Appeal to the Minister of the Environment and Climate Change

Regarding the

Environmental Study Report Road 174 / Prescott-Russell County Road 17 Municipal Class Environmental Assessment Schedule C Study

Prepared by the Cumberland Community Association 174 Working Group Committee

June 2016

Table of Contents I. Introduction ...... 3 II. Purpose ...... 3 III. Approach ...... 3 A. Technical Shortcomings of the Study ...... 4 1. Weighting of Criteria ...... 4 2. Capacity of Road for 2031 and Beyond ...... 5 3. Design of Widened 174/17 – Constraints on Capacity ...... 5 4. Quality of Public Consultations ...... 5 B. Lack of Future Vision of a Transportation System ...... 6 1. Restricted Study Area ...... 6 2. Future LRT Expansion ...... 7 3. Environmental Impact ...... 7 IV. Recommendations ...... 7 1. Re-evaluate the Criteria Weighting ...... 8 2. Expand the scope of the EA to Deliver a Comprehensive Transportation Solution for the eastern Ottawa River corridor ...... 8 3. Alternative Solution to Road Widening ...... 8 V. Conclusion ...... 9 VI. Appendices ...... 11 A. EA Study Results Summary ...... 11 B. Freedom of Information Request ...... 13 C. Scientific Leaders Letter to Congress – June 28, 2016 ...... 15

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I. Introduction It is without dispute that as a result of decades of growth and in anticipation of further unabated development in communities along the Ottawa River east of the City of Ottawa the current transportation infrastructure for commuters is inadequate. The /Prescott-Russell County Road 17 Municipal Class Environmental Assessment (Appendix A), fully funded by the Ontario Government, investigated three alternatives for a roadway solution to allow an increase in vehicular traffic between Clarence- Rockland and the City of Ottawa as well as address issues of safety.

The study results identified ‘Option 1” (widening of existing OR 174/County Road 17) as the preferred albeit most expensive solution. The Cumberland Community Association (CCA) represents the residents of historical Cumberland Village (est. 1799) and rural residents of the most easterly part of Ward 19, City of Ottawa, formerly Cumberland Township. The CCA is appealing the outcome of this study based on what we believe are significant technical shortcomings in the research methodology, which we feel biased the result. In addition, we have significant concern about the complete lack of integration of this proposal into a bigger strategic long-term commuter transportation plan along the Ottawa River corridor, from Ottawa to the Quebec border.

We believe our concerns are legitimate and warrant further investigation before tax-payer money is used to implement this flawed and inadequate proposal. We are committed to finding the best solution that ensures growing communities outside of the City of Ottawa will have access to Ottawa jobs, recreation and resources. However, in 2016 we must be committed to making transportation decisions that are initially and primarily focused on public transportation and based on principles of longer term planning, environmental preservation, pollution reduction, economics and community building. This solution is a result of applying old strategies to changed conditions. We are looking to this progressive Ontario Government to address our concerns.

II. Purpose The purpose of this appeal is to request attention and action from the Minister of the Environment and Climate Change to the objections by the Cumberland Community Association (CCA) to the project to widen Ottawa Road (OR) 174 from one to two lanes in each direction with a concrete center barrier between and Canaan Road As a result of this appeal we request that the Minister order a change in the project status and require a higher level of assessment under an individual Environment Assessment process (referred to as a Part II Order).

III. Approach The objections to the project that have not been resolved with the co-proponents (City of Ottawa and United Counties of Prescott and Russell) of the study during the public consultation process are of two types: 1. Technical Shortcomings with the Study itself; and 2. Lack of a Sustainable Future Vision of a Transportation System serving eastern Ottawa (Cumberland) and neighboring communities to the east.

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A. Technical Shortcomings of the Study Having attended the public consultations and reviewed the completed report, the CCA has identified four major shortcomings of the report as presented below.

1. Weighting of Criteria Weighting of evaluation criteria are obviously critical to conclusions made in any study and can easily be manipulated to achieve a desired outcome. The methodology for arriving at the weightings in this study is highly questionable.

Queries as to how the criteria within each evaluation category were arrived at (both in public consultation meetings and in subsequent written correspondence) were evaded, glossed over or answered in a non-transparent manner by the project team.

Based on the spreadsheet provided by the proponents, “average proponent weights”; current weightings by broad evaluation category follows: • Social: 29.11%; • Transportation: 35.94%; • Infrastructure: 6.5%; • Economic: 13.72%; • Biological: 4.97%; • Physical: 9.75%.

The individual criteria within each category were weighted separately with no explicit details provided for these weightings. The proponents themselves in consultation with “experts” apparently ‘arrived’ at them with no ability to substantiate their decisions during public consultations. Since Option 1 (widening of OR174/CR17 corridor) ranks first in both the Social and Transportation evaluation categories, and ranks either last or second last in the other four categories, clearly, overweighting of the Transportation and Social criteria in effect pre-determines the outcome of the study.

The Biological category was weighted at only 5% for the narrow Option 1 corridor; Trim Road to Canaan Road, while it was given 10% in the portion of the Study area west of Trim Road. OR 174 west of Trim Road varies from about one kilometer to 5 kilometers from the river in an area that is demonstrably less ecologically sensitive and is already the site of a limited access highway on largely developed land whereas from Trim Road through Cumberland Village proximity to the Ottawa River and a number of other ecologically sensitive areas is just one hundred to a few hundred meters. No explanation was provided which is very troubling and indefensible. This requires further explanation.

Changing the weightings of the various evaluation criteria even slightly has a very significant impact on the Study results. For example, if one increases the Biological and Economics weightings by 5% and decreases the Transportation and Social weightings by 5%, then option 3 () ranks first. It would appear that Economics has been 4 2016-06-28 Cumberland Community Association, Cumberland, Ontario

underweighted since the Study has chosen the most expensive option, even before considering the cost of remediation and the true expenses of highly probable expropriation and property devaluation claims. As well, Biological is clearly underweighted, given the nature of the riverside environment, and the fact that it was given a 10% weighting west of Trim Road.

The Cumberland Community Association is so concerned about these evaluation shortcomings that it has made a request for information under the Municipal Freedom of Information and Protection of Privacy Act for all correspondence related to this study specifically concerning the determination of evaluation criteria weightings used to compare the three alternative road solutions. We have not yet received a response from the City of Ottawa and are therefore unable to make a definitive assessment of how the Weighting Criteria were established or if there was interference in this process. We respectfully ask the Minister to inquire into this matter. A copy of the Freedom of Information request is attached as Appendix B.

2. Capacity of Road for 2031 and Beyond The timing of the widening of the road, we were told in the public meetings, was to be in the 2031 timeframe due to lack of City of Ottawa fund availability. However, the Study did not explicitly address whether the widened road would, in fact, be adequate to support the anticipated traffic requirements at that time due to projected growth east of the City of Ottawa. More importantly, perhaps, is the question of planning for subsequent growth; none of the chosen evaluation criteria rated the various alternatives by ability to accommodate subsequent expansion (scalability). Given the physical constraints of the existing 174/17 corridor there would be little ability to further widen this road beyond what is being proposed. Strategic long term planning principles would suggest that any east-west corridor chosen should be one most suitable for scaling to accommodate future growth.

3. Design of Widened 174/17 – Constraints on Capacity In an effort to overcome problems that the widened 174/17 corridor would create (i.e. impact on the historical Village of Cumberland, access by residents and business, safety impact of increased traffic volumes, increased speeding and reckless driving), the Study proposed trade-offs in terms of a barrier divided road, lower speed limits and up to 20 new signal-controlled intersections. The Study did not explicitly address how such factors would impact traffic throughput, capital costs, noise, congestion, pollution or other factors, although clearly such factors would have a significant impact.

4. Quality of Public Consultations Well-attended public meetings held to “consult” with stakeholders were inadequate by any standard of openness, transparency or fundamental fairness. Little or no written material was available prior to the meetings; generally (the complex and voluminous) draft or preliminary Study material was only provided one hour prior to the meetings at the premises where the meeting was held. This afforded very limited opportunity for review, study or analysis of the material. The meetings were poorly organized and no PA 5 2016-06-28 Cumberland Community Association, Cumberland, Ontario

system was provided at the first Cumberland meeting, so that neither questions from the floor nor answers from the proponents could be clearly heard by the participants. It was apparent to the participants that the “public consultations” were held for the sole purpose of checking the box in the applicable legislation, rather than hearing, in any meaningful way, the views and concerns of the public and residents most directly and significantly affected by the Study outcome.

B. Lack of Future Vision of a Transportation System Apart from the technical shortcomings of EA Study presented above, the study lacks an overarching vision of a commuter transportation system that will meet the future needs of the communities of Cumberland, Clarence – Rockland and those further east to the Quebec border. The lack of a long-term comprehensive transportation vision for these rapidly growing communities makes this proposed solution tenuous at best and highlights the inevitable capacity flaws in the proposal. There are three major areas of concern:

1. Restricted Study Area The work of study team was constrained by a very limited study area for the section of OR174 from Trim Road east to Canaan Road within the City of Ottawa and Canaan Road

to Landry Road in Clarence-Rockland. As a result the study did not in any way address the future transportation needs of existing towns or new communities developing to the east and south of the study area. By 2031 the communities east of the City of Ottawa and Clarence-Rockland will have added significant new development with thousands of additional commuters travelling to Ottawa. A strategic transportation oversight plan is 6 2016-06-28 Cumberland Community Association, Cumberland, Ontario

necessary by the to minimize environmental impact and ensure travel efficiency and cost effectiveness of transportation investments.

2. Future LRT Expansion The City of Ottawa and its funding partners are presently building a LRT system that will extend to Trim Road in phase 2 of the project. Extension of a commuter train beyond the city limits is the most effective means for transporting commuters to the LRT. Investment in a train that could extend further east as development warrants is scalable without requiring costly road construction and maintenance or adding more cars to the road.

3. Environmental Impact Currently, an estimated 25,000 cars travel on OR 174/County Road 17 every day the majority of which is commuter traffic, single occupancy. Widening this road to 4 lanes will significantly increase the number of vehicles as growth and development increases, studies confirm that bigger roads always attract more cars and rarely aleviate congestion.

This proposal is unprecedented in suggesting a major four-lane highway immediately along an historical waterway that is the source of drinking water for millions of people. (Examples of where 4 lane highways were moved away from key waterway; Highway 2, Gananoque Parkway and the 401, Rideau River Road and 416, in Quebec, Highway 148 along the Ottawa River and Highway 50).

In the section between Trim Road and Cumberland Village the OR 174 travels along a narrow corridor between the Ottawa River on the north and the high ancient Champlain Sea escarpment too the south and for several kilometers it is barely 200 meters from the water. A significant amount of underground water flows constantly into the river along this corridor draining from the escarpment. The proposed widened road has ditches to mitigate run off which would result in road pollution and salt seeping into the underground water, ultimately ending up in the Ottawa River and further contaminating residential wells on the north side of the road. As well the risk of a major chemical spills from transport trucks in such proximity to the Ottawa River is unacceptable.

This study was remiss in not considering the impact of the concrete center divider wall on the significant wildlife (mammals, birds, reptiles; high turtle crossing area between Trim Road and Cumberland Village) that freely move back and forth between fields, wooded areas and wetlands at the base of the escarpment and the Ottawa River. Was the destruction of this diverse habitat and blocking the natural movement of wildlife identified in the study as a significant Biological evaluation criterion?

IV. Recommendations All levels of government are committed to enhancing public transportation and thereby reducing the effects of climate change to meet our municipal, provincial and national objectives and international obligations. In line with achieving those goals we submit the

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following recommendations for your consideration and action before the environmental and social devastation of another road widening begins.

1. Re-evaluate the Criteria Weighting Based on our analysis of the evaluation criteria weightings and the inability to obtain substantiated details explaining those weighting, as explained above, we believe the Study recommendation is flawed, biased to the Option 1 outcome. It is known that Option 1 will not solve the stated problem. We request that the evaluation criteria weighting to be reexamined.

2. Expand the scope of the EA to Deliver a Comprehensive Transportation Solution for the eastern Ottawa River corridor This EA was solely focused on assessing alternate road solutions for addressing the problem of increased commuter traffic on 174/17 from Trim Road to Clarence-Rockland. This limited perspective does not address the issue of growth in all communities east to the Quebec border. As no municipality has jurisdiction over a comprehensive transportation vision it would fall to the Provincial government to provide leadership in creating such a solution for the benefit of all residents within these communities. Understanding the ‘big picture’ development and growth projections in the Ottawa River corridor and planning road and rail infrastructure to support it will reduce costs and better serve the transportation requirements of these communities.

3. Alternative Solution to Road Widening An estimated 25,000 cars travel OR174/CR17 daily, the vast majority in single occupant vehicles. If eighty percent are commuters and they work approximately 250 days per year, that is 5 million trips! In light of the recent enthusiastic commitment to infrastructure investment in public transportation by all three levels of government, we believe that funds would be far better invested in building a sustainable and scalable Ottawa River Corridor Commuter Train (ORCCT) to connect with LRT station at Trim Road. The world over, people travel by train and connect with urban LRT/subways to continue their journeys within the city (e.g. Toronto Go Trains). This has the obvious advantage of reducing the need for bigger roads, congestion and the need for urban parking space. Environmentally millions of fewer car trips will reduce car-generated pollution (greenhouse gases, noise, dust, road pollution and car related accidents).

We need strong government leadership and commitment to develop alternatives to car transportation, especially within commuting distance from our urban centers. Pushing behavior change to public transportation now will help achieve our climate change objectives and spare our urban/suburban/rural communities from the pollution of millions of unnecessary car trips.

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V. Conclusion

It is true that there has been talk of widening the road along the Ottawa River for decades and that in recent years the numbers of commuter vehicles has increases dramatically due to the ongoing development and growth east of the City of Ottawa boundary. We recognize the need to address this issue.

The EA Study was undertaken to assess road solutions to address the commuter problem resulting from this growth and three alternatives were identified for evaluation. We believe the Study results are flawed in the recommendation of Option 1, widening OR174/CR17 due to questionable evaluation criteria weightings; particularly the underestimation of the Biological and Economic components and absence of evaluation criteria for expansion beyond 2031. To implement Option 1, multiple constraints on capacity are proposed making it dubious that the expanded road would in fact improve commuter times or car through put. There is a strong likelihood that commuter frustration and irritability will increase resulting in more accidents and more high risk driving behaviour.

We believe that our municipal, provincial and federal governments are committed to an infrastructure investment in public transportation. While the desire to widen roads is a simple solution there are many reasons why this is no longer the best solution. Bedrooms communities are blossoming east of the City of Ottawa boundary as they did in the Toronto area twenty to thirty years ago. Eighty percent of the cars on the road are commuters. “Making highways wider isn’t a solution—traffic volume merely expands to fill the available space…Building more roads simply creates more incentive for people to drive.”1 Public transportation that is accessible by bicycle within the community is a superior solution for growing communities significantly reducing cars on the road.

The time for strong leadership and decisive action is now. On June 28th scientific leaders representing a vast number of scientific organizations sent an open letter (Appendix C) to the US Congress imploring them to take action on climate change, stating “To reduce the most severe impacts of climate change, green house gas emissions must be substantially reduced.” In 2016 we should not be engaging in commuter solutions with bigger roads and more cars but with energy efficient commuter trains. It is imperative that this expensive taxpayer funded project provides the best solution for sustainable transportation for present and future generations.

We call on the Minister to order a change in the project status and require a higher level of assessment under an individual Environment Assessment process (referred to as a Part II). Let this small project in eastern Ontario become a model for other communities in the province and the country. Let’s build something that we can be proud of and lead by the example of embracing public transportation outside of urban centres so the evolution of behaviour change can happen now.

1 Stuck – By Don Gillmour, The Walrus, July/August 2016 9 2016-06-28 Cumberland Community Association, Cumberland, Ontario

We thank you for your commitment to a better environmental future for Ontario and appreciate you consideration of our appeal.

Submitted for consideration by Cumberland Community Association

______Chair 174 Working Group Committee 613-858-1770

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VI. Appendices

A. EA Study Results Summary

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B. Freedom of Information Request

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C. Leaders of Scientific Organisations - June 28, 2016

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