Last Chance for Corridors in the Bow Valley: Say "No" to the Three Sisters Mountain Village Plan

From: Dave Poulton, Executive Director
Calgary/Banff Chapter, Canadian Parks and Wilderness Society

Below is an important Action Alert from Heather Macfadyen respecting the current development plans of Three sisters Mountain Village. The maintenace of functional wildlife corridors through the Bow Valley has been a major focus of the work of CPAWS and other conservation organizations for many years. As Three Sisters has the opportunity to develop the single largest piece of undeveloped land in the valley, stretching for 13 kilometres along the west side of the valley between Quarry Lake and Wind Valley, the pattern of development they choose to follow is critical to the future of wildlife movement. Please take the time to write a letter and to attend the public hearing on August 17.

Coming to a public hearing on Tuesday, August 14, 2004
Write or make a verbal presentation:

Town of Canmore
902 - 7th Avenue
Canmore AB T1W 3K1
E-mail: [email protected]
Fax: 678-1524

"NO" to compromising the functionality of the primary multi-species wildlife corridor that has already been reduced 50% from the Alberta government's own standards for wildlife corridors in the Bow Valley.

"NO" to allowing this development to proceed until the progression of land uses in the 2002 Golder Report (page 44) are followed, with the primary corridor and buffer adjacent to the golf course, large 2-4 acre unfenced lots below the golf course, and only then a low density development (page 44).

"NO" to any further development until TSMV establishes and protects all of the 13-kilometre primary multi-species wildlife corridor connecting the two G8 Environmental Legacy wildlife crossing structures designed to allow free movement of wildlife through the Bow Valley from Banff National Park to Wind Valley and under the Trans Canada Highway at Dead Man's Flats.

All Canadians paid for this G8 Legacy gift to the Bow Valley and we need to see this promary corridor work!

FOCUS: The Area Structure Plans for the TSMV Resort Centre and Stewart Creek

The Town of Canmore is presenting a Public Hearing on the Area Structure Plans (ASPs) for DC Sites 1 & 3 +"R", and Sites 2B, 5 and 6 for development of the Three Sisters Mountain Village on (TSMV) Tuesday, August 17 at 6:00 PM at the Canmore Seniors Drop-in Centre.

These ASPs are important because the area to be zoned includes a key segment of the functional wildlife corridor system connecting Banff National Park to Wind Valley, as required by the 1992 Natural Resources Conservation Board (NRCB) decision. It is essential that we all make sure that all of the recommendations for functional wildlife corridors are followed as stated in the 2002 Golder Report agreed to by the Town of Canmore and TSMV.

Sample letter, points for the public hearing and background:

It is important to attend the Public Hearing on August 17 and/or to submit a letter to Canmore Town Council opposing the two Area Structure Plans (ASPs).

Sample letter

Individually worded letters are likely to have more weight than multiple copies of the same letter. However, a brief sample letter follows. Begin with a word of thanks to the Mayor and Council for their initiative in setting up the Wildlife Corridor Review and the resultant Golder Report and taking the lead in establishing functional wildlife corridors on the Three Sisters property.

Mayor Glenn Craig and Members of Canmore Town Council
Canmore Town Hall
902 7th Avenue
Canmore AB T1W 3K1

re: Public Hearing XX on the Area Structure Plans (ASPs) for Three Sisters Mountain Village (TSMV)

Dear Mayor Craig and Councilors:

I write in opposition to the two proposed ASPs for the Three Sisters property, and urge Town Council to reject these plans and insist that revised plans be developed which adhere exactly to the 2002 Golder Report requirements for corridors, buffers and land use zoning. In addition, I would urge Council to insist that a functional Along Valley corridor be defined for the entire length of the TSMV acreage, and reviewed by a truly independent wildlife biologist, before approval is given to such revised
ASPs.

I am appreciative of the efforts that Canmore Town Council has made to ensuring that the Three Sisters land includes functional wildlife corridors. As you are aware, the Golder Report did not apply the current standards for corridors defined by the BCEAG guidelines, but did suggest that its corridor would be functional so long as the associated land uses were followed. I am shocked that the proposed ASPs do not incorporate these land uses, which are essential if the wildlife corridors are to be functional.

I view the proposed ASPs as unacceptable, and urge you to reject them.

Yours sincerely,

Verbal Presentation (with a written copy for Council)

Ask Council to reject the TSMV proposal because:

1. To accept it would be a breach of the public faith after a 4-year consultative process with the public since the new ownership of TSMV, and a 12-year effort by the Canmore and Alberta public to see that the 1992 legal conditions and undertakings of the Natural Resources Conservation Board (NRCB) are met.

2. This latest planning proposal by TSMV is a compromise of a compromise. Both the Town of Canmore and TSMV agreed to abide by the recommendations of the 2002 Golder Report, which, since the primary along valley corridor was reduced from the 1150 metres required by the provincial government's Bow Corridor Ecosystem Advisory Group (BCEAG) standards, relies on a strict adherence to ALL of the land use recommendations in this report.

3. Canadians have endowed the 13-kilometre TSMV primary corridor with two wildlife crossing structures to assist wildlife in a safe passage under the Trans Canada Highway at Dead Man's Flats east of Canmore and over the Rundle Forebay west of Canmore into Banff National Park. BCEAG standards have been applied by provincial government biologists to demarcate the Wind Valley section of the TSMV primary along valley corridor. The 'Golder' segment of this corridor should not be compromised by less functional standards. If the Golder land uses are not strictly followed for all sites proposed, including the Stewart Creek area, this national corridor will not be functional.

4. In his May 2004 review of TSMV's Area Structure Plan, Michael Raine gave qualified approval to TSMV for meeting some of the 2002 Golder recommendations for functional wildlife corridors. It is difficult to see how Raine reached this conclusion since his 2004 review indicates so many serious problems in the location and density of development at the Area Structure Plan stage, and so many wildlife management problems that neither the primary nor along valley corridor will remain functional for wildlife. (Raine's independent judgement is in question as his firm of Golder and Associates works for the developer on undermining issues on their property which are also part of these area structure plans.)

FURTHER, AS RECOMMENDED BY GOLDER (2002) AND THE BCEAG GUIDELINES:

5. Insist that all corridors "be bordered by a conservation easement buffer of 35 m width within which no activity other than thinning for fire control should be permitted" (Golder 2002).

6. Insist on a 35 metre buffer along the Stewart Creek section of the along valley corridor, with nothing less than large acreages adjacent to this corridor.

7. Insist on no human activity in the wildlife corridors, as recommended by the Bow Valley Ecosystem Advisory Group (BCEAG) Guidelines on Human Use in Wildlife Corridors. This is to ensure human safety and wildlife survival

8. Insist on enough detail in these area structure plans now (which Raine admits require review in all areas) so that the public can make a cumulative assessment of all this development on Canmore and its environment BEFORE it is approved. At present the development plan relies on enforcement of use, which is ineffective at best.

AFTER WILL BE TOO LATE.

9. Insist that Golder's (2002, page 43) recommendation that "High and mid-density use should not be situated next to the easements" (corridor plus buffer) be followed. The proposed ASP is contrary to the "layered" land use recommendations and presents wildlife management problems.

For these reasons say -

"NO" to the "resort accommodation" which Raine states "would be similar to a hotel backing onto the corridor easement" in Area C.

"NO" to the Boutique Hotel(s) - there may be more than one adjacent to the corridor in Area D.

"NO" to the 18-acre resort island in area E where Raine says "the density of the accommodation is higher than was previously anticipated" and "could be a problem from a wildlife management perspective".

"NO" to the "up to 50 cabins" of undisclosed size in the "golf recreation area"that Raine notes were not part of the Golder 2002 Report, and "will pose a problem with human-grizzly bear conflicts".

"NO" to the pod of development in the golf course and near the primary multi-species corridor.

IN ADDITION ASK FOR:

1. A copy of the Conservation Easement Agreement between the Town of Canmore and TSMV be made available to the public before the Public Hearing on Sites 1, 3+ "R", 2B, 5 and 6, and make sure that all references to a walking trail in or adjacent to the corridor buffer are removed (4.03, 6.03, 6.04).

2. An agreement between the Town of Canmore and TSMV for perpetual funding for maintaining functional wildlife corridors prior to the Public Hearing.

3. A conservation easement on the Stewart Creek Golf Course and an adjacent 35 metre buffer area, with the Golder principles for a layered progression of land use, with large acreages next to the golf course, followed by low density use.

4. Reclamation of the tipple site in the across valley corridor.

IN SUMMARY:

IF TSMV DOES NOT MEET ITS LEGAL OBLIGATIONS UNDER THE 1992 NATURAL RESOURCES CONSERVATION BOARD (NRCB) DECISION, THE 2002 GOLDER REPORT OR THE PROVINCIAL BCEAG STANDARDS:

SAY "NO" APPROVAL TO ZONING until TSMV has put an integrated corridor plan in place which protects all of the 13-kilometre primary, multi-species Along Valley Corridor, including the widening the connect with the Stewart Creek Golf Course part of the corridor, the current disconnect with the Wind Valley part of the corridor, and the inclusion of the Wind Valley segment of the corridor as mapped by the Department of Sustainable Resource Development using BCEAG standards.

Why?

This zoning is an essential step in the process of establishing functional wildlife corridors on the TSMVproperty and is the appropriate Town policy. The draft 2003 Conservation Easement Agreement proposed by the Provincial Government does not protect 80% of the 35 metre buffer zones essential to the functionality of the wildlife corridors and recommended by the Golder Report. To compensate for this failure, the Town of Canmore Land Use Bylaw Amendment 22(Z)2003 zoned as WC (Wildlands Conservation) all of the Golder-recommended areas for minimum effective wildlife corridors, including all of the buffer areas. It is proposed that the east buffers left out of the Provincial Conservation Easement Agreement will be protected (1) by this WC zoning and (2) in a separate conservation easement agreement between the Town, TSMV and a neutral conservation partner.

Background: The 1992 Decision of the Natural Resources Conservation Board (NRCB) on the proposed TSMV development imposed a number of conditions and undertakings on TSMV including the provision of wildlife corridors "in as undeveloped a state as possible" on the property. In the fall of 2002 the Golder Report was released, setting out 'minimum effective wildlife corridor widths' for both the primary and secondary corridors on Site 1 + Site 3 + Area "R" (the part of Site 2B west of Three Sisters Creek) of the TSMV property.

The Golder Report had been agreed to by the Town of Canmore and TSMV after long and sustained public pressure in recognition of the non-functionality of the previously proposed corridors. This included the primary (along-valley) corridor which the Alberta Department of the Environment had defined in the 1990's, and the two secondary (across-valley) corridors in the Conservation Easement Agreement between TSMV and the Province which was proposed in 2000. These corridors had not been based on reliable scientific evidence, and the 2000 study by Herrero and Jevons had clearly demonstrated that they were inadequate in terms of width, slope and cover. It will be remembered that the proposed secondary corridors included significant portions of golf course; a study by the Miistakis Institute determined that golf courses do not make wildlife corridors.

The Golder Report recommended redefined corridors on the Sites 1+3+R parts of the TMV property including a primary corridor with an effective minimum width of 635 metres (a 610 metre corridor plus a 35 metre buffer) and one secondary corridor with an effective minimum width of 480 metres (a 410 metre corridor plus 35 metre buffers on each side). These effective corridors were to be covered by Conservation Easement Agreements to ensure the protection of the corridors. The Golder report also included land use recommendations for development adjacent to the corridors, with golf course abutting the corridors followed by large-lot housing followed by other low-density uses.

In April 2003 a new draft Conservation Easement Agreement between TSMV and the Province (as represented by the Department of Sustainable Resource Development) was released. This Agreement covered the corridor areas as set out in the Golder Report, but only a small part of the buffer zones (those on the west side of the corridors), leaving approximately 80% of the proposed buffers outside of the Agreement.

The Bylaw Amendment, therefore, is an essential step in the process of establishing functional wildlife corridors on the TSMV property and is the appropriate Town policy.