Update - 3 March
+ Liberal Party critic of Canadian Heritage Stéphane Dion on Feb 26 came out against the location of the memorial (Ottawa Citizen, Feb 27). An article printed on Feb 27 also disclosed that the designers had slightly reduced the size of one part of the memorial. Available on the web site is a pre-press conference article dated Feb 24.
+ In response to a question by MP Paul Dewar, the Parliamentary Secretary to the Heritage Minister, Rick Dykstra, denied that there had been no consultation. The article appeared only in print, on Feb 28.
+ The CBC's The National on March 1 had a story (2'14"), with clips from Shelley Glover, Toon Dreessen, Paul Dewar, Stéphane Dion and Pierre Poilièvre.
Patrick Cardiff, Economist at the Bureau of Economic Analysis, comments:
Shah Haq's paper is fine. I think his biggest contribution to the literature is to set land-use pressure to the European context. The premises, well-thought-out exposition and conclusion are fine. However, I would like to see more empiricism - proof of the assumptions from actual data - than is shown. He seems to be merely repeating what is expected, that is, the obvious. He defines green space adequately, and notes comparisons of some cities' green space sizes in Europe. But I don't see anything new here.
Whenever you have multidimensional benefits (or costs) you lose the conclusions from not controlling for one or more of the competing or conflicting effects. It's impossible to interpret, infer, because you don't know which effect is most prevalent. The study cries out for, at minimum, the development of a green spaces index, that would rank, codify and weight the various amenities that Mr. Haq STATES that green spaces provide - namely, "The important roles played by green spaces are social, economic, cultural and environmental aspects of sustainable development." Then also, the problems of land competition and use are so site-specific that one cannot standardize the findings as "lessons learned." Truly the competition for free public land is a reverse NIMBY issue often, and these can differ completely, even 5 miles apart! Wikipedia has a nice piece under the descriptor "Land use conflict."
I would think in order to prove the value of green space to cities it would be necessary to fix that (those) value(s) against competing interests, such as the building of schools, and then to try to tease apart the weighted effects (at least), so as to interpret outcomes in a rank procedure of benefit importance, all the while taking into consideration how WELL you measure.
Otherwise this is a reasonable primer for the problem in a European setting.
The deadline for comments was pushed back to March 6, 2015.
On February 16, the Greenspace Alliance sent in the following comment:
Congratulations to staff for expressing common sense rules which construction personnel should abide by in the interest of protecting wildlife for which the construction site was habitat. We wholeheartedly agree with its Conclusion on page 13 that "By following this protocol, developers should be able to reduce construction-related impacts on Ottawa’s wildlife, and help the future occupants of their buildings to avoid problems with wildlife in the longer term."
We do note that, if endangered species are not present, respecting the rules is only required "where possible." As in so many other instances, interpretation of the rules during the review process and enforcement of the rules afterwards are key. The appropriate allocation of City resources needs to accompany the approval of this Protocol, including training of planning staff. Staff has to have the capacity to ground-truth a proponent's existing conditions report and in doing so should invoke the assistance of local residents who often have an intimate knowledge of the area involved. Proponents should be encouraged to do likewise.
Also accompanying approval of this Protocol should be an information campaign aimed at the general public so people know what to do if they observe something amiss.
We especially commend the "nudge" to the construction industry to better wildlife-proof buildings (para. 2.7) and to prepare an Owner Awareness Package (para. 2.8).
On the process:
+ We trust that the consultation process on this Protocol will proceed and be reported on in a transparent manner. Weighing of considerations by stakeholders who do not express their comments on the record is not consistent with the City's policies as we understand them and are in any case not consistent with principles of a democratic society.
+ We understand that this Protocol is destined for Planning Committee and we agree with that, given that the key strength of this Protocol is that it will become part of the development review process. We understand it may also be sent to Agricultural and Rural Affairs Committee. While of course some construction takes place in rural areas, the large majority of situations where this Protocol would come into play is typically within the urban boundary. Still, that may be enough ground to send it to ARAC for consideration. Above all, however, this Protocol is a wildlife protection issue and should also be considered by Environment Committee.
On the substance:
+ The Protocol should also apply to City projects.
+ The "sensitive timing windows" are provided for guidance only (p5-middle) and Table 1 does identify the general breeding and hibernation periods. We suggest that, in addition, the protocol explicitly state that animals cannot be disturbed when in hibernation or accompanied by young. Given the drawn-out schedule of a typical development process it should be quite feasible for developers to select the appropriate window (late summer to early fall) to clear a site of wildlife.
+ On p9-middle, it may be wise to specify what the "applicable laws" are that govern relocation of wildlife.
+ In the spirit of section 3(5) of the Planning Act (*), it would seem possible to have the Protocol apply to projects that have already been draft-approved, since final approval has yet to be given. If the PPS can be applied retroactively, so should City policies.
+ Reading para. 2.8 it is not clear why, earlier in para. 2.1, it is stated that the Draft Owner Awareness Package is part of the Wildlife Mitigation Plan "where required." It appears to be always required, regardless of who will occupy the building.
+ While we agree with the scope of the application of the protocol as stated in para. 1.1, we suggest that, in para. 2.4 (p9), the scope may be stated too loosely where it says that "Any occupied (or potentially occupied) trees/features should be flagged..." Clarification of "potentially occupied" would resolve the ambiguity.
for the Greenspace Alliance of Canada's Capital
(*) Section 3... (5) A decision of the council of a municipality, a local board, a planning board, a minister of the Crown and a ministry, board, commission or agency of the government, including the Municipal Board, in respect of the exercise of any authority that affects a planning matter,
(a) shall be consistent with the policy statements issued under subsection (1) that are in effect on the date of the decision; and
(b) shall conform with the provincial plans that are in effect on that date, or shall not conflict with them, as the case may be. 2006, c. 23, s. 5.