What is going on? After again approving the Class B Environmental Assessment (EA) for Second Avenue on March 26, 2015, bump-up requests submitted to the Minister of Environment and Climate Change (MOECC) have forced that provincial ministry to take a close look at the City of Greater Sudbury’s EA process and product for the project. And, once again, the MOECC has had to hold off on making a decision on the bump-up requests (also known as Part II Order requests) because the City has again failed to do the required work for the EA submission to be determined complete.
Class B EA - Numerous Deficiencies Identified
In a letter to the City of Greater Sudbury’s Roads Engineer, Mr. David Kalvianinen, P.Eng., from Annamaria Cross, Manager, Environmental Assessment Services Section of the MOECC, dated May 13, 2015, numerous deficiencies with the City’s EA process for Second Avenue are highlighted. While most of these appear to be minor oversights (such as not providing copies of minutes of meetings with the public or agencies), there are a couple of critical observations which may end up being fatal to the project.
Specifically, the MOECC questioned the need for the Second Avenue widening to 5 lanes between Donna Drive and Scarlett Road due to the absence of traffic modelling data and analysis. The Project File (page 5) identifies the existing average traffic volume on Second Avenue as being 15,000 per day. The Problem Statement in the Project File indicates that the issue with Second Avenue is “existing and future traffic congestion”. Presumably, that must mean that the 15,000 volume number makes Second Avenue a congested road already – and that it’s only going to get worse in the future.
As an aside, I’ve no idea what the number 15,000 average volume number actually means. I’ve read the project file, and there is no definition. Not being a traffic engineer, I’m at a bit of a disadvantage here. Are we talking about cars? Total vehicles? Just motorized vehicles, or is it the total number of people moved (passengers in cars, or on the bus). I just don’t know. One of the purposes of a Project File is, however, to provide the public with information about the project which is understandable. When undefined jargon such as “average traffic volume” is used, the public is put at a significant disadvantage in terms of comprehension.
Existing and Future Need for Expansion
Let’s come back to present and future congestion for a moment. In response to those who had requested a Part II Order from the MOECC in 2014, the City indicates that “In the case of Second Avenue, by the year 2031, if no transportation improvements are made, the northbound traffic volumes will reach a critical capacity point to where transportation improvements should be made.” (page 14). This suggests to me that while Second Avenue is currently considered congested, it hasn’t yet reached a critical point. The City, in taking a proactive approach to widening the road, will stave off Second Avenue arriving at that critical point by 2031. So far, so good.
But where are these numbers to support these conclusions coming from? That’s not just my question – it was one asked by the MOECC. You see, the City based the entirety of its Project File for the Second Avenue EA on work undertaken for the preparation of the Transportation MasterPlan (TMP). The TMP was originally supposed to have been completed in 2013, but it was just released to the public last Friday afternoon. Council received an update on the TMP at its regular meeting on Tuesday, May 12th. The Plan is not yet in final form, as further consultation with the public is first required, to be followed up by approval from Council.
Transportation Master Plan - Unavailable
The contents of the TMP were not available to the public prior to the finalization of the Second Avenue EA – an assessment which relied on conclusions and presumably upon data found in the TMP. The public, and those members of the public and organizations which ultimately filed Part II Order requests with the MOECC, didn’t have access to the data on which the City was relying for its conclusions to move forward with Second Avenue. To me, this is truly incredible.
How can the public fully participate in a public process when background data isn’t made available? The answer is simple: it can’t. One of the fundamental ideas behind the concept of public consultation is to provide the public with as much data and information as possible, so that everyone has the same starting point. In the case of Second Avenue, the public was put at a severe disadvantage in understanding how the City arrived at its conclusions regarding Second Avenue, because there was never any data provided to the public to justify those conclusions.
Of course, this lack of data was mentioned time and again in the bump-up request letters – those filed recently in 2015, and the earlier ones filed last year. Identifiable members of our community, including John Lindsay and Dot Klein, took a lot of public heat for delaying the Second Avenue widening last year, but one of the main reasons for the bump-up request in the first place had to do with looking at alternatives to address the issue of congestion because there appeared to be no data to justify the City’s conclusion that widening Second Avenue was warranted.
Charging Ahead
That the City charged ahead once more with the EA process in absence of providing supporting data to the public is simply shocking. It shouldn’t have happened in the first place, and there is absolutely no excuse for it having happened again.
Now, about that data. The TMP has finally been released, albeit not in its final form. The TMP does assess congestion and other transportation issues up to the year 2031, by looking at existing conditions. 3 scenarios were developed which then assessed where we would be at in 2031 if we undertook certain actions.
Unrealistic Scenarios
In the first scenario, known as “Do Nothing”, the City fails to undertake any actions with the transportation system between now and 2031. It’s an unrealistic scenario, but it has some value. The TMP uses the “Reference” growth scenario from the Background Growth Study prepared as part of the 5-year Official Plan review, so just 10,500 persons are projected to be added by the year 2031.
In the unrealistic “Do Nothing” scenario, Second Avenue in its entirety between the Kingsway and Bancroft is coloured bright red – which signifies that its volume to capacity ratio is greater than 0.8 – meaning that it will be congested, and action should be taken to relieve this congestion.
Red, Orange and Green Roads
Given that the EA Project File’s Problem Statement referred to “existing and projected capacity deficiencies” as a reason for widening the road, one might expect to find a similar red colouring for Second Avenue on the existing conditions map. Certainly, that was my expectation. Interestingly, though, that’s not what we find at all. Second Avenue between the Kingsway and Scarlett (or Kenwood – it’s difficult to tell – see page 13) is coloured orange – meaning that it hasn’t yet reached a critical level of congestion (orange roads have a volume to capacity ratio of between 0.6 and 0.8, and fall into something called a Level of Service category “D” (where A through C are green and good, while D and E are red and bad – with D being defined as the “threshold for acceptable road performance” – see page 10). Below Scarlett, Second Avenue is a nice bright green.
So what was that about those existing conditions again? If the City’s is basing the need to widen Second Avenue on existing conditions, and those conditions depict a volume to capacity of ration in the orange range, does that mean that all roads with a current level of service in the D category are being considered for expansion in the TMP? If appearing at the threshold of acceptable road performance is the trigger for expansion, then I’d expect to see the TMP recommending all orange roads to be expanded in the same manner that Second Avenue has been recommended.
Even a quick look at the existing condition maps on pages 11 through 13 will confirm that numerous orange roads in the D category are not being recommended for upgrades in the TMP – not in the short term (as Second Avenue has been identified) and not in the long term. Arteries like Radar Road, Falconbridge between the Kingsway and Lasalle, Kathleen west of College, and Brady between Broadway and Paris – none of these have been identified for expansion in the TMP based on their existing “D” level of service.
Trigger for Expansion
So existing conditions alone don’t appear to be enough of a justification for expansion. That’s interesting, but not completely determinative. We know that in the unrealistic “Do Nothing” scenario, Second Avenue between the Kingsway and Scarlett turns from orange to bright red. So perhaps it’s the combination of both existing and future capacity deficiencies that leads one to conclude that Second Avenue ought to be expanded now (note that the Problem Statement in the EA, while it refers to both “existing and future capacity deficiencies” as a justification for expansion, it does it in such a way as to suggest that these capacity deficiencies are discrete issues, and does not hint that they are to be considered in combination, as I’m about to do. A casual read of the EA Project File – someone who doesn’t have any data in front of them to refer to, would conclude that existing conditions alone would be enough to trigger the expansion).
Clearly, when you contrast a number of roads coloured orange on the existing conditions schedules with those coloured red on the Do Nothing schedules, it’s easy to see that Second Avenue isn’t the only orange road which turns red. Radar Road stands out – it’s a pretty major route for people travelling from the eastern part of Hanmer to take to get to Garson and New Sudbury. Yet, the TMP is completely silent on the need to upgrade Radar Road in any scenario, including the TMP’s other completely unrealistic “Auto-Focused” scenario – the one where the City goes completely road-happy, expanding 10 existing roads and building a dozen new ones, including the Maley Drive and Barrydowne extensions.
Interestingly, Riverside Drive appears to be coloured red on both the existing conditions schedules and on schedules to the Do Nothing scenario – so it’s a road that’s congested now and will remain congested into the future – but there are no plans to alleviate congestion on Riverside through expansion in the same way that the City seems to want to push ahead with Second Avenue – a road which isn’t even considered congested at present.
So, based on the City’s own TMP, there appear to be roads more worthy of expansion due to existing and future capacity issues than Second Avenue, yet the TMP recommends that a high priority be given to Second. This recommendation appears to be based on future deficiencies in an unrealistic traffic scenario – one in which the City does nothing to expand capacity on existing streets or build new ones over the next 15 years.
Need for Expansion Unclear
The MOECC has indicated to the City that the need for the project wasn’t clear at the time of the finalization of the EA, because the TMP wasn’t available for public or agency scrutiny. Now that the TMP is available, it remains unclear whether there is an actual need to expand Second Avenue. Certainly, the rationale to do so based on current issues appears to be right out the window – other roads with a Level of Service Category “D” rating aren’t being considered for expansion (like Radar Road) – and some roads which are already identified as being congested in the TMP aren’t even discussed in terms of expansion (such as Riverside).
With regards to the future, the only justification for expansion appears to be if the City fails to take any action whatsoever to expand its road network. That seems unlikely, given that new roads such as Silver Hills Drive, have already been approved by the City through the subdivision process, along with a number of other development-driven roads. And then there’s Maley Drive, which we keep hearing that we’re on the cusp of proceeding. Neither Silver Hills nor Maley Drive were a part of the “Do Nothing” scenario in the TMP.
In the Auto-Focused scenario, and in the Orwellian-named “Sustainability-Focused” scenario (which will see the addition of alternative transportation measures included as an add-on to a road network expanded almost as much as contemplated in the High Focus scenario – but I suspect that’s a whole other blogpost, so I’ll leave it alone for now), Second Avenue south of the Kingsway is coloured a bright green. So it’s just in the one “Do Nothing” future that we have to be particularly concerned about congestion on Second.
Traffic Demand Management and Modal Shifts Ignored
It is interesting to note, however, that none of the 3 scenarios included in the TMP consider a couple of pretty important things, such as future changes to the way in which the public travels (called “modal shift”), and future changes to when travel occurs (there are measures that many other cities are using to spread traffic out so that not everyone is travelling at the same time – these measures are known as Traffic Demand Management). Although the TMP ostensibly claims to want to get people out of their cars and onto bikes, buses and the sidewalk – the traffic projection forecasts included are all based on the assumption that in 2031, we’ll still all be getting around the same way that we are today.
Out-of-Date Data
Worse, those forecasts are actually based on data which informed the 2003 Transportation Plan, so that data is actually at least 12 years old now, and by 2031 it will be almost 30 years out of date.
Does anybody really think that the percentages of people using cars in 2031 will be the same as those using them in 2003? With rising energy costs, rising vehicle and insurance costs, and a global movement away from personal motorized vehicular transportation – coupled with a plan that actually should go some way to shift people out of their cars – it’s beyond reasonable that the TMP is using a modal forecast from 2003 to determine our needs in the year 2031.
Even numbers included in the Transportation Master Plan seem to suggest that modal shift is already occurring. The TMP indicates that data from 2003 was used because, “it was deemed that travel patterns in the city had not changed significantly in the years since the household survey was undertaken and that survey results reported in the 2005 Transportation Study were still representative of existing conditions in the city.” (page 102). However, elsewhere it is shown that transit ridership rose 23% since between 2003 and 2011 (and was up at 25% in 2008 – at the height of the bull market – 4.5 million trips) – even though the population has grown by just 2.6% (pages 16-17).
"Reasonable and Feasible"
The MOECC raised the these issues in its letter to the City. “The alternatives [to widening Second Avenue] only considered improvements through widening roads versus the do nothing alternative. The inclusion of other reasonable and feasible (emphasis added) alternatives such as Transportation Demand Management and modal shift would be valuable to the analysis”.
That’s bad news for the Second Avenue EA – clearly, these two “reasonable and feasible” alternatives weren’t considered by the City. This comment is also bad news for every other roads project which might now come forward in the City which uses the TMP as a basis for justification. City engineers and our municipal councilors should take note of this: the MOECC is suggesting that Traffic Demand Management and modal shift be considered when assessing alternatives to establish the need for a new road project. These issues came up at the Council table on Tuesday night, when Councilor McIntosh (Ward 9) questioned the consultant about the TMP. The consultant indicated that these matters could be included in the final version of the plan – yet clearly if the consultant does this, the plan its entirety will need to be turned on its head, as all forecasts and scenarios will have to change – which would also likely lead to a change in recommendations, including the possibility of changing the recommendation to prioritize widening Second Avenue (this is why a public body like the City of Greater Sudbury shouldn’t rely on an incomplete study to determine whether capital projects proceed or not).
With all of this in mind, has the City actually demonstrated a need for expanding Second Avenue? To me, it doesn’t look like a particularly strong case. While there are clearly some issues with Second Avenue, there seem to be better candidates for infrastructure improvements. Why then has the City been pushing so hard with Second Avenue? Remember, this project is going to cost the taxpayers….
How Much Does That Cost?
Uhm, how much is widening Second Avenue going to cost taxpayers? The March 2015 Project File references a cost of less than $2.3 million (see page 10). Yet, the media have been using a different number - $6.6 million – one which includes the complete anticipated project costs, (see: “City to try again to complete $6.6 million Second Avewidening”, the Northern Life, March 25, 2015). Why the difference?
Well, it’s been suggested that the City is deliberately using a misleading and low figure in order to keep the Environmental Assessment at a B level, rather than having it undergo a more comprehensive C level assessment. Although sidewalks, cycling infrastructure, bus bays, traffic lights and stormwater improvements are now all planned as part of the projects (bumping up costs), the initial costs as per the EA were limited to only those costs for the widening of the road itself (see page 10 of the Project File – note the 9 additional items which were added to the original scope of work for the “purposes of cost effectiveness and efficiency”).
Gaming the System
By not including these other improvements as an original part of the project, the City has been able to maintain the charade of artificially low costs – and keep the Environmental Assessment at a B level (where project costs must be less than $2.3 million). The Ramsey Lake Stewardship Committee, in its letter to the MOECC for a Part II Order request, has probably captured this issue best. The RLSC wrote,
“Since a new Transportation Master Plan (available for initial public consultation May 2015) may speak to how the city will address the transportation of people instead of just cars, we feel it prudent for any new road designs to reflect a more broad approach to transportation and to consider more than the movement of a single passenger vehicle. Had a more up-to-date TMP been available, perhaps building sidewalks to move people on foot, bike lanes to move people on bikes, a pedestrian crossing, and adding bus bays would have not been considered ‘add-ons’ by the proponent. In 2014, they were not considered part of the initial cost of this roadwork (under $1M). (Page 10 of the Project File) Had these non-car related features been initially considered, a Class C EA would have been required due to the elevated cost of over $2.7M. This piece-mealing of costs, to avoid a Class C EA, is unacceptable to the community, as it does not allow for meaningful consultation in a cost-effective and community-minded way. “Projects must not be piece-mealed with component parts or phases being addressed separately” as stated in the Municipal Class Environmental Assessment rulebook for municipal roads, water and sewers. Without a Class C EA, citizens were not provided with other options like building a three-lane road for the entire stretch of 2nd Ave, improving stormwater ditches and using the saving in asphalt for better overall stormwater management.” (see: “Letter to the Honourable Glen Murray, Minister of Environment andClimate Change, Re: Notice of Completion – Municipal ClassEnvironmental Assessment – Second Avenue (MR72) InfrastructureImprovements. Notice issued April 1, 2015”, Ramsey Lake Stewardship Committee, April 29, 2015)
Some have suggested that this is piecemealing of projects is akin to “gaming the system”, but it appears to be a practice which isn’t unique to the City – and one which has largely been allowed to proliferate due to a lack of public participation in the EA process. The EA process is proponent-driven, and subject only to some small form of (largely) administrative oversight where bump-up requests are made to the MOECC. It should be noted that these bump-up requests, largely made by the public, have not been subject to a lot of success at the MOECC.
Merits of Part II Order Requests: Yet To Be Determined
Regarding Second Avenue, the MOECC hasn’t said anything about the scope of the EA yet – that will be a part of what the MOECC will have to consider with regards to the bump-up Part II Order requests, as it was an issue identified by the 6 parties making those requests.
Right now, the Part II Order requests are on hold, pending the City finally doing what is required of it to have a complete Level B environmental assessment. While I don’t want to be in a position to second guess how the MOECC might deal with the Part II Order request as a result of the costs issue (along with several other environmental issues which appear to have some legitimacy – especially those involving stormwater – and then the whole issue of need), I believe it would be incumbent upon our elected officials to start asking hard questions about whether it can be realistically expected that Second Avenue has a chance of proceeding with a Class B assessment.
And if it’s not to proceed as a Class B, that means that it will have to go back to the drawing board in its entirety, and we’ll need to start the process over, correctly this time, with a Class C assessment – one which takes a deeper look at alternatives.
(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)
References:
Link to the Draft Transportation Master Plan (TMP), 2015
Link to the Project File, Second Avenue Class B Environmental Assessment
Link to Minnow Lake Restoration Group's Second Avenue Reconstruction Issue Page
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