Banff Railway Lands ARP

(for the full submission, or the transcript of what we said at the hearing on March 20, 2024 click away)

Summary

The Bow Valley Naturalists are dedicated to protection of ecological integrity and the sharing of information about natural systems. Since 1967 we have been active in Banff National Park and the surrounding landscapes by participating in public planning processes, providing educational activities and conducting two of the longest running citizen science projects in the mountain parks. All our 290 current members care deeply about protecting natural ecosystems and include dedicated naturalists, scientists, natural history interpreters and environmental assessment specialists. Many of our members have spent their professional careers in the field of protected area management. BVN has provided comments on innumerable environmental assessments, policy proposals and management plans throughout our 57 years as an organization. We are pleased to submit these comments on the Banff Railway Lands Area Redevelopment Proposal. 

The following points are offered as an overview and summary. More detailed comments and questions for Town of Banff Council

Bow Valley Naturalists’ Response to Railway Lands ARP: An Overview The Bow Valley Naturalists (BVN) are dedicated to the protection of ecological integrity and the sharing of information about natural systems. Since 1967 we have been active in Banff National Park and the surrounding landscapes by participating in public processes and providing educational activities. Our 290 members care deeply about protecting natural ecosystems and include dedicated naturalists, scientists, engineers, natural history interpreters and environmental assessment specialists. Many of our members have spent their professional careers in the field of protected area management. BVN has provided comments on innumerable environmental assessments, policy proposals and management plans throughout our 57 years as an organization. We are pleased to submit these comments on the Banff Railway Lands Area Redevelopment Proposal.

1. This ARP Should Not Proceed BVN requests that the ARP not proceed any further in the Town of Banff’s approval process. This is due to fundamental problems relating to unresolved questions and a lack of recent data relating to the understanding of site-specific ecosystem components and the absence of any new infrastructure that addresses the need for a public transport hub. Approving this ARP will remove future opportunities to use the available land for essential transportation hub infrastructure and add to the cumulative negative environmental damage associated with decades of development in the Banff townsite, including destruction of an rare landform.

2. Press Pause: Too Much All at Once This plan should be paused because the Banff townsite area, and its community, are overwhelmed with too many other inter-related projects occurring at the same time with no understanding of how these projects interact. More time is needed to understand how planning for the railway lands fits with other plans. Foremost is the need to complete the Community Plan review process which guides planning for the town. Additional interactions between this proposal, planning for Banff Avenue Square, the Lake Minnewanka area, the Mountain Avenue redevelopment, the Banff Avenue pedestrian zone, planning a phased, integrated approach to moving people in Banff National Park and mapping and planning for the restoration and protection of montane wetlands surrounding the Banff townsite need to be considered together along with how they cumulatively affect the community.

3. No to the Gondola The proposal for a gondola, aspirational or otherwise, has no place in a plan proposed by the Town of Banff operating under an incorporation agreement with Banff National Park which does not support gondola. The ARP clearly relies on gondola infrastructure across unleased lands in a national park as part of its long-range plans. In essence, through this ARP proposal, the ski area is requesting to use land for its own purposes outside of its negotiated agreements with the Government of Canada to “secure its future”. It is our opinion that this is clearly in contradiction with the Mount Norquay Long Range Plan, the Park Management Plan and the Ski Area Guidelines.

4. There is No Infrastructure Proposed That Will Support Future Public Transit Needs This ARP is essentially a proposal for the accessories to public transport that will occupy valuable lands that might provide future opportunities for meaningful public transit solutions and infrastructure. This ARP is promoted as addressing the need for public transport. Yet, there is nothing in this ARP that proposes any new infrastructure for public transportation, aside from moving bus stalls to the other side of the railway tracks. Nor does the ARP leave any land available for that infrastructure.

5. More Parking for Private Vehicles, No Meaningful Solutions For Banff National Park The current trend is to reduce private vehicle parking in the mountain national parks. By focussing attention on providing another parking lot, this proposal reduces the incentive for meaningful thinking about real public transportation solutions and alternative land use options for the railway lands that may be required to facilitate those solutions. In the mean time, valuable montane ecoregion habitat components will be further degraded.

6. It is a Functioning Wildlife Corridor – Leave it Alone To improve wildlife movement in the lands adjacent to the Town of Banff we have seen the removal of the bison paddock, closing the airport, closing the cadet camp, removing the wildlife lab, moving the horse stables and constructing numerous highway crossing structures. This proposal threatens to step backward and compromise these efforts by proposing to build a new parking in an important but already constricted and vulnerable wildlife movement corridor based on an experimental concept. That concept is not based on thorough examination and discussion current data relating to the Fenland wildlife movement corridor.

7. No More Development North of the Tracks Further development on the North Side of the railway tracks is not consistent with protecting ecological integrity or the natural heritage of the Banff townsite. The need for reclamation has been recognized through this ARP process. That reclamation should be undertaken, based on its own merits and not as part of a trade-off to support more development.

8. Now is the Time for Maintenance and Restoration This ARP further perpetuates a 140-year legacy of cumulative negative impacts on Banff National Park’s ecosystems in the interest of developing the townsite. With greatly improved understanding of ecosystems, now is a time when the Town should be looking for opportunities to compensate for past harms rather than justifying ways to mitigate more cumulative harm. Protecting ecosystems is always a collective gain.

9. And Then There’s the Town of Banff Environmental Master Plan The Town of Banff should be proud of its Environmental Master Plan. This plan speaks to the need for maintenance and restoration of ecosystems and is a model for other municipalities to follow as they plan for sustainable communities. Those who developed this plan should be proud of their work. And so, we are perplexed that much of this ARP proposal seems in contradiction to that plan and is based on superficial understanding of the site-specific ecosystem with promises to only protect important environmental values “if possible”.

The ARP should go back the office and be discussed through the lens of the Environmental Master Plan to assess if this proposal is really what is best for the community.