Links
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2017 June draft plan:
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Shown here are links to the key documents:
In comparing the 1989 existing bylaw, the Cordova Strategy, and the draft interim plan, the first thing that becomes apparent is the increasing imprecision of the writing style, going from a plain declaratory mode in 1989 to a loose interpretive mode in the draft interim plan. The distinction is the existing bylaw gives clear direction to CRD staff that the public and the CRD Board can measure, whereas the draft interim plan is ambiguous, unclear and therefore subject to interpretation by staff who may make of it what they will. An example of this difference is Map 6 of the existing 1989 bylaw that shows the natural resource features of the park, and those features are clearly visible today. There is no equivalent map in the draft interim plan, yet those natural resource features are key to the plan.
Another example is the assertion by CRD staff that the draft interim plan contains the same commitment to maintain the drainage ditches for mosquito control that is in the current bylaw. Comparison of the language shows this not the case - the 1989 bylaw contains clear direction to CRD staff, but there is no commitment in the draft plan:
Current bylaw:
Policies:
(i) The CRD parks Department will cooperate with the Municipality of Central Saanich in preparing a drainage plan for the park. The purpose of this plan is to identify ways of improving the drainage system for purposes of alleviating flooding of private lands and controlling mosquito breeding sites.
(iii) The Regional Parks Department will keep all ditches in the park clear of debris. This will be included in the annual maintenance program.
The Draft interim plan
As with almost everything in the draft interim plan, to gain an understanding of the intent it is necessary to read the entire 66 pages and stitch together bits and pieces from different places.
p.48 5. Drainage Ditches
• Maintain the existing drainage ditch system and monitor its effectiveness in reducing mosquito habitat and its effect on the coastal wetland ecosystem.
p.55 ..... CRD Regional Parks supports adaptive management, and in that light, it may periodically review the interim park management plan to determine if any significant new information exists that would require a change to the policy direction or actions contained in the interim plan
p.6 Implementation of strategic priorities and actions will be contingent on available financial and staff resources .....
Interpretation? The "commitment" at p.48 is firstly subject to CRD staff not deciding that the ditches which have been there 76 years, are effecting the "coastal wetland ecosystem" something which is not identified in the plan and does not show in the 1989 resource features map. Then the "commitment" is subject to CRD staff not simply changing the plan under p.55. And finally is the coup de grace at page 6 - whenever they do not want to maintain the drainage system they simply say they do not have the finances or the staff resources to do the work. In other words, there is no commitment to maintaining the drainage system in the draft interim plan.
As shown, the language of the draft interim plan is so imprecise that to understand the intent it can be necessary to have to read the entire 66 pages and stitch together bits and pieces. Sometimes that is not sufficient and one must go back to the equivalent sections in the Cordova Strategy that was written in slightly clearer terms. And as is shown in the tab giving the review of the draft plan on the boat launch, it can be necessary to have to go to past correspondence to obtain intent.
- 1989 the existing park bylaw
- 2010 Cordova Strategy - a 5 year collaboration between CRD staff and the Tsawout
- 2011 the report of the one public meeting of March 16 2011 where the public told the CRD to leave the park alone
- 2013 draft interim plan.
In comparing the 1989 existing bylaw, the Cordova Strategy, and the draft interim plan, the first thing that becomes apparent is the increasing imprecision of the writing style, going from a plain declaratory mode in 1989 to a loose interpretive mode in the draft interim plan. The distinction is the existing bylaw gives clear direction to CRD staff that the public and the CRD Board can measure, whereas the draft interim plan is ambiguous, unclear and therefore subject to interpretation by staff who may make of it what they will. An example of this difference is Map 6 of the existing 1989 bylaw that shows the natural resource features of the park, and those features are clearly visible today. There is no equivalent map in the draft interim plan, yet those natural resource features are key to the plan.
Another example is the assertion by CRD staff that the draft interim plan contains the same commitment to maintain the drainage ditches for mosquito control that is in the current bylaw. Comparison of the language shows this not the case - the 1989 bylaw contains clear direction to CRD staff, but there is no commitment in the draft plan:
Current bylaw:
Policies:
(i) The CRD parks Department will cooperate with the Municipality of Central Saanich in preparing a drainage plan for the park. The purpose of this plan is to identify ways of improving the drainage system for purposes of alleviating flooding of private lands and controlling mosquito breeding sites.
(iii) The Regional Parks Department will keep all ditches in the park clear of debris. This will be included in the annual maintenance program.
The Draft interim plan
As with almost everything in the draft interim plan, to gain an understanding of the intent it is necessary to read the entire 66 pages and stitch together bits and pieces from different places.
p.48 5. Drainage Ditches
• Maintain the existing drainage ditch system and monitor its effectiveness in reducing mosquito habitat and its effect on the coastal wetland ecosystem.
p.55 ..... CRD Regional Parks supports adaptive management, and in that light, it may periodically review the interim park management plan to determine if any significant new information exists that would require a change to the policy direction or actions contained in the interim plan
p.6 Implementation of strategic priorities and actions will be contingent on available financial and staff resources .....
Interpretation? The "commitment" at p.48 is firstly subject to CRD staff not deciding that the ditches which have been there 76 years, are effecting the "coastal wetland ecosystem" something which is not identified in the plan and does not show in the 1989 resource features map. Then the "commitment" is subject to CRD staff not simply changing the plan under p.55. And finally is the coup de grace at page 6 - whenever they do not want to maintain the drainage system they simply say they do not have the finances or the staff resources to do the work. In other words, there is no commitment to maintaining the drainage system in the draft interim plan.
As shown, the language of the draft interim plan is so imprecise that to understand the intent it can be necessary to have to read the entire 66 pages and stitch together bits and pieces. Sometimes that is not sufficient and one must go back to the equivalent sections in the Cordova Strategy that was written in slightly clearer terms. And as is shown in the tab giving the review of the draft plan on the boat launch, it can be necessary to have to go to past correspondence to obtain intent.