Editor:
As a former Banff resident and frequent visitor since 1994, I have continued to follow with interest the railway lands area redevelopment plan (ARP) process, most recently council's special meeting for the public hearing on March 20.
Reading the correspondence with the Town provided by the current Banff field unit superintendent Sal Rasheed is a jarring experience.
The Town flagrantly ignored the request by interim superintendent Kendra Van Dyk in her Aug. 20, 2021, letter to delay placing a draft ARP before the public until Parks Canada could determine whether it conforms with federal statutes, the Incorporation Agreement, and the Banff National Park management plan. It is beyond dispute that this clearance has not yet been granted.
More significantly, Parks Canada has clearly stated that an environmental review of an ARP is not undertaken until this conformance has been established and for good reason: if an ARP does not comply with federal statutes and legislation, it is a waste of time and resources to proceed further with it.
Town Manager Kelly Gibson in his letter of Oct. 6, 2023 to Rasheed provided a summary of council's multi-step process for approving an ARP, and then added: "It is recognized that Parks Canada would still need to make a determination on the scope and level of environmental review. ... Our understanding is that Parks Canada would then make a determination on the significance of any impacts based on the environmental assessment document and provide a description of appropriate environmental mitigations as required."
It is simply astounding that council and Town administration appear to believe that by passing an ARP, the Town would somehow nullify Parks Canada's assessment that every draft ARP to date has failed this conformance review, and that such passage would somehow oblige Parks Canada to ignore its own clearly stated procedures and move to an environmental review.
If the mayor and council barrel ahead with this apparent plan at the council meeting on April 22, 2024, continuing their pattern of ignoring clear guidance from Parks Canada, they will soon learn that this belief is mistaken.
The collective behaviour of the mayor, Town council, and Town manager in treating Parks Canada as some sort of junior advisory partner in this matter is now approaching malfeasance. They would be well-advised while contemplating their next actions to carefully consider both the Banff field unit superintendent's most recent letter, as well as the comprehensive legal opinion provided by Shores Jardine, urging collaborative development of "win-win" scenarios.
Marc Ryser,
Concord, Massachusets
