property is within the South Canmore Local Habitat Patch – and in a region where cumulative effects are already significant (Ford et al., 2020, Golder, 2020a, Golder, 2020b, Whittington et. al., in press) any further additional development only contributes to the existing significant cumulative effects.

While a memo, not an independent review as required by Policy 18.2.15, the MSES conclusion is clear. Too bad this document was not made easily available to the Canmore public.

Heather MacFadyen, Chair

Bow Corridor Organization for Responsible Development

 

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