Environmental Assessments — Why Bother?

In yesterday’s Star, we learned that Queen’s Park has gutted the Environmental Assessment process by imposing a six-month cap on the period an EA can be under development. The claim is that transit’s opponents, those who would delay projects to no good end, have tied EAs in knots preventing much needed, environmentally friendly transit development.

I beg to differ.

What has caused the most grief to every recent transit proposal has been questions of detailed design and implementation. Time and again, we have seen schemes that trample over neighbourhoods for the simple reason that the “professionals” don’t understand what they are doing. There are two ways to handle this type of problem: work with local communities to improve the plan, or fight them to the wall. As recent examples:

  • The West Donlands LRT EA produced a completely new scheme for running the Cherry Street right-of-way along the side of the road rather than in the middle. This only happened because the EA took the time to work with the community.
  • The East Bayfront EA is mired in questions about a second portal to the Bay Street tunnel. With the accelerated EA, what will quite likely happen is that a new portal on Queen’s Quay itself will be rammed through over local objections despite much work in good faith to find an alternative.
  • The Waterfront West EA is a procedural nightmare with many overlapping studies producing, at best, second rate results. The presence of an already-approved EA nearly two decades old for part of the line further limits discussion because an analysis done years ago under different circumstances cannot be challenged.
  • The St. Clair right-of-way project ran into serious problems because of neighbourhood impacts and a design that left much to be desired. A major delay arose from a legal battle, not from the EA process itself. The credibility of the project has been further undermined by the chaos with which it has been managed, using that term rather loosely.

Dalton McGuinty may think that he’s doing transit a big favour, but what has really happened is that the EA process is reduced to little more than a quick review. If the proponents of various schemes expect co-operation from the public, their professionals (staff and consultants) must learn how to be more inclusive, how to integrate community concerns in the process.

Only last year, a new streamlined “Class EA” was defined for most transit projects that eliminated the hugely wasteful “terms of reference” stage in which an army of consultants, engineers, facilitators and other hangers-on went through the charade of deciding that, yes, this project we want to build is the project we want to build. The next year was spent in actually looking at the options in detail. This farce, thankfully, is over, and EAs were expected to drop to about a year.

Now, McGuinty wants it down to six months. The single biggest problem with the old process was a “Catch 22”. You couldn’t talk about detailed design (the thing most people actually care about) until you had an approved EA, but by the time that happened, mysteriously the design had progressed to the point where significant changes were difficult or impossible, and all a neighbourhood could do was choose the colour of paint on the transit shelters.

Time and again, the professionals have shown that they don’t look at all the options, in some cases because external influences cause filtering of what is considered. No better example exists than the WWLRT. The ghostly presence of the Front Street Extension prevented potentially superior options from getting on the table until the community and local politicians demanded it. Under the new rules, such options would likely never be seen because it would take too long to analyze them.

The Environmental Assessment process does not exist simply to protect the odd spotted newt that may live in the path of a new transit line. “Assessment” includes looking at the impact on communities, and “Alternative Assessment” means considering ideas other than the one the planners cooked up over lunch.

The dedicated lane for Toronto’s St. Clair streetcar, for example, was held up for months at the assessment stage with fights over curb heights, which had nothing to do with the environment. In the end it took two years to get through the assessment.

I don’t know where the Star got this blinkered view of the St. Clair debacle, but a lot more was going on than debates about curb heights. The big issues were sidewalk cuts, intersection design, lane widths, parking and host of other matters affecting how the project would affect the neighbourhood. That’s “environment” the last time I looked.

Under existing rules, if someone objects to a streetcar, the transit authority has to come back with a study showing the implications of a bus, train, or even a hot-air balloon servicing the corridor instead.

“If someone wanted to talk about a new idea using cable cars or catapults you would have to evaluate them,” TTC chair Adam Giambrone said.

Giambrone forgets that Transit City, a network of LRT lines, only exists because for years advocates like me objected to subway schemes saying “there’s a better way”. Indeed, even though the Sheppard Subway was already on the books east from Don Mills to Scarborough Town Centre, the TTC now plans an LRT line along Sheppard itself.

There’s a reason we take a second look at official proposals. Even I, a supporter of Transit City, worry that the momentum of LRT could be lost if, suddenly, we wake up to find a completely new proposal on the table and plans to ram it through without debate. Transit City may benefit from streamlined approvals, but the same process could be used to change it beyond recognition.

Are we headed back to the bad old days when governments simply built whatever they wanted and the public be damned? How many decades has it taken just to get some reasonable understanding of what transit can be, other than ruinously expensive subway projects?

The key to all this lies in the Star’s sidebar:

The scope is limited to environmental concerns. Right now, everything that was argued over during the municipal planning process, including how wide a dedicated bus lane should be or whether a streetcar project is even needed, is rehashed at the environmental assessment.

This presumes that we have a municipal planning process that actually works and involves communities rather than fighting them. I don’t remember much communuity consultation, much “municipal planning process” around a lot of the projects on the table, in part because everyone assumed that the Environmental Assessments would be the venue to sort all of that out.

The entire process needs an overhaul right from the overall policy framework, the early stages when proposals are little more than doodles on a napkin, through the formal EA, and into detailed design. If all we actually get is planning-by-election-announcement, followed by perfunctory EAs and superficial design consultation, transit projects risk needless alienation of the very people they are meant to serve.