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PROPOSED UNDERTAKING DIFFERS FROM OTHER UNDERTAKINGS IN THE CLASS TO WHICH CLASS EA APPLIES
1) Proposal is not Recurring
2) Cost
3) Length of Time for Assessment
4) Extent of Public Concern
5) Potential for Significant Adverse Environmental Effects
6) Federal Assessment Also RequiredLACK OF SATISFACTORY PUBLIC CONSULTATION
1) Inappropriate public consultation
2) Lack of integration of public concerns
3) Advisory Committees
4) Delcan’s Role InappropriateINAPPROPRIATE ASSESSMENT METHODOLOGY
1) Need for Project Based on Questionable Assumptions
2) Inappropriate Methodology for Comparative Evaluation of Alternatives
3) Selective Elimination of Alternatives
4) Selective Use of ScienceBENEFITS OF CARRYING OUT INDIVIDUAL EA
PART II ORDER, Environmental Assessment, Alta Vista Corridor, City of OttawaThe Alta Vista Corridor was identified as a possible location for transportation infrastructure in the 1960s. When the provincial Highway 417 was being built, this corridor was one of the proposed routes. In fact, it was the first proposed route in 1965 as part of the "South East Freeway" which included plans to turn King Edward into an expressway through Sandy Hill and Lowertown. Although Highway 417 was built in a different location, the Alta Vista Corridor was retained in the Official Plan of the City of Ottawa, and has been proposed as a roadway in various configurations and various routings over the intervening years. Council, reflecting the wishes of the public, has not approved any of the previous proposals.
In September 2000, before the corridor became the responsibility of the City of Ottawa, the Regional Council adopted recommendations found in the Alta Vista Drive/Smyth Road Transportation Strategy, supplementing that report with additional recommendations, including one that required that the Alta Vista Parkway be studied as a “bus/light rail only” route and as a “transit/vehicle route”. These recommendations were the impetus behind the environmental assessment which was initiated by the City of Ottawa on 21 February, 2001.
When the EA was initiated by a presentation to City of Ottawa Transportation Committee in 2001, community organizations opposed its designation within the Class Environmental Assessment for Municipal Road, Water and Wastewater Projects. The opposition was based on advice received from staff at the Environmental Assessment Branch, Ontario Ministry of Environment, who explained that the Transportation Committee’s requirements to look at dedicated transit options could not be achieved within the Class process. Unfortunately, City of Ottawa staff advised differently, and the EA was initiated, based on their recommendation.
PROPOSED UNDERTAKING DIFFERS FROM OTHER UNDERTAKINGS IN THE CLASS TO WHICH CLASS EA APPLIES:
Class environmental assessments are intended for application to projects which are:
• Recurring;
• Similar in nature;
• Limited in scale;
• With predictable environmental effects; and
• Responsive to mitigation.The Alta Vista Corridor infrastructure project does not fit these criteria. It differs from typical proposals in the class.
1) Proposal is not recurring: The Alta Vista proposal does not resemble typical proposals in the class. It is not a recurring proposal. It is not similar in nature to simple road projects. It is not limited in scale, and it does not have predictable environmental effects. The preferred alternative being advanced for the proposal involves complex linkages with existing road and transit systems, and the construction of a bridge across a major river. It will require remediation of severely contaminated land before construction can begin. Because of its length and central location, it would have negative impacts on several communities in Ottawa.
2) Cost: The total cost of the project exceeds cost estimates for the simple road or wastewater projects for which the class was designed. The cost estimates given by the consultant have varied over the 4+ years of the EA, from the figure of $92 million, used in the evaluation exercise. This figure includes $59 million for construction cost, $9 million for project management, and $9 million for overall contingency. However, the consultant is now quoting $59 million for the much shorter and much simpler 2-lane road to be built as Phase 1 of a 3-phase project. If the $59 million estimate for this first phase, which is roughly one-third of the total length of the proposal and does not include most of the technically challenging and expensive portions (traversing an old landfill site, crossing the Rideau River, and reconfiguring the interchange at Highway 417), is correct, it calls into question the estimated cost of the total project. Based on $59 million for the short, 2-lane hospital linkage, it is likely that the cost of the 4-lanes plus bridge in the remainder of the corridor would exceed $200 million, much more than the limited scale envisaged for reviews using the class model.
3) Length of Time for Assessment: The Alta Vista Corridor proposal is for transportation infrastructure; however, it differs from the standard road-building proposal and scale of proposal for which the Class was designed. This environmental assessment has been going on for nearly five years, while a typical assessment completed under this Class would be expected to be completed within 18 and 24 months. The length of time is an indication of how difficult it has been to force-fit this EA into the Class structure.
4) Extent of Public Concerns: Members of the public have consistently demonstrated their opposition to the building of a single-occupancy vehicle roadway within the Alta Vista corridor. At each of the public consultation events sponsored by the City and its consultant, several hundred persons attended, and the majority voiced opposition to the work of the consultant. There might have been considerable support for a solution that is totally transit, but such a solution has not been adequately investigated or evaluated during the environmental assessment process. In fact, the use of the Class EA process precluded the advancing of a transit-only option, because that scenario would have required the consultant to re-start the process as an individual EA. Organized groups of public citizens have consistently proposed solutions that included portions dedicated only to transit; their options have not received serious consideration.
5) Potential for Significant Adverse Environmental Effects: The proposed alternative for the Alta Vista proposal would include excavation of severely contaminated soil at historic landfill sites. These landfill sites are in close proximity to the Rideau River, suggesting possible impacts on fish habitat. Their excavation would result in environmental effects that are not easily predictable, and that might not be responsive to mitigation. These have not been explored in any detail within the Class EA, nor have the activities been factored in appropriately in the evaluation of alternatives.
Residents along the northern section of the proposed road corridor, where approximately 3,000 people live in a complex of 5 high-rise apartment buildings, would be subject to a marked increase in noise and air pollution. The noise levels at this location are already 63.5 to 68.7 dB, depending on the building. The consultant explained that as noise levels are already so high and as noise growth is not linear, the presence of the proposed road would “only add 1 to 1.5 dBA to the existing noise levels”. The increase was not considered significant enough by the consultant to require attenuation. When asked about how the noise impacts should be dealt with for these residents, the consultant commented that there are some impacts that cannot be mitigated; that the situation is bad now, and will continue to be bad with or without the proposed road; and that the apartment building should upgrade its windows. This is unacceptable. The noise impacts represent a significant cumulative adverse impact – the proposal should not be permitted to proceed if this cumulative impact cannot be mitigated.
Because the consultant artificially limited the study area of the EA, many of the impacts of the proposal have not been identified or evaluated. These include the impacts on all communities north of the Rideau River, and also the downstream communities which would be receiving the increased traffic. Because the EA does not identify all of the impacts, it obviously does not consider whether or not mitigation is possible. Hopefully, in an individual EA, under the direction of EA specialists from the provincial government, the study areas would be scoped in a manner that would encompass all environmental impacts
6) Federal Assessment also required: The Alta Vista proposal will trigger a federal environmental assessment, further complicating the planning process. The Environmental Study Report, page 3, Figure1-2 indicates that the City of Ottawa’s does not plan to initiate the federal assessment until the proposal is in the final design stages. This demonstrates the City’s lack of understanding of the purpose of environmental assessment as a planning tool.
The City of Ottawa has discussed its EA requirements with the Canadian Environmental Assessment Agency, and has been informed that the Agency would be available to assist in the coordination of a federal-provincial EA in accordance with the recently approved Canada-Ontario Agreement on Environmental Assessment Coordination. However, it would appear that the City has elected not to pursue the coordinated EA approach and has not yet initiated any activity with appropriate federal departments, despite commitments given that the project would include a harmonized EA with the federal level. Enquiries indicate that Transport Canada will definitely require an environmental assessment due to approvals required under the Navigable Waters Protection Act. The proposed alternative might result in destruction of fish habitat, which might cause Fisheries and Oceans Canada to trigger a federal assessment as well. Although the stream of assessment is likely to be a screening, and although the City of Ottawa would be able to use much of the information already developed during its current assessment, there would be a requirement to assess cumulative effects, some of which are likely to be residual, adverse, and significant, and for which mitigation measures might not be possible.
LACK OF SATISFACTORY PUBLIC CONSULTATION
1. Inappropriate public consultation
a. Non-interactive: poster boards only. Two of the public consultation events organized by the consultant consisted of a room full of more than 30 poster boards, with no verbal explanation of what they represented. The poster boards had been selected to show only the consultant’s view and they were confusing to all members of the public who had not studied the documents on which they were based. Although there were 3 members of the consultant’s staff available, only one of them was able to answer complex questions, a situation which was not satisfactory with several hundred people trying to digest and understand the material.
b. Ignores impact community:– The consultant decreed that the study area would exclude the downstream communities, and only evaluated impacts for communities beside the central part of the corridor, ignoring downstream communities or communities at northern end of corridor. When public events were staged, they were held only in the parts of the community that might support the proposal. The consultant refused invitations from the communities of Ottawa East and Sandy Hill, both of which would suffer serious adverse impacts from the implementation of this proposal.
c. Final Report is not conducive to public participation: The final report does not clearly lay out the final recommendations or the rationale that supports them. There should be an executive summary that is easy to locate and understand. Forcing laypeople to wade through several hundred pages is not conducive to participatory democracy.
2. Lack of integration of public concerns:
a. No public report of the results of the public consultation
The City of Ottawa held 4 large public events. At each event, members of the public were invited to complete comment sheets about the conduct of the EA, and about the results shown up until the time of the public event. The comment sheets were collected by Delcan, the City’s consultant. There was no information forthcoming from the collected comments – no summary report; no publicly available, quantified indication of public opinion. Council’s Transportation Committee was told only that opinion was divided, while those in attendance at the events could discern that opinion was overwhelmingly opposed to the consultant’s plans.
The public event organized by the City of Ottawa in May 2005 was cancelled a few hours before it was to take place. Community organizations, with limited or no budget, had spent considerable effort to ensure members of their communities would be present, and that their concerns would be heard. Despite this disrespectful treatment of the public by the City project team, the rescheduled meeting drew approximately 400 people, with an overwhelming majority of speakers against the proposed alternative.
b. No apparent changes in plans or choice of options, as a result of public consultation
The most damning feature of the spurious consultation done by the City of Ottawa staff and its consultants is that none of the consultation was reflected in any way in the final proposal. The City started the exercise with a plan to build a four-lane road through the corridor and the City ended the exercise with the same plan, the same routing, the same proposed connections. The plans of the preferred solution differ only marginally from drawings produced in 1994 in a previous EA done on the South East Sector of the City.
c. No attempt to integrate with concurrent assessments:
The Alta Vista study did not incorporate or interact with the parallel work being done on the future of the Hospital Lands, specifically the National Defence Medical Centre (NDMC) that is slated for closure in the next few years. It could have been possible to redirect the proposed road routing to take advantage of existing road infrastructure on NDMC property, instead of destroying greenspace.
More seriously, the Alta Vista study did not acknowledge the Province of Ontario’s environmental assessment of proposals to widen Highway 417. There is a direct dependency between the proposed alternative in the Alta Vista study and the lack of capacity in Highway 417 to accommodate the additional traffic that would result. The City of Ottawa’s attempt to reconfigure the interchange between the Alta Vista Corridor and Highway 417 would be result in additional exits from the AVC into residential neighbourhoods. The environmental assessment study does not assess the resulting impacts to these receiving communities.
There were two committees established by City of Ottawa staff, with each having one-third of the votes during the process of evaluating alternatives.
a) Technical Advisory Committee (TAC): This group was established to ensure integration of technical requirements from municipal, provincial and federal departments and agencies. City of Ottawa staff invited federal officials from Fisheries and Oceans Canada (DFO), Transport Canada (TC), the Canadian Environmental Assessment Agency and the National Capital Commission; and provincial officials from the ministries of Environment and of Transportation. The bulk of the approximately 30 membership was comprised of City of Ottawa staff and consultants. This committee had one-third of the votes during the evaluation of alternatives, although only a few of its members participated actively enough to be aware of the complexities of the proposal.
The only regular attendees at the meetings of the TAC were City staff, and their consultants. Apart from attendance by the National Capital Commission, at no time was the federal government represented at a meeting, in spite of the fact that a federal environmental assessment will be required for the proposal, and in spite of a commitment from City of Ottawa staff and consultant to harmonize the provincial and federal EAs from the beginning. When Transport Canada officials were contacted by Citizens for Healthy Communities in April 2005, they indicated that a federal environmental assessment would be required for the proposal but that, at that point, no City of Ottawa official had contacted them to discuss the matter.
At the September 21st meeting of the City Transportation Committee, when questioned about federal department participation in the TAC, city staff claimed that “they have been at the table participating and they have had no issue with the process to date.” The truth of the matter is that minutes of the TAC show only the representative from the National Capital Commission in attendance.
b) Public Advisory Committee (PAC): The membership on the Public Advisory Committee was intended to include one voting representative from each impacted community and some special interest organizations, such as Transport 2000, the Cycling, Roads, and Pathways Advisory Committee, and the Parks and Recreation Advisory Committee. Observer status was granted to other interested communities and special interest organizations. Voting status entitled the representative to ask questions at the meetings and to vote on the evaluation of alternatives. The criteria distinguishing between voting members and members with observer status were ambiguous and inconsistent, with the decision about respective status being made by City staff. In one case, representation of an area (Lees Avenue Apartments Buildings – approximately 3,000 residents) was denied voting status on the grounds that the buildings to be represented were merely a subset of a larger community association; in a similar case, voting status representation was given to residents of one street, although their area was within and already represented by a community association. Coincidentally, in the former case both residents were pro-transit, while in the latter case both representatives were pro-road. The selection criteria for granting/refusing voting status were questionable and not transparent, and gave the decisions had the appearance of depending on whether the community agreed or disagreed with the staff’s pro-road bias.
Members of PAC were expected to represent the opinions of their respective communities. Some members conscientiously consulted with their communities before stating a position or voting on controversial material. However, the consultant allowed the weighting of evaluation criteria by PAC members to be submitted confidentially. This was disputed by several members of PAC for its lack of transparency, and for the suspicion that some PAC members were stating their own personal views, rather than the views of their communities.
The PAC was intended to be a forum for the discussion of EA information at the various important stages of the review. In most cases, the material to be discussed was not distributed to the participants in sufficient time to permit detailed reading and understanding of what was presented. At one PAC meeting, new material was presented at 10:15 at night, after PAC members had already been in attendance for over 4 hours, showing a serious lack of respect for the participants. In the documents that were presented, PAC members identified many contradictions or inconsistencies. These were not satisfactorily addressed by the consultant. These inconsistencies can be illustrated by the example of the Lees Avenue apartments. Up to 3000 people live there and they will have a four lane road built between them and the rest of their community. There will be obvious effects on the noise, air quality, and linkage to community facilities and recreation – however, the study calculations showed the air quality will improve with the addition of four lanes of additional traffic. The consultants were unable to explain this anomaly, despite requests. Noise issues for the same population were dismissed because the apartment dwellers already have excessive noise from the adjacent Queensway. The essential question to demonstrate is how the clearly negative effects on this population could be proven to be balanced by the positive effects on another population in the study. Who benefits? How many people are in this alternative group? How are the benefits calculated? The study team stated that the calculations were not quantitative and these questions could not be answered. This is not a proper or "defendable" assessment.
On the night when the selection of the preferred alternative, the four lane highway, was presented to Public Advisory Committee, there were many questions raised. The study team stated that there was no time to consider the questions during the meeting as the agenda included a discussion of the next step, the proposed road designs. This comment showed that the study team did not intend to discuss this important decision with the Advisory Committee. The questions submitted by Advisory Committee members following the meeting were not answered in any substantive manner.
When it became obvious that the study team was not prepared to respond to concerns raised by the Public Advisory Committee, some PAC members offered an alternative review procedure. Members of the Advisory Committee offered to pay for a peer review of the selection of the preferred alternative, by a competent, professional engineer selected at random from those who would respond to a proposal call. The peer review, as proposed, would not incur major costs or a time delay to the environmental assessment study. This offer was turned down by Chris Gordon, the City manager. He stated that the review of Transportation Committee obviated the need for an outside peer review. It is unlikely that members of Transportation Committee reviewed the voluminous documentation created in the study or had the technical background or interest to undertake an evaluation as rigorous as that of a professional peer review.
In late 2004 and early 2005, over half of the membership of the PAC withdrew from active participation. For four years, these members had attempted to work within the process established by City of Ottawa staff and consultant. For four years, they had seen their suggestions for changes or compromises rejected, usually without any stated justification. They had agreed to participate, believing that informed discussion would produce the best solution, and withdrew regretfully. However, after four years of participation, it had become apparent that the PAC was ‘window-dressing’ only. The PAC members withdrew because their continued presence would have lent credibility to a flawed process, a process which paid no respect to opinions or contributions that differed in any way from those of City staff.
4. Delcan’s Role Inappropriate
The consultant, Delcan, overstepped the appropriate bounds in its participation in the environmental assessment. Its job was to conduct the EA; however, Delcan also gave itself one-third of the voting power when the weighting of criteria was performed. Its weights were out-of-line with those submitted by members of the PAC. For example, the average PAC weighting given to the criterion for Air Quality was 10.49; Delcan’s weighting was 2.80. The average PAC weighting for the criterion on Overall Transportation Service was 13.44; Delcan’s weighting was 7.86. The average PAC weighting for Transit-based mobility was 21.64; Delcan’s was 5.35. It is not clear that Delcan’s votes were cast without first having seen all other votes tallied, leaving them in a position to tip the scales toward their preferred alternative. No sensitivity analysis was done to determine how much Delcan’s portion of the weightings influenced the final decision.
Why was Delcan permitted this involvement? The consultant was in a definite conflict of interest position, using its weighting to influence a decision which would result in an additional contract: Delcan had been promised the design work for this proposal, but only if the alternative chosen was a road-based alternative, not a transit option .
INAPPROPRIATE ASSESSMENT METHODOLOGY
1) Need for Project based on Questionable Assumptions
a. Population growth projection over-estimated growth. The growth projection figures were established during the boom in the local high technology sector. With the failure of this part of the Ottawa economy, the figures have been shown to be a major over-estimation. During the past four years, the figures were inaccurate by 26%.
Although the needs assessment was done at the initiation of the environmental assessment and had to use data available at that time, the assessment was re-calculated in 2004, when the City of Ottawa Transportation Committee (part of City Council) sent the EA back to staff and consultants to require consideration of some transit possibility. At the time of this re-assessment, new data were available to indicate that growth projection figures for Ottawa suburbs were seriously over-estimated. This new information was not used in the re-assessment of need.
b. Artificial ‘Cap' on Transit: The needs analysis placed an artificial cap of 30% on possible transit ridership. Transit use has typically been much higher in the areas that would be served by the Alta Vista Corridor, the central core of the city.
The operation of light rail in the same area has the potential to attract an even higher percentage to transit use. For example, when the O-Train pilot project was initiated, the target ridership figure was to average 4,000 riders per day. Recent figures show that these projections under-estimated significantly the potential of light rail to attract new transit users. In September, 2005, there were an average of 9,183 riders on the O-Train! That figure is consistent with the steady increase in ridership levels recorded each year. The figures support the observation that, by setting the cap for public transit usership at 30% in their need projections, Delcan and City staff seriously under-estimated the percentage of residents who would use transit. This resulted in a corresponding over-estimation of the need for road infrastructure.
2) Inappropriate methodology for comparative evaluation of alternatives
The double concordance method is difficult to understand, easy to manipulate, and has not been used widely by environmental assessment professionals for a considerable time. The following are some of our concerns:
a) Only the alternative that ranked first against a particular criterion received points for that criterion. All other alternatives would receive zero for that criterion. Therefore, alternative X could conceivably rank second against all criteria and score zero points, whereas a poorer overall alternative Z could rank higher on one criterion only but still score higher overall. (It is interesting to note that the same consulting firm has used a fairer, more transparent methodology for the EA it is managing of the City of Ottawa light rail proposal.)
b) This methodology tries to deal with non-quantifiable attributes in the same manner as it deals with factors which have numerical limits. The resulting comparison is subjective. The comparisons were done by the consultant, with limited documentation to support decisions. In this particular environmental assessment, the methodology selected permitted the consultants to manipulate the comparison to obtain such ludicrous results as:
• A new four lane roadway would cause less air pollution for residents of the Lees Avenue apartments than the ‘do nothing’ option;
• The construction of a new roadway would result in the creation of new vistas and panoramas of the Rideau River, and was therefore preferable to not building a roadway;
• A four-lane roadway would provide better linkages to transit than would a transit alternative; and
• A roadway (in spite of the increased potential for vehicle-induced accidents) would improve safety as compared to the ‘do nothing’ option.c) Earlier use of this method by Delcan in City of Ottawa environmental assessments resulted in complaints being registered by communities about the distorted results (e.g. King Edward Avenue EA).
d) The assessment of each alternative against the various criteria was done by the consultant and City staff, with no oversight and no public debate. When members of the Public Advisory Committee asked to see the records of the rationale behind the assessment, the consultant was unable to produce any documentation to support the alternative assessment. Given the extreme subjectivity of some of the criteria, this process was unacceptable and resulted in the manipulation of the assessment.
3) Selective elimination of alternatives
a) The elimination of transit
The consultant eliminated certain alternatives, without adequate or consistent justification. The light rail alternative was eliminated because the consultant stated that the City of Ottawa would not use this corridor if it decided to introduce light rail; therefore a light rail alternative did not fit well with the City’s Official Plan.
The criteria were originally established based on the understanding that a transit-only option would be one of the alternatives being evaluated. Because other transit proposals were being considered by the City of Ottawa during the same time frame, it was necessary to include evaluation criteria which would factor in the impacts of other transit/road projects. Two of the criteria included to address the possible duplication of infrastructure proposals were Criteria A 10, Consistency with Planning Policies, which considered existing and planned land uses, and Criteria B1, Overall Transportation Service, which considered the provision of a balanced and integrated transportation system. A transit-only option in the Alta Vista Corridor could have been expected not to score highly against these criteria if other transit proposals would service the same communities. However, the transit option was eliminated by the consultants before it reached the evaluation phase, in spite of Council’s stated requirement that a transit-only option be among those undergoing evaluation!
While it may be true that the Alta Vista Corridor might not be the optimum routing for proposed light rail in the City of Ottawa, it is not appropriate for the environmental assessment to eliminate an alternative based on a possible future political decision. In time, Council might decide to have more than one light rail line. The purpose of the environmental assessment is to carefully compare the alternatives and to indicate which alternative could be implemented with the least negative environmental impact.
The terms of reference approved by the City of Ottawa Transportation and Transit Committee included the requirement for the evaluation of the Alta Vista Corridor as a“bus/light rail only” route and as a “transit/vehicle route”. The selection of evaluation criteria and the weighting of the criteria were done based on understanding that transit would be one of the alternatives evaluated. This never happened. The “bus/light rail” alternative was screened out without ever rising to Transportation Committee, or being part of a public debate. Different weightings would have been assigned if road-only options were the only ones being considered.
b) The “Do Nothing” alternative
The transit alternative was eliminated because it did not fit well with the City of Ottawa Official Plan. Neither did the “Do Nothing” alternative, but it was retained.
The comparison of the remaining alternatives was distorted by its retention. While it is important to look at the “do nothing option”, the other options should not be evaluated individually against it, but rather as a grouping of “do” options, each of which causes some disruption to the existing environment. By including the “do nothing” option in the comparative evaluation, the result was that it earned all of the points for most of the “community-friendly” or “environmentally-friendly” criteria. These points would otherwise have been allotted to the most environmentally and socially acceptable of the “do“ options.
a) Target used as cap on possible transit use: The consultant used the City of Ottawa transit target in all its calculations as if it were a firm figure which could not be exceeded. By artificially establishing the target as the maximum achievable, the consultant limited the consideration of transit options. It would have been more appropriate to determine what capacity a public transit solution would have, and to use the capacity figure as the maximum possible number who could be accommodated on transit.
b) Induced traffic: Induced traffic is an established phenomenon which other progressive jurisdictions acknowledge and which Transport Canada includes in a planning tool and which the city now requires (Air Quality and Climate Change Management Plan, Jan. 2005) as part of all EAs. Members of the Public Advisor Committee requested its consideration many times during the Alta Vista EA; the consultant and City staff always refused. Consideration of induced traffic and induced transit usage would have produced different results than those recorded by the consultant.
A substantial body of research recognizes the validity of including induced travel in assessing the impacts of transit and roadway projects. A report prepared for the Washington Metropolitan Council of Governments points to findings from various studies which demonstrate that demand for travel is responsive to new capacity and that, in the long term, this new capacity leads to new and longer trips . The authors caution against including in induced travel any trips diverted from existing facilities onto new facilities (displaced traffic).
Research in the area of reductions in travel facilities also supports the notion of induced travel. Where roadway capacity was reduced, it was found that there were reductions in traffic volumes .
Transport Canada has made available a modeling tool called TransDec, which was developed for use in the assessment of transit and highway investment projects. The impetus for the creation of this model was the recognition that most currently-used models favour roadway investments over transit investments because they don’t properly account for many of the costs attributable to roads and the benefits attributable to transit projects. The TransDec model includes induced travel as well as accident costs, infrastructure construction, operation and maintenance costs, mobility for the disadvantaged, and contribution to liveable communities. The consultants who prepared the Environmental Assessment of the Alta Vista Transportation Corridor have not included these factors in their Environmental Assessment. As a result, they have not provided the most comprehensive assessment possible, given currently-available tools. Given these omissions, there is a real possibility that this assessment is biased in favour of the roadway alternative.
c. Study area incorrectly defined: The study area was incorrectly restricted to ignore any communities north of the Rideau River. The result was that the description of existing environment was incomplete, and that no impacts were measured on any of the downstream communities, or communities in the northern third of the proposal. This omission particularly shortchanged the community of Old Ottawa East which would suffer some of the most severe of the negative impacts, of noise, air and visual pollution.
By inappropriately defining the study area, the consultant exacerbated the error by not considering any of the impacts on Old Ottawa East or Sandy Hill during the comparison of alternatives. By restricting the community to only the areas near the southern part of the corridor, the consultant distorted the impacts of the various alternatives.
d. No economic analysis: Delcan’s assessment fails to take into account changing economic factors that will lead to increasing use of public transit in the future. Given the cost of fuel today, people are reconsidering the ways they commute. It seems inevitable that fuel prices will continue to rise, with the result that the transit share of the commuting public will increase. Delcan refused to accept this, even as a possibility, and based its calculations on the assumption that use of public transit will never exceed 30% of the population.
BENEFITS OF CARRYING OUT INDIVIDUAL EA:
The benefits of requiring an individual EA would be:
a. The federal environmental assessment could be appropriately harmonized with the provincial assessment, ensuring that important decisions are made by both jurisdictions at the same time. Currently, it appears that the provincial decision could be made and the proposal initiated, before the federal assessment even begins. That would be perceived as pre-empting the federal authority to make an independent decision about the viability of the proposal.
b. Proposal would be scoped correctly to include the impacts on the downstream or receiving communities. Study areas would be defined to encompass all the impacts.
c. Transit alternatives would receive a fair evaluation.
d. EA would require appropriate consultation of all impacted communities, not just the ones that perceive a benefit in the proposal. The proponent would be required to demonstrate how public consultation had been considered in the environmental assessment.
e. There would be arms-length oversight by the Province over the establishing of terms of reference.
f. The EA would harmonize appropriately with the EA being conducted by the Ontario Ministry of Transport regarding possible expansion of Highway 417.Rejecting the environmental assessment would send a clear signal to the members of the Ottawa public that the Province of Ontario provides genuine oversight on environmental assessments.
It would indicate that the provincial government expects proponents to use up-to-date scientific analysis and technology, and the consistent application of appropriate methodology.
It would demonstrate support for the principles of environmental assessment: EA is intended to be a planning tool, and EA is intended to integrate the values of the public into the decision-making process.
It would emphasize the need for bureaucratic processes to be open, consistent, transparent and honest.