Wednesday, January 27, 2016

No Social License for Maley Drive Phase 1 Project

The $80.1 million Maley Drive Extension Project, Phase 1, lacks the social license necessary for it to proceed at this time. While the price tag for Maley has ballooned, the project’s scale and scope has shrunk to a shadow of itself, with the latest proposal being only for half the road that was proposed more than 20 years ago – back when the first technical evaluations were conducted for the project.   Although Sudburians have heard how Maley will lead to further investment and economic development in our communities, there has never been a business case made public which supports these suppositions.  A recent Cost Benefit analysis was prepared in support of the project, but it determined that there would be very little benefit to the municipality and all of its taxpayers.  Data used to support that analysis was over a decade out of date.  

The original environmental assessment, conducted over 20 years ago, was based on underlying socio-economic assumptions and a degraded physical environment from a past era.  The more recent 2008 environmental update reaffirmed these assumptions without taking a critical look at them.  Since then, the presence of threatened species has been positively identified in the watershed that Maley will traverse, and yet there have been no plans to update the 21 year old Environmental Assessment with this new information.

And almost unbelievably, the project that is now being considered for funding by senior levels of government has never been endorsed by any municipal Council.  Council has, in the past, endorsed a road project which would have extended from MR 35 (Elm Street) in the west all the way over to Falconbridge Road in the east – but that’s no longer the project that is moving forward for federal funding at this time.

Residents, businesses and taxpayers have not had the opportunity to provide meaningful public input into the Maley Drive Extension project at any time since the project was conceived.  The Maley Drive Extension Project, Phase 1, will be one of the most expensive pieces of public infrastructure which municipal taxpayers have ever been asked to invest in.  And yet we are being asked to do so by taking a leap of faith – faith that old growth models from the latter part of the last century will remain valid over the 30 year lifetime of the project.  We are to take it on faith that assessments of the physical and socio-economic environment from before the Great Recession will remain relevant over the next 30 years.  We are to believe that the project will bring a net benefit to our communities, despite the costs, and in absence of any critical evidence – and in the face of contrary evidence from similar roads projects.  

The price is too high to proceed without a social license from area residents.  If we are to go down the path of massive public spending, we must do so with our eyes open and with a good understanding of what we are going to get for our money – and what the consequences are of spending that money on Maley, rather than on other city-building projects.

Maley Project - Scope & Scale

When originally conceived, the Maley Drive project was intended to upgrade some existing roads in the City, and to build a connection between them across the northerly boundary of what was then the City of Sudbury.  Upgrades would be made to the 2-lane Lasalle Extension from MR 35 to Frood Road, with the Lasalle Extension being  4-laned between Frood Road and Notre Dame.  At a point close to where College Boreal has since been constructed,  a new two-lane road was intended to veer northeast toward MR 80, where it would intersect with a cloverleaf interchange.  That new road would head west to Barrydowne, where it would connect with an upgraded, but still 2-lane Maley Drive all the way to Old Falconbridge Road. 4-laning was contemplated between Old Falconbridge Road and Falconbridge Road.

The original 1995 Environmental Assessment was prepared in support of the project I’ve described above.  The 2008 Environmental Assessment addendum, prepared to update the original EA, was based on a modified version of the original project – all of Maley would now be 4-laned from Frood Road in the west to Falconbridge Road in the east.

After the completion of the 2008 Environmental Assessment Addendum, the City went out looking for funding from the province, only to be rebuffed in its efforts.  When the Building Canada federal funding initiative came along after the 2008 recession, Council directed staff to apply to the government of Canada to get Maley moving.  In 2014 or 2015, it seems that the City submitted something to federal Department of Infrastructure  - but that proposal was not the one contemplated in the Environmental Assessment.  

"Phases" 1 and 2

What the City has applied for under Building Canada is something called “Phase 1” of the Maley Drive Extension project.  Phase 1 is estimated to cost $80.1 million.  It will consist of building a new 4-lane road between the Lasalle Extension at College Boreal in the west, with a cloverleaf interchange across MR 80, to link up with Barrydowne Road in the east.  Between Barrydowne Road and Falconbridge Road, Maley Drive will be refurbished, but will remain a 2-laned road with a level rail crossing. 

The sections of Lasalle between MR 35 and College Boreal, and the upgrades previously contemplated to the existing part of Maley Road (which include grade separation at the CPR crossing, and a roundabout at Barrydowne and Lansing Avenue) are not included in Phase 1, but rather consist of what is now being referred to as “Phase 2”.  The City has at this time not sought any funding from senior levels of government for Phase 2, nor has it been setting aside annual funding for Phase 2 in the same way that it has for Phase 1.  Phase 2 is currently estimated to cost about $50 million dollars, but the City’s own Roads Director believes that real costs will be higher (see: “Maley project feasible: report,” the Sudbury Star, November 5, 2015. Note that the City has updated its website since the November 5 publication, and now is using the figure of $70 million for Phase 2).  The City of Greater Sudbury will be on the hook to figure out a way to fund Phase 2 all on its own.

According to the Sudbury Star, when asked about Phase 2 in November, 2015, Greater Sudbury’s Mayor indicated that he was “not aware” of it.  Mayor Bigger did acknowledge that “there may be completion to a different length of road construction that would add up to more dollars” – but did not seem to realize that this “different length” consisted of elements which City Council and residents have all along thought would be included in the Maley Drive Extension Project, but which were removed from funding requests to senior levels of government. 

Clearly, Mayor Bigger isn’t the only one who has been unaware of what the Maley Drive Extension project is intended to be.  Local media continues to misrepresent the project as a “ring road” along the northeastern part of the City (see: “Decision on Maley expected within months: Bigger,” the Northern Life, January 16, 2016, which erroneously indicates that “Maley Drive “would complete a ring road around the city”) .  While it is true that some in our community have talked about eventually linking Maley to the Southeast by-pass which currently terminates at Highway 17 and the Kingsway just west of Coniston, there really aren’t any serious plans to do so, and no technical assessments have ever been prepared in support of this linkage.  Further, a “ring road” is usually thought of as something which goes completely around an urban area.  There is currently no northwest by-pass – and none has ever been seriously talked about at all.  And yet the term “ring road” is often used to describe the Maley project.

Does Past Findings Still Hold True for Smaller Project?

Instead of even a quarter of a ring, what Greater Sudbury will be getting for $80.1 million is something much smaller – essentially just a new road between College Boreal and Barrydowne Road.  While this new 4-lane road will connect existing roads (the Lasalle extension and the existing portion of Maley Drive – both of which are just 2 lanes), it is unclear if the road will be able to accomplish the tasks for which some evidence exists and suggests could be accomplished – namely reducing congestion. 

Past forecasts for how Maley Drive would reduce congestion on Lasalle Boulevard and the Kingsway were made with the assumption that what we are now calling Phase 1 and Phase 2 would be both be built – one right after the other (or in combination with one another, depending on which building plan is looked at).  These past forecasts also did not take into account how improvements made to the Lasalle/Notre Dame intersection has eased the flow of traffic on Lasalle Boulevard.  Largely, data from the 2005 Transportation Master Plan has been used – and even the 2015 Cost Benefit analysis was based on this old data.

Further, the 1995 Environmental Assessment and the 2008 Addendum to it were both based on the new Phase 1 and Phase 2 projects proceeding simultaneously.  We now know that only Phase 1 is likely to be funded – and Phase 2 may never be built.  Do the socio-economic assumptions made in these historic assessments still hold up when only part of the project is to be constructed?

Not 1 Project, But 2

What we are doing with the Maley project is like building half of a house.  We may be pouring a very sturdy foundation and putting up some really great walls on the first floor.  But the stairway leads up to nowhere and when it rains, there’s very little shelter to take because we haven’t added a roof.  A house built like this isn’t much of a house, no matter how good the planning was that when into its construction.  The same is true of the Maley Drive project – we can’t assume that Maley is going to work with only Phase 1 being constructed.

I understand that our City likes to develop roads projects in chunks – referring to them as “phases”.  But really, we should be looking at these individual chunks as stand-alone discrete projects, and not just as a phase of a larger project.  We look at other types of development this way – subdivision approvals come to mind.  Technical analyses are produced for the entirety of the project to determine its viability and sustainability, and phasing decisions are based on other considerations, such as how many units can be sold in a given timeframe, and what’s the best time to extend sewer and water pipes.

Make no mistake – the Maley Drive Extension, Phase 1 project is a discrete road project, separate from Phase 2.  The City’s website makes this clear: Phase 1 has benefitted from a higher level technical analysis than has Phase 2 (see: “Maley Drive Extension: An Affordable Investment that will be Managed in a Fiscally Responsible Manner,” the City of Greater Sudbury, undated.  Compare the first two bullet points).  The way in which each project is being funded also suggests that we are talking about two projects, and not just one.  

The Realm of Uncertainty

That should worry our Council and Greater Sudbury residents.  After all, our Council has never endorsed only a partial build of Maley.  Certainly, there has never been any public consultation ever undertaken on constructing just Phase 1 – while leaving Phase 2 to be built at an unspecified future date without $70 million (and counting) of funding that we don’t have, and don’t know how to get.  We’re not talking about a phased project here – we’re clearly talking about two discrete projects, only one of which is intended to be funded right now.

Residents living along Barrydowne Road between Lasalle and Maley Drive in particular ought to be very concerned, as a new 4-lane highway will be dumping all sorts of new traffic at an intersection close to their homes.  Barrydowne north of Lasalle is largely a residential area.  If Maley Drive east of Barrydowne remains a 2-lane road, it is probable that much of that traffic from the new 4-laned westerly extension will exit south through Barrydowne, rather than risk traversing a 2-laned Maley with a level CPR crossing.  And yet these residents have never been asked what their thoughts on this circumstance might be.
Of course, I might be wrong.  I’m not a traffic expert.  But I’d love to see the traffic modelling which has been produced by the City which shows anticipated traffic flows from a half-built Maley.  Until then, my evidence-based assumptions remain fact free – just as fact free as the City’s assumptions about traffic which have never taken into consideration the impacts of building Phase 1 but not Phase 2.

Cost Benefit Analysis and Business Case

The November, 2015 Cost Benefit report from AECOM consulting identifies just two benefits from what it calls the Maley Drive Phase 1 project over the 30-year lifetime of the road.  These benefits include a reduction in travel time for motorized vehicles (both personal vehicles and truck traffic), and a reduction in greenhouse gas emissions.   Upon a closer look, the analysis behind both of these “benefits” are considerably flawed, however it does stand to reason that at least initially, there may be a savings of travel time accrued to motorists and trucks.

The AECOM analysis is, however, not based on what the City is referring to as Phase 1 of the Maley Drive project.  Indeed, it contains elements of the unfunded and unlikely to ever be built Phase 2.  Specifically, the AECOM report looks at that section of Maley between Barrydowne Road which extends along the existing corridor to about 300 metres east of Lansing Avenue.  Importantly, Phase 2 of the Maley Project contemplates a traffic roundabout being installed along a 4-laned section of Maley at Lansing.  We know, however, that no such roundabout is a part of Phase 1 of the project, and that Maley will only consist of 2 lanes east of Barrydowne.  This error alone is enough to cast some doubt on the findings of the AECOM report.

Traffic Assumptions

More importantly, however, is the report’s findings that travel time will be saved by the public and the trucking industry.  These findings were based on the use of data from the 2005 Transportation Master Plan – and brought forward under the assumption that traffic patterns in the City will not change for the next 30 years.   Basing travel assumptions out to the year 2045 on data from 2005 seems absolutely ridiculous when travel trends are considered.  While it is true that there is little recent data available about Greater Sudbury traffic trends (even the recent 2015 Draft Transportation Master Plan uses 2005 data – possibly one of the reasons that the Plan hasn’t been adopted by Council yet; see Section 2.2.2: "Transportation Study Report (draft)," City of Greater Sudbury, April 2015), it is not difficult to extrapolate that some significant trends evident throughout North America will likely impact the way in which Greater Sudburians get around our City over the coming decades.

Already, the provincial Ministry of Environment and Climate Change has told the City of Greater Sudbury that it needs to consider traffic demand management strategies for new roads projects (see: “Letter to Mr. David Kalviainen, Roads Engineer, City of Greater Sudbury, re:  Part II Order Requests – Second Avenue Road Infrastructure Improvements,” Ministry of Environment and Climate Change, May 13, 2015  MOE letter).  The MOECC’s letter regarding Second Avenue would have been available to AECOM prior to the preparation of the Cost Benefit report, but it was ignored. 

What the MOECC said about Second Avenue will not prove to be a one-off comment – indeed, throughout North America, cities are looking at ways of maximizing the use of their transportation networks at times of day in which they are under-utilized.  Spreading out rush hour can – and does – have a huge impact on easing congestion at peak periods. It has more of a positive impact on reducing congestion, in fact, than building new roads.

Understanding What's Driving Congestion: Induced Demand

Studies have shown that building new roads does not ultimately reduce congestion.  These studies explore a concept called “induced demand”, which shows how when a new road is built, it often leads to more traffic on all of the roads in the transportation network, because it has initially made travelling by car a little easier.  New roads often open up new areas to development, and where development occurs, congestion follows. The more roads we build, the more congestion we get.  That’s a hard lesson that we’ve learned from our experiment with 20th Century suburban design.  But it is a lesson nonetheless – one based on facts and evidence.

And yet AECOM chose to ignore these facts and evidence, and tossed “induced demand” into the wastebasket.  AECOM refused to explore how traffic demand management might actually reduces congestion – probably because the City of Greater Sudbury has refused to take a serious look at this tool, choosing instead to hang its congestion reduction hat on building new roads alone – even though the evidence does not support this strategy as one that is sustainable – or even based on evidence and experience.

AECOM's Emissions Greenwash

AECOM also decided to calculate the tonnage of greenhouse gas emissions saved through the reduction in travel time which it identified as a benefit.  Again, since the reduction in travel time benefit is specious given what we know about induced demand, it’s not at all clear that we can expect an actual reduction in greenhouse gas emissions.  Instead, because of induced demand, we should expect an overall increase in emissions.  But even if Greater Sudbury manages to buck the induced demand trend with Maley Drive, AECOM’s assessment of emissions makes zero sense.

AECOM believes that 2,459 metric tonnes of carbon per year can be saved thanks to an overall reduction in vehicular travel time, based on no changes in commuting habits between 2005 and 2045.  Even assuming that this is the case, AECOM does not account for greenhouse gas emissions which would be expended during the construction of the Maley Drive project.  Work undertaken by Sudbury Engineering Technologist Tom Price shows that the construction of Male Drive Phase 1 is likely to produce over 213,000 tonnes of CO2 – making emissions saving a wash based on AECOM’s own calculations.

Missing Benefits and Costs

How AECOM could have overlooked emissions from construction in their Cost Benefit report simply staggers the mind – and demonstrates that the entire report is completely flawed.  Yes, the entire report – because AECOM only looked at congestion and emissions.  What about all of those other benefits, such as short-term job creation we can expect from construction.  The City estimates exactly 780 jobs will be created, with a total economic stimulus to our community of $88.8 million (see: “Maley Drive Extension: An Affordable Investment that will be Managed in a Fiscally Responsible Manner,” the City of Greater Sudbury, undated).  Of course, the Greater Sudbury Chamber of Commerce believes the City’s jobs numbers are understated.  The Chamber claims that 1,400 jobs will be created, and $156 million will be added to the region’s GDP (see: “Maley Drive Task Force,” Greater Sudbury Chamber of Commerce, June 4, 2015).  Not sure who has the more believable numbers?  Me neither, as the City and the Chamber both haven’t cited any sources or provided any factual evidence on which their conclusions could be based.

Those are just some of the missing benefits that one might have expected to see in a Cost Benefit report for Maley Drive.  One can imagine the sorts of costs that have been left unevaluated on the other side of the ledger.  And some have wondered, including Laurentian University Professor of Economics, Dr. David Robinson, who took an in-depth look at the AECOM Report, and concluded that either it was not actually a Cost Benefit analysis, or it was a deeply flawed one (see: “Maley Drive: How Not to do a Cost Benefit Analysis,” Economics for Northern Ontario, November 6, 2015).

Environmental Assessment - Assumptions

The 1995 Environmental Assessment, which is currently not available to the public, appears to have been based on a number of assumptions.  Although I’ve never read this report, I am inferring what these assumptions might have been, based on what the 2008 Environmental Assessment addendum indicates.  It appears that the 1995 EA indicated that a truck by-pass would be desirable to get mining trucks off of Lasalle Boulevard, and that the mining and smelter sector believed that there would be financial benefit from creating a new east-west corridor in this location.  The former municipality of Sudbury also thought that it was a good idea to build a new east-west corridor north of Ramsey Lake – although why the former City believed this is not identified.

Largely, those assumptions have filtered down to us today as the primary reasons for investing in the Maley Drive project, although others have been added, including the need to facilitate economic development and to open up new areas of the City for development.  Neither the 1995 or the 2008 Environmental Assessments took either of those latter considerations seriously, likely because they’re not serious considerations (regarding how Maley won’t open up new areas for development, I’ve previously written more extensively about this myth in, “Taking a Closer Look at Maley Drive, Part 3: Expectations for Growth,” Sudbury Steve May, November 12, 2015).

But even the assumptions built into the 1995 Environmental Assessment should be challenged – especially after 20 years of further analysis.  Let’s take a closer look:

Truck Traffic

Getting the trucks off of Lasalle Boulevard appears to remain the most viable reason to build Maley Drive, in my mind.  I don’t think that many can argue that building Maley won’t lead to this outcome.  However, questions must be asked about the volume of truck traffic that is likely to relocate to a truncated version of Maley such as the one now being offered up as Phase 1.  And further, are the number of trucks currently using Lasalle Boulevard the same in 2016 as they were in 1995?  
To answer the first question, we just don’t know – because no one has run the traffic models which look at a new 4-laned road between College Boreal and Barrydowne running into an existing 2-lane road between Barrydowne and Falconbridge – one which contains a level rail crossing.

To answer the second question, again Sudbury’s Tom Price has taken a close look at truck traffic and has determined that the number of trucks which currently use Lasalle is actually less today than it was in 1995, thanks to changes in the mining and mineral sector that have happened in our communities over the past 20 years.  Increasingly, trucks are taking an alternate route through Valley East and Valley West to get to their destinations – one which has caused problems for rural residents living along MR 15 north of Azilda and west of Blezzard Valley.  While it may be that a new Maley, even in its truncated Phase 1 form, might be preferable to the present rural truck route through the Valley, the City has not done any studies which support that outcome. And indeed, neither the 1995 or the 2008 Environmental Assessments considered Maley in the context of the rural truck route (see Section 2.0 of the 2008 Addendum – and the direct reference to “Lasalle Boulevard” and the lack of reference to any other truck route).

Clearly, the traffic patterns on which these two assessments were prepared have changed.  Mining trucks are already travelling less on Lasalle than they were in 1995 – and they’re using rural routes to move between locations more than they were in the past (causing significant hardship for rural residents along this route).  Even the City of Greater Sudbury is now justifying the project by indicating that Maley will get trucks off MR 15 & MR 80 (see: “Maley Drive: A Solid Investment in the Social Future of the City of Greater Sudbury,” the City of Greater Sudbury, undated).  However, without actually having studied what the impacts might be, I believe it’s difficult to quantify to what degree the City will achieve success in this outcome.  

Can you imagine spending $80 million on a new road for trucks which isn’t ultimately used by trucks?  Now I admit that outcome seems unlikely even to me with regards to Maley Drive – but the fact of the matter is that there is little evidence to demonstrate what we are all taking on faith here about trucks and Maley, given the way in which truck traffic in our communities has evolved over the past 20 years.

And what can we realistically expect of truck traffic in the future?  Will shipping mining products by truck still be profitable as we get deeper into the 21st Century?  Our provincial government is talking about putting a price on carbon – one which will raise fuel prices for all users, including trucks.  While the price the province has been kicking around isn’t likely to act as much of a deterrent to truck traffic (likely to be around $30 to $40 per tonne, in keeping with carbon costs in B.C. and proposed for Alberta), if the price of carbon pollution eventually rises as high as the price used in the AECOM report (a staggering $88.50 per tonne – a price which, by the way, is considered middling when it comes to incorporating the actual social costs of carbon, which may be as high as $200 per tonne – see: “New economic model may radically boost the social costs of carbon,” arstechnica, January 12, 2015), will trucking heavy expensive materials such as those currently shipped on our municipal roads remain a profitable exercise?

Junction Creek Watershed: Still "Degraded"?

With regards to the physical environment, both the 1995 and 2008 Environmental Assessments refer to the Junction Creek watershed through which the Maley Project is to extend as being “degraded”.  The 2008 Addendum reports on field surveys conducted in 2006 in which no threatened or endangered species were identified, and in which the findings were largely in keeping with those made back in 1995 (except in 2006, 3 new tributaries of the Junction Creek were discovered – with no explanation about how they might have been missed back in 1995 – which kind of makes one wonder what other features the 1995 Assessment might have missed).

10 years later, can we still make the same assumptions about this part of the Junction Creek watershed?  There have been a number of initiatives undertaken by the Junction Creek Stewardship Committee in recent years to improve and enhance the quality of the creek and its tributaries (see: "Something fishy with the Junction Creek festival," the Northern Life, May 23, 2015).  One of these initiatives in 2014 looked at the health and abundance of turtles in the aquatic ecosystem (see: “After 15 years, Junction Creek showing signs of life,” the Northern Life, May 24, 2014).  It turns out that Blanding’s Turtles have been identified at locations in the watershed.  Blanding’s Turtles are a threatened species in Ontario, which means that the protection of their habitat needs to be given greater consideration.  It’s not known whether Blanding’s Turtles may be living in the tributaries of Junction Creek across which Maley Drive is intended to traverse.  The 2006 field surveys did not identify the presence of Blanding’s Turtles.

The point, however, is that we know that there is now a threatened species living in the watershed.  As a result, we can’t simply rely on field surveys conducted over a decade ago.  And yet, no new updates to the 2008 Addendum are being considered at this time, even with the knowledge that a threatened species has been located in the watershed.  To allow Maley Drive to proceed in absence of a more fulsome assessment of the known presence of and potential habitat for a threatened species is extremely problematic and potentially illegal.  

Up-to-Date Assessment Critical

The need for up-to-date Environmental Assessments is illustrated by this one example – but there may be others that we don’t know about, and won’t know about until appropriate studies are undertaken.  The lifespan of Environmental Assessments is typically just 5 years (certainly, the 2008 Addendum indicates that the 1995 Environmental Assessment needed to be updated after 5 years – I admit that I do not know whether the same is true with the 2008 Addendum, but the Sudbury Star reports that the City of Greater Sudbury may be under the impression that the 2008 Addendum “lapses” later in 2016 – see: “Maley project feasible: Report,” the Sudbury Star, November 5, 2015). Grazing the edge of an Environmental Assessment’s best before date to justify a project moving forward where there is evidence of a changed circumstance to both the physical environment (Blanding’s turtles) and the socio-economic environment (a smaller, truncated road being considered; truck traffic having migrated to the Valley) defies logic, and certainly is one of the primary reasons why the Maley Drive Extension project Phase lacks a social license.

Council Endorsement

But it’s not the only reason.  Who gets to make decisions in our community which impact on residents, the business community, and the fiscal health of our municipal government?  Typically, we like to think that these decisions are made primarily by our municipal Council, but every now and then, senior levels of government might opt to by-pass Council and make a decision with their own interests in mind.  Every now and then, voters are tasked with making a specific decision for themselves through a referendum.  But usually, it’s our Council that makes decisions on behalf of the disparate elements and interests which make up our communities.

In the case of the Maley Drive Extension, Phase 1 project, however, Council has never actually made a decision to pursue this project.  While it is true that Council has, in the past, on several occasions, made clear its support for a more fulsome Maley Drive project (see Decisions based on Staff Reports dated April 3, 2009; January 6, 2011; and August 8, 2012 – the last of which contemplated a phased project, but one which would be completely funded and built-out in 4 years. Read my further analysis of this issue, “The Incredibly Shrinking Road: Staff Pulls a Fast One on Council with a Shorter Maley Drive,” Sudbury Steve May, November 5, 2015), this discrete, stand-alone Phase 1 project has never had the benefit of a Council resolution in support – in fact, staff have never even gone to Council looking for that support.

Can it possibly be that our City has been making the case for funding to senior levels of government for a project which has never been endorsed by Council on behalf of the City’s citizens?  It certainly looks like that’s the case.  However, given the labyrinthine twists and turns taken by the Maley project over the past 2 plus decades, perhaps it’s not completely unexpected. 

Careful Consideration

But going forward at this time – without Council endorsement – would be unacceptable.  Council must either make a decision on the Phase 1 road – or take it to the public and hold a referendum.  
This is important, after all.  We’re talking about the biggest and most expensive public infrastructure project in the history of our City.  It’s simply unconscionable that Council wouldn’t make a decision on the project, in absence of any previous Council ever having reviewed this project – or deciding that it was appropriate for the community.

Our Council must take into consideration all of the available information on this specific project before making a careful decision.  That should include a new Environmental Assessment, which looks just at how Phase 1 is intended to interact with the physical and socio-economic environment, and takes into consideration the potential impacts on the habitat of Blanding’s turtles, a threatened species.  

Careful consideration means reviewing an actual Business Case which assesses the need of the project – and not simply the wimpy business case required by Infrastructure Canada for funding under the Building Canada program.  A real analysis of a complete range of costs and benefits should inform the business case analysis of need.   That includes a look at how spending money on Maley might impact how money is spent on other, potentially more worthwhile projects which will have a greater impact on the social, environmental and economic health of our communities.

Public Consultation

And finally, Council’s decision should be informed by a real public consultation process.  Up until now, there has been no real opportunity for the public to provide input on any aspect of Maley Drive – and no opportunity whatsoever to provide input to Council on the scaled-back Phase 1 version which has headed for funding.  Opportunities for limited public engagement would have been available prior to the completion of the 1995 Environmental Assessment.  The 2008 Addendum process, however, focused only on involving those members of the public who participated in the assessment process pre-1995 – presuming they were still around the City more than a decade later.
But as far as public participation goes, that it’s.  And that’s clearly not enough.  Especially since the scope and scale of the project has changed over time, along with the assumptions upon which the project was based.

Even if the federal  government announces the availability of funding for Maley Phase 1, that alone should not deter our Council from going through a fulsome review process to determine whether Phase 1 is going to meet the long-term needs of our communities.  Anyone can throw money around, hoping to get results – but real fiscal sustainability should be informed by the best available facts and evidence, so that public funds can be used responsibly. 

No Social License

In absence of an updated Environmental Assessment, a business case which assesses need and based on a comprehensive analysis of costs and benefits, and a Council decision informed by public participation, it is clear that the Maley Drive Extension Project, Phase 1 road development has not attained the social license necessary for it to proceed at this time.  All levels of government considering funding this project must acknowledge this reality – and back off.

That we find ourselves in this situation after more than two decades of work and expense is problematic, to say the least.   However, new infrastructure projects are often subject to being pulled in multiple directions and evolve over time, based on changing circumstances.  In that respect, Maley Drive is no different – and we ought not kick ourselves too hard for ending up where we have.  But we must acknowledge that the project we are about to undertake has long-term economic and city-building consequences which have not yet been adequately explored by Council, Staff or residents.   As a result, there is no social license to proceed with the project.

(Opinions expressed in this blog are my own, and should not be considered consistent with the policies and positions of the Green Parties of Ontario and/or Canada)

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