Comment on the Draft Terms of Reference

Overview

The Study is important and necessary for a well-informed decision on how to proceed with protecting RNUP.

We support the draft terms of reference subject to the following qualifications.

Detail comments

1. Under Study Objectives and Scope Section 1.0.... "Future potential development activities''...of DRAP. The ToR should also include monitoring of current development activities such as the surveying and staking out land or potential clearing or bulldozing. Surveying has already been observed. Other forms of monitoring could be a watching brief for applications for building permits on the DRAP lands. These activities, some of which have already taken place signal imminent threats to the DRAP. (See also the last point under section 6.0)
2. Also under Study objectives and scope...."other potential effects".... It would be useful and helpful to:
   1. articulate spiritual values of the RNUP ... Raising the appreciation of flora and fauna to a moral and spiritual level as a source of reflection, awe, connection with the Creator. People go to RNUP and adjacent lands to commune with nature and development of DRAP lands would potentially affect this form of communion.
   2. use data on visitors to reflect the consequences of not protecting the lands. The socio-economic range of people who use the park, the different cultural backgrounds and the broad range of reasons - educational, recreational, spiritual, romantic, creative -for the use of the park, and the threats posed by adjacent development are values that deserve clear articulation.
   3. investigate the circumstances for the change in the Greenbelt (Were there agreements between the DeGasperis Corporation, which bought large swaths of the DRAP before the announcement of Bill 23)
3. While we understand the importance and necessity of having "a Secretariat to handle the administrative and technical aspects" section 3.0... there is sometimes a tension between the people who do the secretariat work and providing "the public with opportunities to participate meaningfully" in section 5.0. We ask for a clearer sense of what “meaningful participation” means. We suggest regular briefings of the framework of analysis…particularly
   1. how the report will integrate the sciences with cultural and spiritual values
   2. how the report will integrate science with the existing network of federal and provincial laws,
   3. research under way, interim findings
   4. issues of integrity of the commissioners and their meetings. (This is at issue because of the experience of David Johnston and the investigation into meddling with the 2019 election. There are developers who have huge financial interests in building on the land and it will be a matter of intense interest about whether they meet with the commissioners, when, and whether their conversation is a matter of record. Note that the loose coalition of people who oppose the development includes First Nations, Farmers, Environmentalists, Municipalities, people concerned with issues of homelessness and faith groups.
4. Under Committee Activities and Requirements Section 5.0 there is a section called Description of Existing Conditions the opening sentence reads "Identify, compile, review and present information on existing environmental, health, social and economic conditions within the Study Area." This should include "spiritual" conditions or ensure that the definition of "social" conditions includes eco-spirituality. As noted above eco-spirituality represents a particular form of participation in the RNUP and a form of personal worship.
5. Also in section 5.0 section g III Analysis of potential effects, there is a mandate to "describe any relevant avoidance, mitigation or compensation measures, which may address potential adverse effects." It seems that one solution is for the Federal government to acquire the DRAP lands, either by purchase or legislation and that this should be made explicit.
6. The Report and Records section 6.0 says, "The Committee will complete its work and submit its final Report to the Minister within 18 months of the public announcement of the appointment of its members. This is not 18 months from the date the minister announced the study or even from now, but “from the appointment of the committee members." That could be well into 2025. It seems that this timeline ignores the real threat posed by the current development activities above. The study should have either
   1. tighter timelines or
   2. a capability to respond to an existential crisis (bulldozers on DRAP lands) with an interim report or a temporary injunction