MPCA letter to Russell Mills, NCC Chair, re: next phase of the study
The following letter was sent last week by the MPCA to Russell Mills, NCC Chair, highlighting key factors that need to be considered as the next phase of the project is defined:
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MANOR PARK COMMUNITY ASSOCIATION
ASSOCIATION COMMUNAUTAIRE DE MANOR PARK
March 4, 2009
Mr. Russell Mills
Chairman of the Board
National Capital Commission
202-40 Elgin Street
Ottawa, Ontario, K1P1C7
Dear Mr. Mills:
Re: Interprovincial Crossings Study
While the position of the Manor Park Community Association (MPCA) has consistently been that a new Interprovincial crossing is necessary, we have serious concerns about the manner in which the Interprovincial Crossings Phase 1 Environmental Assessment was conducted. We therefore welcome and appreciate the decision of the NCC Board not to accept the consultant’s recommendation to proceed with a Phase 2 Assessment of the Kettle Island Corridor alone.
We believe that as the Commission enters the next phase of this important study, there are some
changes in priority and methodology that will result in a more transparent and acceptable process. The purpose of this letter is to seek information regarding the process for the next steps and to share our views with you prior to the start of the next phase.
Independent Analysis is Required
MPCA believes that there were a number of flaws in the manner in which the Phase 1 study was
conducted, the most egregious of which was the disregard for the health, safety and well-being of
residents in close proximity to the corridors under study. I will not present details here, but would refer you to the many hundreds of submissions made to Roche-NCE following PCS#4, and to the oral and written presentations made at the NCC AGM on Dec. 3, 2008.
We urge the NCC to seek an independent assessment for Phase 2 of the EA by hiring a different
consultant for the next phase. This would not only provide greater objectivity but would also assure us that the NCC is truly committed to protecting the interests of existing communities. Our concern is that the same consultant, if engaged for the next phase, would simply confirm its Phase 1 conclusion.
Canadian Environmental Assessment Act
The NCC Board has decided to carry three corridors forward into Phase 2 of the Environmental
Assessment. However, it is our understanding that under the Canadian Environmental Assessment Act (the “Act”), there is no opportunity in a screening study to compare alternative projects, but rather that the screening study requires that only one site-specific project be considered.
In light of this, how will Phase 2 proceed? Our technical committee, comprised of a number of engineers, has suggested that the next step in the Interprovincial Crossings study be a comparative analysis to compare the alternative corridors before selecting the site-specific project. This comparative analysis would of course need to be in sufficient detail to make a rational decision, but it would not require the design of intersections, structures, noise barriers, berms, etc. Following completion of this comparative analysis, the fully detailed screening study, as envisaged in the Act would proceed.
It is important that this matter is clarified so as to be part of the Terms of Reference for the next phase of the study.
Terms of Reference are Critical
It is essential that the Terms of Reference for the next phase be carefully developed and open to public review and comment, prior to engaging the consultant.
As noted above, the Terms of Reference need to reflect both the decision of the Board and the provisions of applicable legislation.
As suggested by the Province of Ontario, the impact on existing communities, compatibility with public transit, and impact on economic development are all highly important criteria that need to be recognized in the Terms of Reference. These factors were not sufficiently weighted in the Phase 1 study.
Results of the recently-initiated interprovincial transit study and updated interprovincial truck traffic studies need to be completed before evaluating the candidate corridors.
The actual corridors to be evaluated should not be strictly limited by the Terms of Reference to the
alignments of corridors 5, 6, 7, as defined by Roche-NCE. To do so would exclude possible variations for corridors 6 and 7 (including one proposed by MPCA’s Technical Committee and previously made available to the members of the NCC Board), which could provide the optimal solution.
Meaningful Public Consultation is Required
Given the paramount importance of the impact on existing communities, we urge the NCC to facilitate the participation, in all aspects of Phase 2, of representatives from communities that will be affected by the corridors under study.
This would include providing input to staff in drafting the Terms of Reference and ongoing consultation throughout the process.
In particular, unlike what transpired in Phase 1, weightings for each assessment factor should be subject to public participation. If only special interests are represented in the weighting process, how will communities be protected? Citizens need to have input.
The Recommended Corridor Must Solve the Truck Route Impasse
The new crossing must be located so as to solve the truck (semi-trailer) route impasse. It must be
selected to accommodate all the long-distance heavy transport vehicles that are today so problematic along the Rideau-King Edward corridor.
As matters stand, Ottawa City Council has passed a resolution, backed by the Ontario Municipal Board, to ban such trucks on the King Edward Corridor, as soon as a new crossing is opened. The Rideau Street BIA has threatened legal action if this does not occur. The City of Gatineau has accepted the Kettle Island Corridor option, but only if trucks can remain on the Macdonald-Cartier bridge and be prevented from using Montee Paiement. The Phase 1 report recommends continuing to permit some heavy truck traffic on the King Edward Corridor and the remainder on the Kettle Island Corridor—negatively impacting existing communities along both routes.
When presented with the impasse, Roche-NCE suggested that if all heavy trucks were to be prohibited from King Edward Avenue, many would choose to use the Chaudiere Bridge instead of the new corridor. The approaches to the Chaudiere Bridge from expressways on both sides of the Ottawa River are difficult and pass through the downtown cores of Ottawa and Gatineau. Furthermore, structural limitations have recently been discovered in the Chaudiere Bridge. Hence, our view is that the Chaudiere Bridge is unsuitable to absorb an increased proportion of the heavy vehicle load.
In short, the new corridor must have the capability to absorb virtually all the interprovincial heavy vehicle traffic.
The Manor Park Community intends to remain active on this file in the upcoming months. We look
forward to working closely with the consultants, the NCC staff and the Board, with a goal of finding a
solution that does not harm communities and meets the needs of the National Capital Region.
I would be grateful if you would distribute copies of this letter to members of the NCC Board.
Yours sincerely,
John Forsey, P.Eng.
President
cc. (soft copy only)
Hon. Mauril Belanger
Hon. Madeleine Meilleur
Coun. Jacques Legendre
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March 12th, 2009 at 9:13 am
A modified combination of corridors 6 and 7 on both sides of the river does indeed offer a route with minimal community impact. The terms of reference should be expanded accordingly, and premised on a people/communities first approach. Other principles should be imbedded. For example, access from the new crossing to the Rockcliffe Parkway. Moreover, access to the Hemlock/Beechwood corridor should also be eliminated from the Kettle Crossing option before going any further.
The next phase could be led by urban planners supported by transportation engineers and not vice-versa. Fully agree that community experts and potentially impacted stakeholders be fully engaged in the drafting of terms of reference, in the consultant selection and in the design of the consultation process. The public consultation process needs to be upgraded to ensure public views are also sought on drafts, not just positions.
At the provincial level, transportation ministers could formally share oversight responsibility for the crossings with other interested colleagues (e.g., communities, health, environment)
March 12th, 2009 at 9:16 am
The above should read ‘no access from the crossing to the ROckcliffe Parkway.
March 13th, 2009 at 2:44 pm
Among other things, the MPCA’s letter to the NCC is a thoughtful and persuasive rebuttal to the claim that the NCC succumbed to NIMBYism by acceding to the Ontario and Quebec governments’ call for environmental studies of three crossing sites, and not only the Kettle Island option recommended by its consultants. At the heart of this claim is a belief that those opposing a crossing at Kettle Island are putting their own interests ahead of the public good, and that their objections are selfish rather than principled.
Accusations of NIMBYism are often an effective tactic for undermining perfectly reasonable arguments for opposing development by implying that opponents are so focused on their self-interest that nothing they say merits consideration. However, properly understood and addressed, such opposition helps to define and promote the public interest by forcing decision-makers and their consultants to revisit their assumptions about what this means in the context of particular developments. The best approach to perceived NIMBYism is therefore to deal directly and openly with concerns that engender it.
In this case, the weight assigned by the NCC’s consultants to their study’s evaluation criteria reflects various policy preferences and values which were never disclosed, let alone publicly discussed before the release of their recommendation. The result is a recommendation based on obsolete planning ideas that again sacrifices the needs and interests of people and communities within the greenbelt, where all inter-provincial crossings are currently located, to the demands of the heavy trucking industry and Gatineau and other commuters, and also to the detriment of densification and other efforts aimed at creating a liveable and sustainable city.
The lack of transparency in dealing with these concerns and not NIMBYism is why crossing sites in addition to Kettle Island had to be included in the next phase of the inter-provincial crossing study. It is also why this phase of the study should be done by different consultants than those who conducted the first phase.