My Comments on Greater Sudbury's Draft Transportation Master Plan

I attended the recent public information session for the Draft Transportation Master Plan (2015) held on June 24, 2015, and made a presentation there, which included asking a question of municipal staff.  I thank Council for the opportunity to provide public input in such a venue, and to be able to interact with staff in that format.

At the conclusion of the evening, there was some discussion regarding next steps. It was not made clear that the deadline for further public submissions would be less than 48 hours later – even though there was ample opportunity to provide that information to both Council and to many of the citizens in our community which have been engaged with the review of the draft Plan.  Many of the questions that we had about the plan were only answered during the public input session, or several hours before at the Public Information Session.  As further comments from the public would be informed by new information brought forward at both of these sessions, it is incredibly unreasonable to expect submissions to be made with less than 2 days worth of time (and to only find out about the deadline through a post made to the City’s website on June 25^th is, frankly, insulting).

This is not what public consultation is all about.  When many of our new council members were elected, there were promises made to the public about increased transparency and providing opportunities to the public to become more engaged in civic issues.  Given the significance and importance of this matter to the future health and economy of our City, I am simply shocked that the City has decided to cut off further public input at this time, with just 24 hours notice.

While I understand that there will still be an opportunity for additional public input as part of the review and Environmental Bill of Rights processes, I feel that it is very important for the City to take careful consideration of all public comments at this time, as revisions to the plan which are to be presented to Council on July 7^th will likely put the Plan in its final form – meaning that it will likely only face further alteration if required by an outside agency, or if specifically directed by Council.

To be blunt, the public has been waiting for the completion and release of this draft plan since input was first requested in 2013.  The draft plan was only made available to the public in April, 2015.  The review of the plan raised a number of questions.  Some of those questions were answered only on June 24, while others have not been answered.  With this in mind, there is no good reason to move with undue haste now through the public consultation process. 

With this in mind, I offer the following comments:

Official Plan and Environmental Assessment Process

Part of the purpose of developing a Transportation Master Plan is to inform the Official Plan 5-year update, and to provide a base for future environmental assessments for planned infrastructure projects.  As such, the Transportation Master Plan (TMP) is far more than a guidance document – it is an important part of Official Plan (OP) and Environmental Assessment (EA) processes.  As such, what the TMP says really matters – and what it depicts on its schedules is really important.

Shifting From Auto-Focus to People Focus

Although the TMP includes a number of good measures regarding the direction that policy development may take, such as the development of a Complete Streets policy, and calls for a the development of a Transit Master Plan, what is clear is that the Transportation Master Plan has at its heart a focus on moving motorized vehicular traffic, rather than moving people.  While I believe this is the wrong focus, after a number of years of production, I acknowledge that we have probably gone too far down this particular road to turn back now.  While it would have been my preference to include robust policy and guidance for AT and transit in the TMP, I understand that we may need to wait until the time of future updates in order to have alternative transportation options for citizens treated on the same level as cars and trucks.

The TMP’s deficiency in considering cycling, walking and transit is all the more reason that the Plan should establish clear direction for the preparation of an Active Transportation (AT) Plan and a Transit Master Plan.  The TMP should direct the preparation and completion of both of these plans by incorporating timeframes for their completion.  The City should undertake to complete these plans, and budget for their completion.  The Plans themselves should include goals, objectives, timelines for action item implementation, as well as budgets. 

The Official Plan review should be informed by the completion of both the Active Transportation Plan and the Transit Master Plan.  While I understand that this may hold up the review of the Official Plan, what Council and the public heard on June 24^th at the information session was that once a new transportation element appears in, or is removed from Official Plan, it is difficult for changes to be made.  With this in mind, and with questions remaining about the need for an expanded road system to meet the needs of a population which is expected to grow only modestly between now and 2031, it is important that our Official Plan include development direction based on a broad range of evidence.  The completion of the OP review should be informed by the completion of the Active Transportation Plan and the Transit Master Plan.

A Real Long-term, Sustainable Focus

The TMP lays out three scenarios for consideration.  Each scenario depicts what the City’s future road network will look like in the future.  In the “Do Nothing” scenario, which the text of the Plan indicates that only approved projects will be constructed (although it does not identify what “approved projects” are), and in which the schedule depicts no new additions to the road network, there appears to be little new construction.  The “Auto-Focused” scenario includes a large number of new roads.  And the “Sustainability-Focused” scenario includes slightly fewer new roads, and mentions that consideration will be given to alternative transportation infrastructure.  This last scenario is recommended as the preferred choice of the three.

The “Sustainability-Focused” scenario is hardly sustainable.  The significant number of new and expanded roadways it proposes has not been vetted through a needs analysis based on current data.  Data used to propose this network goes back to the 2005 Transportation Study.  Data projects a modal split of only 2% for transit riders, yet even back in 2003, the modal split was 3%, and has since risen to between 4% and 5%.  In 2031, given current trends, we can expect it to be even higher.

There is no modal split calculated for alternative transport (AT) users, despite the “Sustainability-Focus” scenario’s stated desire to have AT play a more significant role in trip generation.

Further, there is no discussion about Transportation Demand Management (TDM).  TDM can likely play an important role in alleviating congestion at peak periods where levels of service have become degraded.

Also, there has been no consideration of other activities to reduce congestion beyond expanding existing and building new roads.  The implementation of High Occupancy Vehicle lanes and car-pooling initiatives should be considered by the TMP.

Getting Serious About Sustainability

For a truly long-term, sustainable option for the development of our transportation system, it’s important that right calculations be used to justify expanding the system.  What is clear is that the right calculations to justify the expanded road network as depicted in the “Sustainable Focus” scenario have not been used, as they have failed to consider an appropriate modal split, or consider Transportation Demand Management.

Further, the outcomes depicted in the “Sustainable Focus” scenario include only the development/enhancement of existing roads to serve the needs of vehicles.  While the TMP does identify active transportation elements and refer to the development of a Complete Streets policy, these non-vehicular based elements exist outside of the 3 scenarios, and will not inform how the road network is to be considered for development through the EA process.

In recent comments made by the Ministry of Environment and Climate Change (MOECC) regarding the EA for Second Avenue, the MOECC requested additional information on both modal split and TMD, as it appeared that the City had not considered either as part of the justification for moving forward with plans for widening Second Avenue.  Given that the TMP is intended to be a part of the EA process, fulfilling Master Plan requirements, it is not unreasonable to assume that a similar response from the MOECC may be received should this plan move forward based on an unsupported modal split, and without the benefit of TMD considerations. 

Design Standards

It’s encouraging to see that design standards for roads have been included in the TMP.  However, these design standards don’t always match the type of active transportation elements depicted on the AT schedules.  Further, in some cases the AT schedules appear to include gaps (the Kingsway between Bancroft and the downtown comes to mind) for cycling infrastructure where the TMP’s design standards suggest cycling infrastructure should be present.

Cycling Infrastructure

There should be greater direction regarding the timing of cycling infrastructure implementation on existing roads.  If we are to achieve a minimum grid, we can’t simply rely on infrastructure being included at the time of road repair.  Retrofitting existing roads will be necessary.  Council has already started budgeting for retrofits.

The Active Transportation Plan will hopefully address these matters, although again, it’s unfortunate that they weren’t addressed in the TMP.

Pedestrian Infrastructure

Safe locations for pedestrians to use to cross roads should be prioritized – especially where they coincide with bus stops.  The needs of pedestrians should be considered at the time that roadwork is to be considered.

Final Thoughts – Opportunity Costs

The economic success of any community is contingent upon a number of factors.  The types of jobs which our community is strategically positioned to pursue include well-paying, professional jobs in the mining supply, public service, health and education sectors.  In short, Greater Sudbury finds itself in competition with other communities who are trying to attract the Creative Class.

The Creative Class does not fear congestion – it embraces it.  The Creative Class knows that a successful, livable City is one in which congestion is present.  The Creative Class wants to live in communities which are transit-friendly, and cater to the needs of cyclists and pedestrians.

Cities which have emphasized the priority of fighting congestion have found that they have become less desirable locations for building the Creative Class economy due in large part to the design of the cities that they have constructed.  If fighting congestion is a priority, a city will build wide streets, and lots of them.  It will tend towards sprawl.  It will create an environment where walking and cycling isn’t a real option, and car ownership is a requirement.  In non-congested cities, transit is an economic drain rather than a healthy, accessible alternative.

For too long, our City has prioritized cars over people.  If we are going to become a destination for creative class jobs, we need to start getting serious about shifting the development paradigm from one which has emphasized unsustainable sprawl towards one founded on the principles of sustainability. 

I believe that the Transportation Master Plan, in its current form, will prove to be an impediment to building the City of Tomorrow that we will need to become to remain economically competitive into the 21^st Century.  The numerous roads proposed by the so-called “Sustainability-Focused” scenario are fiscally unsustainable based on the expected growth of population and jobs.  Further, paying for the operational costs associated with these new roads will meant that we won’t be able to pay for other initiatives which would be better able to facilitate the transportation options that we need to promote livability in our community.

That’s why I hope that Council decides to wait until the Active Transportation and Transit Master Plans have been completed before proceeding to finalize the review of the Official Plan.  It’s also why I hope that Council will consider requiring a review of the modal split used to justify the expanded road network, and require that Transportation Demand Management initiatives be considered when running the model before the TMP is posted to the Environmental Bill of Rights for public comments to the Ministry of Environment and Climate Change.

Thank you for considering these comments.

Sincerely,

Steve May

(opinions expressed in this blog are my own and should not be interpreted as being consistent with the views and/or policies of the Green Parties of Ontario and Canada)