Below is an letter from environmentalist and Richmond Hill resident Natalie Helferty requesting a bump-up for the Bayview widening Environmental Assessment.
We need to consider ALL the costs of adding more traffic lanes and provide better alternatives to car and truck travel. We can and must plan our transportation system more sustainably. A healthier and happier future depends on it.
-Shawn
P.O. Box 32217
Harding Postal Outlet
Richmond Hill, ON L4C 9S3
nhelferty@rogers.com
myluvden@yahoo.ca
Honourable Laurel C. Broten
Minister of Environment
135 St. Clair Avenue West, 12th Floor
Toronto, Ontario M4V 1P5
minister@ene.gov.on.ca
November 7, 2006
Re: Class Environmental Assessment (EA) for Bayview Avenue between Elgin Mills & Stouffville Roads in Richmond Hill on the Oak Ridges Moraine
The Bayview Avenue Class EA done by York Region recommends widening of Bayview Avenue to 4 lanes plus turning lanes, so 5 lanes, on the Oak Ridges Moraine in Richmond Hill.
The Region’s Class EA is lacking a number of very important analyses and alternatives that can only be addressed through an Individual EA or with revision to the Municipal Class EA standards of practice to include them. Given the latter is too late for this particular Class EA, we recommend that the Ministry consider a ‘bump-up’ to a Part II Individual EA to address these outstanding issues and concerns which follow:
- In my view, widening to 5 lanes is premature. The Region has not demonstrated ‘need’.
- Recommendation to widen is based on the old 2002 Transportation Master Plan that is now undergoing an Update by the Region. This needs to be completed before widening is considered.
- Transportation Alternatives undergoing EAs now were not evaluated specifically with respect to reducing car use and the need to widen now: Phase II VIVA dedicated lanes up Yonge Street; Biking & Walking Master Plan; Carpool Matching/SmartCommute/404 Carpool lots; new GO Station in Richmond Hill being considered now for all-day GO train service.
- Environmental Health impacts on residents ignored. Lighting, smog, noise not addressed. Noise increase is based on an unvalidated model. No cumulative or health analyses done.
- Climate change impacts ignored. More storms + more pavement = floods! More cars = more CO2. Planning for climate change must occur in all Environmental Assessments to avoid costly infrastructure replacement and downstream flooding and also analyze impacts of cars on climate.
- Rouge Strategy recommends reduced pavement and renaturalization for flood control. This strategy is developed from modelling climate change and future urban growth (pavement) impacts using urban stormwater data and climate models. The technique is used elsewhere as ‘Low Impact Development’ (LID) to reduce paved surface runoff and do onsite infiltration for storm water. Transportation Master Plan (TMP) update should incorporate new thinking and designs.
- Peak Oil impacts ignored from rising oil prices from ‘peak oil’ when the easy oil is gone and when supply cannot match demand due to global growth. The reality of fossil fuels as a finite resource needs to be acknowledged in TMP Update. Planning to 2031, so past estimated ‘peak’.
- Impacts on residents and wildlife are outstanding. Urban ‘upgrade’ with full street lighting will degrade dark sky and property values; ‘curb and gutter’ is an amphibian ‘death-trap’; connectivity is not seriously considered as no wildlife studies were done; salt impacts on forest, streams & wells and air & light pollution measures and impacts on wildlife were ignored
- An increase in traffic speed is a safety issue. There will be an increase in speed, without stops or traffic lights, with ‘street racing’ and safety issues for traffic turning out of residential streets.
- The Class EA incorrectly interprets the Oak Ridges Moraine Conservation Plan. The plan states that transportation infrastructure is not allowed unless there are no reasonable alternatives as interpreted by the Region. The Region incorrectly says that roads are allowed as long as its justified and there is no reasonable alternative. This is permissive when the Act is restrictive.
- The ORMCP Section 22(2) Areas of Natural and Scientific Interest (ANSI) was ignored. It states that a Vegetated Protection Zone be required adjacent to an ANSI, such as the Jefferson Forest, with a Natural Heritage Evaluation being done to determine the limits of the Vegetated Protection Zone for all site alterations, including infrastructure where ‘need’ has to be demonstrated with no reasonable alternatives. With 5 lanes, vegetation will be removed along the road way.
- The intent of the ORMCP has not been upheld with this Class EA. The intent of the ORMCP is to protect all natural heritage features and functions and their water resources. Any work within the ORM should have been treated as an Individual EA (Category D) “if potentially adverse effects are suspected or serious public concern exists.” (ORC Screening Rules) In Natural Core Areas, Natural Linkage Areas and Countryside Areas, only very restricted new resource management, recreational, transportation, infrastructure and utility uses are permitted within these features.
Please seriously consider our issues that remain outstanding through this Class EA process, which is premature and is in need of a Part II Environmental Assessment to look at full impacts and alternatives considering the location on the Oak Ridges Moraine through Core area and the Provincial Acts that have post-dated the TMP 2002. The test of ‘need’ was not demonstrated in this Class EA.
If you wish to contact us, feel free to do so.
Thank you.
Natalie Helferty, Past President
Marianne Yake, President
On behalf of the Executive
Cc:
Bruce MacGregor, bruce.macgregor@york.ca York Region Commissioner, Transportation & Works
Bryan Tuckey, bryan.tuckey@york.ca York Region Commissioner, Planning & Development Services
Salim Alibhai, salim.alibhai@york.ca Project Manager, Roads, York Region Transportation & Works
Eugene Zawadowsky, ezawadowsky@richmondhill.ca Richmond Hill Commissioner Engineering & Public Works
Marcel Lanteigne, mlanteigne@richmondhill.ca Manager Transportation, Richmond Hill Engineering & Public Works
Joan Anderton janderton@richmondhill.ca CAO, Town of Richmond Hill
David Barrow dbarrow@richmondhill.ca Deputy Mayor, Town of Richmond Hill
Brenda Hogg bhogg@richmondhill.ca Regional Councillor, Town of Richmond Hill
Ana Bassios abassios@richmondhill.ca Planning Commissioner, Town of Richmond Hill
Vito Spatafora vspatafora@richmondhill.ca Ward Councillor, Town of Richmond Hill
Joe DiPaola jdipaola@richmondhill.ca Ward Councillor, Town of Richmond Hill
Minister John Gerretsen, minister@mah.gov.on.ca Minister of Municipal Affairs, Province of Ontario
Gord Miller, gord.miller@eco.on.ca Environmental Commissioner, Province of Ontario
Andre Marin, amarin@ombudsman.on.ca Ombudsman, Province of Ontario
References:
Richmond Hill By-Law to Regulate Light Pollution http://www.rasc.ca/light/print/rich.htm
Greenbelt Act and Plan http://www.mah.gov.on.ca/userfiles/HTML/nts_1_16289_1.html
Oak Ridges Moraine Act and Plan http://www.mah.gov.on.ca/userfiles/HTML/nts_1_31_1.html
Technical Papers for the ORMCP http://www.mah.gov.on.ca/userfiles/HTML/nts_1_16401_1.html
ORC EA Screening Tool http://www.orc.on.ca/AssetFactory.aspx?did=382
No comments:
Post a Comment