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New Video Clips:1. Bruce talks about the SIA Application 2. Bruce's Analysis of the CVRD Report on EcoDepot Response Letter to CVRD from Ministry of EnvironmentDownload pdf of Response Letter to CVRD Announcement of Meeting June 26, 2012 File: PR-105809 Mr. Warren Jones Dear Mr. Jones: Re: South Island Aggregates Application for an Authorization to Discharge Waste We acknowledge receipt of your letter dated June 18, 2012 sent on behalf of the Board of the Cowichan Valley Regional District (CVRD) requesting an extension of the Public Consultation period until November 30, 2012. Even though the Public Consultation process was initiated on May 10, 2012, South Island Aggregate (SIA) application is still under consideration as of today, June 26, 2012. Additionally, the request made by Dr. Bruce Fraser, Director of electoral Area B of the CVRD, to hold a public meeting on the SIA application following the proponent's Open House of May 31, 2012 has effectively extended the Public Consultation period as the outcomes of that meeting will have to be included in the Consultation Report. Considering the above information and the fact that the latest draft Technical Assessment Report is not yet available for review, it is very likely that the consultation period will remain open for some time yet. In regards to the CVRD Board request for a moratorium on the SIA application, the Ministry of Environment (MoE) has no legal authority to place a moratorium on applications and has a legal obligation to consider the application from SIA.
MoE will continue to consider requests received from stakeholders, and seek further clarification as needed to ensure the concerns can be addressed through the application process that is currently underway. Please do not hesitate to contact me as needed at 250 751-7245. Yours truly, Luc Lachance, P. Eng cc: Mr. Jim Hofweber, Executive Director, Environmental Management Branch, Ministry of Environment (Jim.Hofweber@gov.bc.ca )
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Ecodepot Report
Good Idea, Faulty Method, Wrong Place
The Regional District was attempting to follow through on its important “zero waste” goal by addressing a gap in waste management in the south Cowichan area. It proposed to establish a public recycling facility and proceeded to make it happen by having a facility designed and selecting a suitable location. This otherwise laudable objective was derailed, despite what the Board and staff believed was proper due diligence, by the public reaction to being surprised with a site location in an area they believed to be inappropriate. This initial problem only grew over time as the opposition became more organized and the CVRD redoubled its efforts to justify the site using hundreds of thousands of dollars of public funds to counter public resistance from those most affected by the chosen location. The CVRD efforts to provide for local consultations, to conduct site suitability studies and to engage the wider south Cowichan public were thwarted by the fact that the site selection had been made in secret, that the site purchase was already completed and that no indication could be given that other options were possible. The “decide, announce and defend” approach met a classic, predictable and ultimately successful resistance. The right approach to such a circumstance is to admit error, repair to the extent possible and move to prevent similar errors in the future. The report appears to be oriented toward justifying the extensive and expensive CVRD efforts and questioning the legitimacy of the opposing efforts of the local Cameron-Taggart residents. It suggests that success might have been achieved if the “after-the-fact” communication efforts were even more substantial, and in doing so demonstrates that the most important lesson has not been learned.
“We Goofed”: Admit Error, Repair and Improve
The best professional advice in such circumstances has been known for a long time.
As a Board, we should be saying right at the outset:
“We made an initial mistake in the DAD approach to site selection and we compounded it by dismissing the opposition as misguided and by trying to overcome their objections. We acted in good faith following the in-camera procedure for land matters, we thought we were being diligent with the extensive further studies, communications and consultation we commissioned, but they only added fuel to the fire that we had initially created. We mistakenly spent a lot of public money, staff time and Board effort in the process and we now intend to recover as much of that as possible. We learned an important lesson in public process and commit to improving our approach in the future”.
Analysis
Report Structure
The draft report structure does not lend itself to a clear explanation of what happened. It mixes the rationale for an Ecodepot and the CVRD’s due diligence actions with the problems of siting in such a way that it is hard for the reader to tell what the CVRD believes was done incorrectly and what was justified.
Process
The Ecodepot project failed for well-known reasons, very familiar to practitioners of public engagement.
The site was selected and purchased in secret, then announced to local residents. Because of confidentiality requirements, the Board could not provide transparent reasons for why the site was considered best of a series of undisclosed options and then the CVRD went to extraordinary lengths to justify the decision – the process known in the trade as DAD – decide, announce and defend. The project was lost right at the beginning and no amount of after the fact justification could salvage it. Continuing investment in technical studies, communications about the conceptual plan, advisory committees, First Nations consultation, agency liaison, exhortations about the need for a facility or praise for the site was ineffective. It was seen and characterized as a combination of CVRD determination in the face of opposition and expensive “spin” using copious amounts of public tax money to overwhelm local objections. In effect it was seen as “throwing good money after bad” in the eyes of the directly affected residents. The report goes to great length to illustrate what in the right context would have been good and thorough work, but in the DAD context turned out to be wasted effort. Acknowledgement of this problem is included in the report, but is scattered in the document rather than receiving the prominence it deserves.
It is useless to argue that the communication and outreach effort was insufficient, that inadequate use of social media contributed, that the technical studies did not happen swiftly enough, that factual information was late, that early referendums would have been more effective, that the opposition used underhanded tactics to characterize the facility as a dump or that the public was negatively disposed toward recycling. None of these are relevant. The battle became one of the “surprised and ignored local residents being bullied by a government that had already made the unilateral decision to select a site despite those affected believing that the site was not appropriate”. That is the reason for “sustained opposition”. That is the reason that all the subsequent diligent work was for nought. That the local residents won is entirely commonplace.
A more effective model of project development would go something like this, with the affected public engaged at every step:
Too much of the review is focusing on perfectly respectable methods that were unfortunately employed after the “horse was out of the barn”. That is the reason they simply did not work, not that they were inherently faulty. They would only have become relevant and useful if the process had avoided the classic DAD pitfall in the first place. The consultation, communication and technical study methods are not at fault and do not need extensive future repair, with the exception of the so-called “triple bottom line” assessment that was said to have been carried out for the chosen site, but for which there is no published record. The technical study efforts were hopelessly compromised by the initial site selection process. The report should have admitted this up front, but instead it will look like the CVRD is continuing to justify their efforts, long after the fact – in other words the CVRD would appear to be continuing in the mode of the last D in DAD. This will invite the criticism of “whitewash” though none is intended. The extensive work was clearly done in good faith but it did not appear to be so because it was loaded into the project after the site decision was already made. The continuing efforts to justify the decision gave the appearance of being designed to pursue the project in its chosen location, “come hell or high water”, despite strong local opposition. The “factual” record of measures taken, as presented in the report, does not now improve their reception.
Accounting
The report’s official accounting for funds includes the following:
Project expenditure |
Amount |
Land purchase (potentially recoverable) |
661,881.00 |
Consultants and Legal expenses |
612,925.71 |
Advertising |
15,641.53 |
Signs |
4,159.78 |
Engineering |
5,000.00 |
Legislative expenses |
4,701.31 |
Meeting expenses |
855.07 |
Sundry expenses |
1,707.40 |
Referendum costs |
38,705.18 |
Total Project Expenditures |
1,345,576.98 |
Staff time allocation |
5,600 hours June 1, 2010 |
This brief summary should be augmented by noting the sources of funds employed, a full statement of what was paid to whom for what specific service, and an estimate of how any of the expended funds can actually be recovered. It cannot be lost on the public, that the Ecodepot siting process was a very expensive mistake.