December 5, 2005
The Honourable Laurel C. Broten
Minister of Environment
12th Floor, 135 St. Clair Avenue West
Toronto, Ontario
M4V 1P5Dear Minister:
Re: Part II Order, Environmental Assessment, Alta Vista Corridor, City of Ottawa
INTRODUCTION
This letter is written on behalf of members from the following community associations and organizations:
- Transport 2000 Canada
- City Centre Coalition (coalition of 9 community associations)
- Citizens for Healthy Communities
- Sierra Club of Canada (Ottawa Group)
- Ottawa East Community Association
- Action Sandy Hill
- Ottawa South Community Association
- Dow’s Lake Residents’ Association
- Centretown Citizens’ Community Association
- Glebe Community Association
- 170 Lees Avenue Apartment Buildings Residents
- Dalhousie Community Association
- Canterbury Community Association
The purpose of the letter is to request a rejection or bump-up of the environmental assessment (EA) being conducted by the City of Ottawa for proposed infrastructure for the Alta Vista Corridor. The City of Ottawa has directed the EA as a Schedule C environmental assessment, under the Class Environmental Assessment for Municipal Road, Water and Wastewater Projects.
The City of Ottawa’s original selection of the Class process was incorrect. Subsequently, to avoid an automatic bump-up to an individual EA if any part of the preferred alternative were for “transit only”, the main objective of City staff and the consultant has appeared to be to ensure that any considerations of transit involved a sharing of infrastructure, and could be accommodated under the Class process. The result of this approach has been a built-in bias throughout the assessment, preventing transit-only options, for all or part of the corridor, from receiving comprehensive consideration.
When the environmental assessment report was presented to the City of Ottawa Transportation Committee and subsequently to the full Council, the motion reflected the dissatisfaction of the elected representatives with the environmental assessment. After discussing and rejecting the words, ‘approves’ and ‘accepts’, the Committee and Council decided to say that it ‘receives’ the report. Furthermore, the environmental assessment was only received on the basis that the Hospital Link section alone (Phase 1 of the proposal) be implemented, and that Phases 2 and 3 not occur until the proposal has been further reviewed in the Official Plan Reviews of 2008 and 2013. We therefore request that the Hospital Link section be ‘bumped up’ to an individual assessment, permitting serious consideration of transit-only infrastructure for all, or part, of the link to the hospital complex. Concurrently, we request rejection of the remainder of the environmental assessment on the grounds that it is seriously flawed, and that it is for infrastructure which will not be considered until after 2013, when the needs and conditions in the City of Ottawa may require a different approach to transportation of residents.
In fact, decisions by the City of Ottawa over the past year confirm that the project for which the City is a proponent is the hospital road link, and little else. In the Alta Vista Corridor, the City has leased land to the hospitals for use for parking, precluding construction of a road in the full Corridor. The City only has funding from its Capital Budget Forecast for the construction of a hospital link road in the Corridor while allocating funds in its 2005 Capital Budget for the design of the hospital road. That this road is the City of Ottawa project requiring an EA is, in fact, well described in the Notice of Study Completion published by the City.
In summary, the City of Ottawa has not applied the terms of reference of the class document fairly or appropriately, and has prepared a report for a project for which it is not a proponent. With respect to the assessment of the full Alta Vista Corridor, the study area identified was too restricted; the consultant had inappropriate influence during the weighting of criteria; documentation was not available to the public in a timely manner; information gathered during public consultation had no impact on the environmental assessment; and the methodologies used by the consultant were flawed and biased.
We are, therefore, requesting that the environmental assessment of the Hospital Link be “bumped up” to become an individual environmental assessment, under the Ontario Environmental Assessment Act, with terms of reference approved by the Ontario Ministry of Environment. We also ask that the remainder of the assessment be rejected, as not required for the City’s project. The benefits of carrying out the individual EA would be that it would be scoped correctly to ensure serious consideration of transit alternatives; it would require appropriate consultation of impacted communities; it would be harmonized with the federal assessment and with the provincial assessment of the possible expansion of Highway 417, avoiding overlap and duplication; the role and influence of the consultant would be minimized; and there would be Provincial oversight for the establishing of terms of reference and the conduct of the EA.
We ask that you review the attached rationale in making your decision. Please direct any communications on this matter to Heather Jarrett, 83 Havelock Street, Ottawa, Ontario, K1S 0A4.
Sincerely,David Gladstone
President, City Centre CoalitionCarol Gudz
Ottawa Group, Sierra Club of CanadaDavid L. Jeanes, P. Eng.
President, Transport 2000 CanadaAnthony Hadwen, Heather Jarrett, Wendy Lambert, Jon Legg
Rotating Chairs: Citizens for Healthy Communitiesc.c. Honourable Dalton McGuinty, Premier, Province of Ontario
Gordon Miller, Ontario Commissioner of the Environment
Honourable Madeleine Meilleur, Minister of Culture, Francophone Affairs
Honourable Jim Watson, Minister of Health Promotion
Richard Patten, Member, Ottawa Centre
Bob Chiarelli, Mayor, City of Ottawa
Christopher Gordon, Project Manager, City of Ottawa