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.

9 thoughts on “Environmental Assessments — Why Bother?

  1. I agree completely with expedience in the environmental assessment process to help transit projects get through more quickly. The key word is ENVIRONMENTAL assessment. This is not the venue to be discussing greater design considerations for transit projects, this is a venue to be discussing environmental impact concerns. eg. does the project pass through a watershed area, will the noise impact wildlife, etc. etc. While I agree that the municipal planning process is not ideal at the moment, we should not be designing the EA process to compensate for the shortfalls in this process. Ideally all processes would work as they should, but if they don’t, it can’t be right to design one to make up for anothers shortfalls – you’d need to fix them both so they work as intended.

    Steve: In principle, I agree with you. However, the actual, real world reception of Transit City by the “professionals” not to mention a lot of folks on this blog was to scream “how can you say it’s an LRT network without an alternative assessment”? Aside from the millions in consulting fees that had just gone up in smoke, this showed that the clear model has been to figure out your options as part of the EA, and not just worry about the purely environmental issues.

    The single biggest gaffe on the St. Clair project was the claim that detailed design issues could not be considered until there was an approved EA, by which time the decision on what mode, whether it would be completely a segregated right of way, and many other points, were already beyond discussion. That simply would not be possible if the only thing the EA looked at was the state of vegetation and wildlife on St. Clair.

    You can’t change the scope of the EA process so massively if you don’t also fix the planning process that first leads up to a proposal like Transit City, and then elaborates it into plans for each corridor. Technology and alignment choices affect the “environmental” part of the study, and you can’t split them up just to make the process run faster.


  2. I’m with you Steve, and not with Franz Hartmann of TEA, and maybe some other “green” groups. From what I’ve seen of urban transit proposals, the EA processes are seriously flawed, and the results are at worst sad wastes of time, money and resources.

    The Spadina LRT EA couldn’t find room for bikes – but Ms. Grier messed up on that one.

    The St. Clair EA also didn’t manage to find room for bikes. The end results on both lines were at least fairly transit-positive though.

    The Front St. EA and its effort at renewal is the big disaster – despite an appeal made – shucks – nearly five years ago? – for an Individual EA that would actually contrast options to the $255M Dumb Growth that would mess up two transit systems – there’s been no decision, and the province says it’s all referred back to the City. Even one very simple good option – the expansion of GO running so close to the FSE it’ll have its tracks moved for c. $60M – was Outside of the Preferred Options. And there are about a dozen other possibilities, one of which is the WWLRT.

    And that EA from 1993, actually says that what is proposed more or less – isn’t a good enough deal to do. Not good enough in transit terms to bring people in from Etobicoke, and not good enough in dollars either. Doing a piecemeal EA or an expedited EA means they don’t have to justify their “plans”, and we run the very serious risk of having Waterfront Transport Follies (WTF) repeated in many other areas with a few hundred million$ of wa$te, plus wasted opportunities for effective transit.

    However, as with the FSE, when we were told that it was going to happen, it ain’t necessarily so. Today’s Star has a better story including some good comment from Mike Sullivan of the Weston Community Coalition saying “let’s build transit that can be used by the people” – though I think it likely needs to be an LRT vs. subway. Please all – consider writing in letters to the Star – they might be more responsive though they’ve not responded in the way I’d like about some op-ed efforts.

    The other major route is likely through the Environmental Commissioner of Ontario and the Environmental Bill of Rights as this proposal should be put on the EBR for comment.

    The other route might be through environmental groups. I do worry about TEA being a little too tight with the NDP for criticism. New term inspired by the TTC Commissioners actually – “blindp”

    A CBC interview with David Donnelly of Environmental Defence had enough caveats that he might be amenable to community inputs about flaws. Eco-justice might be approachable, and the Sierra Club of Ontario might also have the ability to express reservations.

    It’s really commendable that there’s a desire to expedite transit, but in the hurry to make sure there are real projects doing real things for real votes we could be making Really Big Mistakes – and that’s not good enough.

    To use the WWLRT + FSE again – it’s almost a billion of spending – without really thinking of GO. And if we could save a few hundred million and still get as much transit impact wouldn’t that help the rest of the shytstem? Gord says he lacks $12M to make the connection between the GO Station on the Bloor line and Dundas St. W., and maybe we need another $80M to buy enough streetcars for the Queen/King lines to keep service up…

    Painting a bike lane beside 8kms of subway would only take $200,000 and yet that’s nearly impossible 40 years after the subway opened. Bikes use even less energy than transit – and how bikes have fallen off the agenda is an indication that the EA processes aren’t working, and should be applied in an urban environment in fuller detail, and with intervenor funding.


  3. I’m not sure if a cable cars catapults could help the transit congestion on Dufferin, but I do know that the current EAs don’t work very well. What’s needed is less EA and more PC – Public Consultation. There is no reason we cannot get public input right now – except the unwillingness of the TTC to do so, EA or not.


  4. Everything you say about this is right. The most striking thing I found about the Star piece was simply that every quote in it was accurate to one degree or another. While the process has serious problems, it isn’t being used to best effect, or in good faith. We need a process that is reasonably paced, but which actually allows public involvement, and we need that public involvement to be much more real than was seen on St. Clair, or is being seen on WWLRT.

    As for the planning process, I haven’t seen any consultation on Transit City, and these new EA’s are going to mean there essentially isn’t any relating to some fairly basic parts. Yes, it’s a the right program, but that doesn’t give the city any right to ram it through without consultation.


  5. Catapults! I think I mentioned this before here or elsewhere, possibly as a solution to GO’s track space issues – just have catapults send commuters to Union Station in the morning with the use of nets at the other end. The return commute might be a bit more difficult getting people where they want to go. (And given GO’s Union Station fixation, it’s an appropriate technology – after all, it’s not like anyone wants to go anywhere else.) And I’ll pity the GO Constables with the now much less enviable job of checking tickets.

    Now if we catapulted swan boats, would they get enough speed to fly?

    Steve: Clearly you have not read “Swans on the Don”. The latest generation of this technology flies on its own, sans catapults!


  6. When will we actually have an open house to discuss on which corridors lines will actually be built in general? This would debate, for example, whether the Sheppard LRT should really be built on Finch instead or whether the Don Mills LRT should really be built on Victoria Park. We did not see this with Transit City or pretty much any other of our major transit projects. In Transit City, the city planners seem to have taken the highest performing bus routes, drawn them on a map and said “let’s build streetcars here”. If this has been done, the public would have quickly realized that a subway on Eglinton makes much more sense than a subway on Sheppard and killed the latter project.

    This needs to be incorporated into the EA (or similar) process. We should not be gutting the EA process so that there is almost no public consultation.


  7. For every project that can be improved a little by the EA process, I see years and years of delay on other projects. Look at the EA on the Georgetown line. The federal government promised funding to reduce travel times and provide an airport service on the Georgetown line two Prime Ministers ago (Chretien) – I can’t rememeber what year it was – but Chretien left office in 2003. The EA is still in progress, and isn’t likely to be approved until at least 2010. There’s a good 5-7 extra years that the Georgetown GO passengers have had to suffer a slow service, simply because a few local residents have tied the system in knots, because they think that their needs are more important than the GTA as a whole. By the time the EA is completed, we’ll surely be onto the 4th Prime Minister – certainly the 4th Parliament since the funding was announced – lord knows if the administration at that time will have the follow-through to fund what will be required.

    Steve: The original proposal for the Weston corridor was a pet project of a former cabinet minister who pushed it through just before leaving office. It had nothing to do with good transit planning and everything to do with favouritism for the company that would operate the service. Once they started to look at the details, the proposal dwindled from a shiny new train, the sort of thing people think of for airport shuttles, to a bunch of reconditioned RDC’s trundling back and forth from Union to Pearson.

    The level of service proposed is nowhere near what would be required to force a grade-separation through Weston. More time is lost by the VIA trains on this run in farting around at Union Station and waiting to merge in with the freight traffic in Malton than in the relatively slower move through Weston itself.

    Next came GO with its own proposal for improved service in the corridor. Their heavy-handed approach to the EA process — give out as little information as possible and treat the locals as an interfering nuisance — did nothing to endear GO to the folks in Weston.

    Blue 22 is going nowhere not because of the EA process (and by the way, the Feds have not made any changes in their EAs), but because it doesn’t make sense economically for its proponents.

    The Weston corridor needs a “local” service that stops in several places to serve travel not just to the airport but between northern Etobicoke and downtown. I suspect that, but for Blue 22, this route might have shown up in the Transit City plans.


  8. Steve: “I suspect that, but for Blue 22, this route might have shown up in the Transit City plans.”

    If the EA process had been streamlined, by this point in time, Blue 22 would have died it’s natural death, as not ecomically viable. GO Service would have been improved, and we would be looking at how to improve local service along this corridor. I think you are correct – the NIMBYs highjacking of the EA process to promote their own interests has only delayed, if not forever stopped, any transit improvements in that area.

    In terms of the EA process itself – I’d have thought you’d have been thrilled at how the process has been capped. There’s no way Transit City will be built with even the class EA process. Look at the fuss the St. Clair residents kicked up. I’d think this would be nothing, compared to, for example, the Don Mills residents, when one tries to stick a dedicated track down the middle of Don Mills from Eglinton to Lawrence – and another 25 or so battles.

    And remember, the EA process is about Environmental issues. When I’ve dealt with these on a professional level, the prime issues are wetland destruction, loss of forests, woodlands, open areas, impacts to endangered species, groundwater consumption, contamination issues and pollution issues, and noise issues. Given that most of these issues just aren’t on the table at all for an above-ground mass-transit project – and for pollution issues, clearly transit is a benefit, it really should only come down to noise. And that’s normally one of the easier issues to deal with (and personally, I find diesel engines going past my house make more noise than electric – so I’m not even sure that this would be an issue).

    I’m not saying that there shouldn’t be some consideration for neighbourhood issues such as sidewalk width, turning lanes, etc. But these aren’t EA issues, and should be dealt with in 2 or 3 public meetings over a short period of time.

    I’m sure by restricting the process, we’ll lose a couple of things that should have been there. But we might have built many kilometres of track by 2015, rather than still be debating the location of the portal along Finch Street West. And frankly, with the full EA process, it’s not like bad decisions are being avoided now. The full EA process still gave us poles down the middle of St. Clair – which restrict the use of the ROW by emergency vehicles. And it also gave us tracks down the middle of Fleet Street – when clearly just standing there, you can see that tracks along the side of the road ala Cherry Street would have made a lot more sense.

    Steve: I have moved my reply to this comment to a separate post.


  9. The province has only recently introduced the streamlined Class EA so why the need now to impose a six month time limit? Have they even given the new process a chance?

    Maybe what we do need is some form of multi-stage approach. That is, first we might get approval for the project/idea in general.

    Then we would move on to the specifics of a particular proposal. The key is to get the public involved as was done with Cherry Street. Of course, we were dealing with only a short length of track rather than a long line as would be the case with any of the Transit City lines. At different points along the line there would be different concerns.

    That also assumes some degree of competence from the professionals we the public are dealing with. Sadly, from reading this blog, this doesn’t appear to be the case. Toronto Hydro, the TTC and the works department couldn’t co-ordinate timing on St. Clair and Fleet.

    Elsewhere, you mentioned the rationale for having centre poles on St. Clair-that the streetlights would be placed farther apart than existing. Thus the TTC would need to have its own poles. Yet somewhere along the way, the distance reverted to the existing thus removing the justification for centre poles. Yet centre poles remain.

    Then there is the case of the disjointed planning process for the Waterfront West Project. Segments are being studied in isolation but the line segments have to connect with each other! What would be best within each study area might not make for the best overall project.


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