river valley Planning modernizAtion
Action Needed
Please read the update below and let council know your thoughts. A template letter for your consideration is here.
The draft Ribbon of Green Strategic Plan, and River Valley Area Redevelopment Plan (ARP) will be coming to the Urban Planning Committee on Tuesday, September 17. Administration will present the drafts that they presented at Stage 4 engagement, along the with the What We Heard report for stage 4. These drafts do not incorporate feedback from the public received during Stage 4 engagement – we’ve heard that administration plans to make new drafts available early in October. (It is regrettable and that the new drafts are not to be provided in advance of the Urban Planning Committee meeting.)
We have a small team working with administration on the detailed work to make improvements to the policy statements in these documents. At a higher level, we have a few main concerns that we would like to bring to your attention:
1. The current draft Ribbon of Green permits mountain biking in preservation areas. This represents a departure from (ecologically sound) policy and practice with respect to preservation areas for the last 40 years, in which mountain biking is prohibited in preservation areas. We would like to see city council continue to uphold the preservation area policies we have historically implemented on this issue. In sensitive ecologies, mountain biking and trail building results in habitat fragmentation, disruption to bird nesting and animal denning sites, and erosion, as well as enables encroachment of plants the city considers to be invasive non-natives. Please write to your city councillor to explain why you see that prohibiting mountain biking in preservation areas is important and does not unduly restrict mountain bikers’ use of the river valley. Include your perspective on how mountain biking is sufficiently accommodated in the river valley using city-sanctioned trails through conservation areas, as councillors will be looking for this rationale when making their decision on whether or not to support our position. You can review the draft Ribbon of Green here: https://www.edmonton.ca/sites/default/files/public-files/Draft-RibbonofGreen-StrategicPlan.pdf?cb=1725379627
2. In our view, the current draft River Valley ARP does not include provisions for a clear, fair and transparent decision-making process for when development applications within the river valley are brought forward – something which was requested in stage one of engagement according to the What We Heard Report. The “deemed essential” language, instead of being clarified, was removed from the new draft, and we don’t see what has taken its place. The draft does not outline how stakeholders will be informed of development proposals, nor does it stipulate how potential impacts, including cumulative impacts, will be measured and presented to the public to inform decision making. Requirements for when a development proposal is required to go to a council for a public hearing are significantly weakened, requiring only the largest and likely extremely rare projects to be subject to public debate. Please write to your councillor and / or to the Urban Planning Committee (Councillors Janz, Rice, Rutherford, and Wright), to tell them why you consider a robust public engagement and public hearing process to be crucial to how we plan for the river valley, and share your concerns with the lack of clarification of “essential” development. Include your thoughts on what questions you would be asking of administration if you were sitting in their seat. You can review the ARP here: https://www.edmonton.ca/sites/default/files/public-files/Draft-RiverValley-AreaRedevelopmentPlan.pdf?cb=1725306166. (It’s much shorter than the Ribbon of Green).
We encourage citizens to write to the mayor and city council regarding the items in bold above. Emphasize that you want to see more protection for the river valley, and that as our city grows, protecting the river valley as a wildlife corridor and natural area for people to respectfully connect with nature in the heart of the city will only become more and more important.
Reach Council and the Mayor here.
Archived River valley Planning Modernization news Up to July 9 2024
River Valley Modernization stage four engagement (Confirm our Ribbon) has now closed and a “what we heard” report will be available in the fall. ERVCC is requesting that written feedback be allowed to continue. We will let you know if we are successful.
The Draft RIbbon of Green Strategic Plan and River Valley ARP will be going to Urban Planning Committee in September 2024, and to Public Hearing in December 2024.
We support the strategic vision and principles expressed in the Ribbon of Green, with only a few caveats. The ARP however, is the Statutory Plan, and unfortunately, we cannot endorse the ARP as it is currently drafted. We believe that if the ARP were passed as is, protections for the river valley would be significantly weakened, whereas opportunities to update the bylaw to reflect new developments in ecological understanding, planning for urban biodiversity, and decolonization since the ARP and RoG were first passed in 1985 and 1992 are missed.
What follows comprises a summary of our main concerns with the draft ARP:
The definition of “open space,” the primary land use for the new ARP, includes uses such as cemeteries, civic squares, pedestrian oriented streets, school yards, and institutional campuses, among others. Why would these uses be permitted on the majority of river valley lands? This appears to be a significant change from the previous bylaw which restricted uses to natural areas and low-impact recreational uses.
The bylaw is worded so that hardly any proposed developments would have to go to council for a review, let alone a public hearing. For instance, a council review and strategic assessment would be required for “intensive” open space, transportation, or utilities facilities, but these are defined to be greater than 20,000m2 for open space, and greater than 500m2 for transportation and utilities facilities, so anything smaller than that requires no oversight. For another example, the deemed essential clause was dropped, eliminating another avenue for council oversight.
The land use policies use non-committal language, such as “should” rather than “shall” and “discouraged” rather than “not permitted,” and includes no environmental protection policies, but only human use policies. This language does not provide any grounds to hold municipal actors accountable to the principles outlined in the Ribbon of Green, or in Edmonton’s higher level strategic documents such as Connect(Ed)monton and Breathe.
The document contains no provisions for a fair and transparent decision making process that takes into account studied impacts of development and community and stakeholder feedback, despite this being a top priority based on comments received in the public engagement sessions.
The document contains no provisions for how the policies will be implemented.
How you can help
ERVCC will add our postion paper here as soon as it is completed and we will post a campaign here to help you lobby your city councillors for a stronger River Valley Bylaw.
In 2021, the City began a process of “modernizing” river valley planning, focusing on “updating” the 1992 Ribbon of Green planning document and the 1985 River Valley Bylaw (also known as Bylaw 7188 or the River Valley Area Redevelopment Plan). ERVCC supports the tightening-up of these documents for clarification (what, for example, is the definition of “major public facility” in the River Valley Bylaw?); however, we do not understand what “modernization” means in the context of this project and are concerned that the plans are being changed to align with development pressures in the river valley, rather than the plans, as they exist, guiding decision-making and protecting the river valley from those pressures in the first place. ERVCC has raised these concerns with the City while continuing to participate in the process to help ensure that any changes to these plans leads to more, rather than less, protection of the river valley. The ecological integrity of the river valley as a wildlife corridor, habitat, and greenspace undertaking “ecosystem services” in cooling the city and helping to protect the city from drought and flooding is critical in this time of climate and biodiversity crisis. ERVCC also sees a major opportunity for Edmonton to undertake genuine decolonizing work through a changed relationship with the river valley – one that recognizes the colonial history of this place and the importance of learning from local Indigenous ways of knowing to see the river and all the other beings here as our kin, to whom we should show gratitude, care, respect, humility, and reciprocity. The river valley does not simply exist here to serve us.
Between 2000 and 2015, Edmonton lost 75 acres of river valley land yearly to development. Loss of another 130 acres has occurred with construction of the Valley Line LRT and the E.L.Smith solar farm. With U of A law students, ERVCC did a gap analysis of current regulatory oversight of the river valley and determined that what few park protections exist are extremely weak. We need to stay vigilant and strengthen our river valley bylaw.
New trends in Environmental Impact Assessments are emerging and we are working . The whole concept is becoming substantively and procedurally criticized and we are working to ensure projects that don’t belong in the valley are screened out early. Projects like the Gondola need not be revisited. We suggest this reading list on Decolonializing Conservation.