Keith's critique of proposed
consultant review of Saanich EDPA law

Sent to Saanich council on April 22, 2016:

Comment on proposed consultant review of Saanich EDPA bylaw

Herein I comment on the proposed terms of reference for consultant review of the EDPA law, document file 2860-25 of April 18, 2016, for members of the Saanichite species.

The proposal is fundamentally flawed because it does not include scrutiny of the technical basis for the EDPA law, and because it is authored by a person responsible for the bad work in it.

Note for example, the Purpose and the first paragraph under Scope of Work, which narrows consultant selection to “experience and expertise in creating local government tools to protect the natural environment, instead of neutrality and thinking skills”. That will produce a biased result.

Missing is examination of the question I raised about methods of knowledge and by others about accuracy of biology/botany used by Saanich. Most fundamental is why Saanich defines “species” by political boundaries that plants and animate creatures have no knowledge of so can’t live by, instead of on essentials such as body covering, reproductive method, and motive ability. Use of a non-normal definition fails basic communication principles, misleads others, and corrupts the thinking skills needed for life.

Secondary questions are why the diversity from recent human activity is attacked while that of a few centuries ago is exempted (the Garry Oak meadows created by tribal people to increase local food production). And why Saanich’s analysis was so badly done that buildings and pavement were classified as “sensitive ecosystems” – getting paid for bad results works against life. When plants and animate creatures including humans try to live contradictions – such as a bear trying to copy a bird by jumping off a cliff flapping its legs - they die, unless rescued by someone who thinks properly. As well, a question is what is meant by “ecosystem” – when invented in the 1930s the word meant everything including humans.

“Options” 1, 2, and 3 of the proposal (not the earlier of same numbering) are vague, they are talk instead of proper review. Option 3 uses collectivist entities (“public parties”) and whatever “stakeholders” is meant to mean (property owners of course are, but any citizen concerned about process, honesty, and objective law is a stakeholder). There is a fallacy of “consultation”, we saw that on the new Craigflower bridge where cost was added to bulge the deck for a few weeks of fishing when the new bridge would have had ample width without that, while the process took time away from doing basic homework like figuring out fish schedules to avoid work in the water while they were about thus work was delayed. (Deck bulging was an example of failure to look at the full picture, council is repeating that type of error with the EDPA.)

The draft terms of reference do not include a requirement for fundamental methods of knowledge, such as whether or not proper surveys are to be done instead of using self-selecting respondents which cannot be valid even though Ms. Hvozdanski told me they are because by occasional coincidence results matched professional surveys. A proper consultant would have broad knowledge of life, including property rights and compensation for taking. The intent is obviously a very inward-focused exercise, as most input is to come from staff and environmental activists.

Note that consultants do not necessarily do good work – the omissions, sloppiness, bias, and fundamental contradiction in the Westland Resource Group’s report on Cuthbert Holmes park is a good example. (See for an exposition of that botch, which was priced at about what Hvozdanski suggests the EDPA review would be. I’ve also criticized the performance of the potential bidder Habitat Acquisition Trust, who are by their founding mission biased and misled attendees at an EDPA open house.)

Who chooses the consultant? The proposal is that council do, but only after evaluation and summarizing by staff – which is an opportunity to embed bias. Hopefully councillors will do their homework, to fully understand the subject, unlike the many cases when they did not. I suggest the finance department be well involved as they are used to scrutinizing information for accuracy, completeness, and integrity. Definitely not the planning and environmental departments due to conflict of interest given their past performance, nor the legal department who in my direct experience are callous and sloppy. Note that the April 18, 2016 proposal was authored by Adriane Pollard, the very person on the defensive against the facts of her performance thus there is high risk of bias – that is not acceptable, Hvozdanski is being foolish by counter-signing her work.

This is another subject needing an independent outside review.

Remember that it took an outsider to identify the errors and misleading statements in the spyware fiasco (BC’s privacy commission) and a whistleblower to reveal the problems (a whistleblower whose subsequent treatment will serve to suppress honesty in Saanich staff).

PS: I don’t expect to attend the council meeting on this, for security reasons due to your spending on bad laws instead of policing.

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