Updated February 28 2007

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News & Status > Queensway Bump-up

The widening of Queensway has been challenged by a bump-up request to the provincial Minister of the Environment. Grounds for the bump up are outlined below. Please consider lending you support to this bump-up request by contacting the Minister of the Environment.

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Bump-up cover letter

February 23, 2007
The Honourable Laurel C. Broten
Minister of Environment
12th Floor, 135 St. Clair Avenue West
Toronto, Ontario
M4V 1P5

Dear Minister Broten:

Re: PART II ORDER, Preliminary Design Study and Environmental Assessment for Highway 417 (Ottawa Queensway), from Highway 416 to Anderson Road (G.W.P. 663-93-00 C.A. 4005-A-000090)

This letter is written on behalf of the following community associations and organizations:

• City Centre Coalition (coalition of 10 community associations)
  • Action Sandy Hill
  • Centretown Citizens' Community Association
  • Dalhousie Community Association
  • Hintonburg Community Association
  • Ottawa East Community Association
  • Glebe Community Association
  • Dow's Lake Residents' Association
  • Old Ottawa South Community Association
  • Carleton University Students' Association
  • Citizens' for Safe Cycling
• Sierra Club of Canada (Ottawa Group)
• Transport 2000 Canada

The purpose of this letter is to request a rejection or bump-up of the environmental assessment (EA) being conducted by the MTO for proposed infrastructure for Highway 417 (Ottawa Queensway) from Highway 416 to Anderson Road.

The MTO has directed the Queensway EA as a Class EA. The MTO’s selection of the Class process was inappropriate given the unusual nature of the Queensway and the need to seriously consider options other than just road widening. Transit only options would require an individual EA.

This specific EA failed to properly compare more environmentally sustainable transportation alternatives. It also failed to adhere to sound public consultation practices by avoiding the question of lower speed limits and by undermining neighbourhood traffic studies.

The recommendation to accommodate more cars on the Queensway will worsen air quality, increase greenhouse gas emissions and undermine Ottawa’s Transportation Master Plan modal share target for transit.

We ask that you review the attached rationale in making your decision. Please direct any communications on this matter to Pierre Johnson, 61 Lees Avenue, Ottawa, Ontario, K1S 0B8.

Sincerely,

Campbell Robertson
Chair, City Centre Coalition

Carol Gudz
Ottawa Group, Sierra Club of Canada

David L. Jeanes, P. Eng.
President, Transport 2000 Canada

Pierre Johnson
Past President, Ottawa East Community Association

c.c. Honourable Dalton McGuinty, Premier, Province of Ontario
Gordon Miller, Ontario Commissioner of the Environment
Honourable Madeleine Meilleur, Minister of Culture, Francophone Affairs
Honourable Jim Watson, Minister of Health Promotion
Richard Patten, Member, Ottawa Centre
David Lindensmith, Senior Project Engineer, Ontario Ministry of Transportation

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Bump-up document

TABLE OF CONTENTS: PART II ORDER, Preliminary Design Study and Environmental Assessment for Highway 417 (Ottawa Queensway), from Highway 416 to Anderson Road (G.W.P. 663-93-00 C.A. 4005-A-000090), MTO

BACKGROUND
PROPOSED UNDERTAKING DIFFERS FROM OTHER UNDERTAKINGS IN THE CLASS TO WHICH CLASS EA APPLIES
1) Proposal is not recurring
2) Length of time for assessment
FAILURE TO ADEQUATELY CONSIDER ALL ALTERNATIVES AND COMPARE THEIR IMPACTS
1) Transit
2) Speed limit reduction
INCOMPLETE PUBLIC CONSULTATION
1) Avoidance of response to speed limit question
2) No integration with City’s Area Traffic Management plans
BENEFITS OF CARRYING OUT INDIVIDUAL EA
BENEFITS OF REJECTING EA
APPENDICES
A) Air quality map for Ottawa
B) Chronicle of correspondence on speed limit question

PART II ORDER, PART II ORDER, Preliminary Design Study and Environmental Assessment for Highway 417 (Ottawa Queensway), from Highway 416 to Anderson Road

BACKGROUND

The Environmental Assessment (EA) for Highway 417 (Ottawa Queensway), from Highway 416 to Anderson Road aims to improve the operation as well as the safety of the highway.

The Queensway is not only a very significant piece of transportation infrastructure in Ottawa, it is the largest identifiable local source of air pollutants in the region. Ottawa does not have heavy industry, which leaves transportation in a dominant role in both greenhouse gas and air pollution production. See appendix A for a map representing the emissions of all major roadways in the Ottawa-Gatineau region. From an air quality, climate change and effect on the urban form, nothing else in Ottawa comes close to matching the Queensway’s impact. This makes any recommendations on this roadway of great importance to the health of the city and its residents.

Air pollution related deaths in the Ottawa area were estimated by the Ontario Medical Association to be 290 in 2005 and if current trends are maintained will rise to 490 by 2026.

The Environmental Assessment (EA) for Highway 417 includes a number of recommendations such as some mainline widening, some ramp reconfigurations and sound barrier upgrades. Although these various recommendations are part of the same study, they can also be thought of as independent of each other (e.g. the interchange modifications at Woodroffe are not in any way dependent on the interchange modifications at Nicholas). The 417 EA is in a sense an omnibus study serving a variety of purposes such as safety, capacity, and the environment with a number of recommendations. This Part II Order, “bump-up” request is in response to many but not all of the recommendations in the study.

The omnibus nature of this 417 EA is appropriate to avoid the recommendations being piecemealed in isolation in separate studies. The scope of this 417 EA has not been broad enough. The scope should have included more alternative modes and this study should not have been separate from the study which looked at the 417 west of the 416 junction. First the study looking at the 417 west of the 416 recommended widening and now a study for the 417 east of the 416 is doing the same. This is piecemeal widening of the 417. It is classic “domino” style road widening where the need to alleviate a bottleneck is used to widen a section of road, which in turn contributes to another bottleneck further downstream and the process is repeated. While it is too late to request a bump-up on the Queensway widening recommendations west of the 416, we have the opportunity to see this current 417 EA done more thoroughly to avoid the cascade of environmental dominos downstream of this study.

PROPOSED UNDERTAKING DIFFERS FROM OTHER UNDERTAKINGS IN THE CLASS TO WHICH CLASS EA APPLIES

Class environmental assessments are intended for application to projects which are:

• Recurring;
• Similar in nature;
• Limited in scale;
• With predictable environmental effects; and
• Responsive to mitigation.

The Preliminary Design Study and Environmental Assessment for Highway 417 project does not fit these criteria. It differs from typical proposals in the class.

1) Proposal is not recurring

The Queensway is significantly different from current or conventional highway designs. The downtown portion was conceived in the late 1950s and built in the early 1960s by exploiting a rail corridor, which traversed the heart of the city. The resulting highway was much wider than the rail corridor and it lacked adequate space for ramps as well as interchanges. The result in many cases was ramps with geometries inadequate for the speed of the traffic as well as a highway in atypical proximity to residential land use. Early in the study one the transportation planners aptly said “we would not design a highway like this if we were doing it today”. The Queensway is unique. For its first decade it was a limited access divided highway only serving the immediate Ottawa area. It began life as a highway for daily commuters. In the early 1970s the 417 was completed to highway 40 in Quebec making it for the first time connected to an inter-city divided highway and it wasn’t until the completion of highway 416 in the 1990s that the Queensway became linked to other 400 series highways in Ontario.

This 417 EA encompasses the oldest parts of the Queensway. Ramp modifications and widening alternatives in these areas are anything but typical and certainly not routine or recurring as is the intended use of a Class EA.

2) Length of time for assessment

This 417 EA study began in late 2002 and the first public meetings were in January of 2003. It has been more than 4 years since this study began. The length of time elapsed is indicative that this should not have been a Class EA.
The length of time draws into question the assumptions used at the beginning of the study to justify the need as well as the assumptions anticipating the availability of transit infrastructure.

In 2002, the population growth projections in Ottawa’s Official Plan were over-estimated. The growth projection figures were established during the boom in the local high technology sector. With the downsizing of this part of the Ottawa economy, the figures have been shown to be a major over-estimation. Over a four-year span, the figures were inaccurate by 26%.

The backbone of the Transportation Master Plan (TMP) in 2002 was a light rail network with EAs underway for North-South and East-West routes. The North-South project has since been shelved and the continuation of East-West LRT EAs are now on hold.

In spite of reduced actual growth, Ottawa’s transit modal share target remains at 30%. The means of achieving that target is much less clear now than in 2002 and the reduced actual growth would also reduce the overall demand, particularly for roads.

The TMP is in the throes of significant changes which were unanticipated 4 years ago. The Queensway as the largest single roadway in the region should not be re-designed out of the context of the city’s Transportation Master Plan.

FAILURE TO ADEQUATELY CONSIDER ALL ALTERNATIVES AND COMPARE THEIR IMPACTS

The EA act requires examination of all reasonable alternatives, in a transparent clear process. Two alternatives were inadequately examined in this case: transit and lowering the speed limit in the older section of the highway. For instance: neither of these options was compared with the preferred solution to determine its effect on air quality.
Before describing the alternatives which were not properly considered, some of the impacts of the recommendation from the 417 EA to widen portions of the Queensway must be highlighted for contrast: higher volume of vehicles on the 417, more noise coming from the 417, more pollution and greenhouse gases generated from the Queensway, as well as effectively moving the Queensway closer to homes, parks and playgrounds. Proximity to a major roadway is critical in evaluating health impacts. Amongst the most lethal of pollutants and cumulative in their effect are ultra fine particles. The concentrations of these are highest the closer one gets to a roadway or conversely, as in some of the recommendations in the 417 EA, the closer the roadway gets to where people are. The Queensway is already the largest single source of air pollution in Ottawa. See appendix A for a graphic representation from Ottawa’s 1995 EMME/2 model for evidence.

1) Transit

Transit was not compared as an option in this study. Ottawa’s TMP with its 30% modal share target for transit was given as a rationale for not needing to consider transit. The underlying assumptions being that:

• the TMP plans including the light rail plans would be sufficient to meet the 30% objective,
• the 30% transit modal share target is a maximum.

Any transportation need not met by 30% transit was therefore justification to only look at a road-based solution because we can exceed our modal share target for automobiles but not for transit.

The modal share target in and of itself does not command percentages of commuters to use a particular mode. Commuters make choices based on a range of factors which include the relative performance of the available infrastructure. What is available is part of what determines the actual modal share. One cannot use the 30% figure and extrapolate a fixed number of bus riders and fixed number of cars on the road, ignoring whether transit or road capacity is added to the network. This is nonsense but in effect what was done in this 417 EA.

The Transportation Environmental Study Report on page 80 in section 6.2.2.6 on Air Quality states that “Concentration levels for the “Build” scenario were higher than for the “No-Build” scenario, since the increase in highway capacity provided under the Build scenario is expected to result in an increase in traffic volumes on Highway 417 with a corresponding reduction in auto use on adjacent streets.” This statement reveals the flaw in the analysis: that exactly the same number of people choose to drive during the peak hour regardless of the availability and performance of transportation alternatives.

Lack of road capacity during the rush hour contributes to some people choosing to travel at other times of the day, or telecommuting, or using another mode of transport if available. Conversely increased road capacity contributes to more people driving who otherwise don’t travel during rush hour or who use other modes. The former effect is often called induced traffic/demand and latter is called displaced traffic. Both effects also apply to transit capacity.

It should come as no surprise that the east end of Ottawa, which has fewer alternatives in terms of major roads to get downtown, has a higher transit modal share than the west end. Transit availability is part of the equation but so is road availability.

Transport Canada endorses sustainable transportation planning tools such as TransDec, which account for induced demand.

There was no accounting for induced or displaced traffic in the 417 EA. Therefore, the extent to which a widened Queensway would displace traffic away from transit has not been determined. The extent to which a widened Queensway would make achieving a 30% modal share for transit more difficult remains unmentioned in the 417 EA. The air quality assertion quoted above implying a zero sum of pollution lost on adjacent streets being equivalent to the pollution gained on the Queensway cannot be supported since the number of cars on the road during rush hour would not be the same.

If transit options had been compared in this 417 EA, we would have an estimate of trips displaced from roads and the resulting effect on air quality would be much more significant.

Ottawa currently does not have a secure plan to reach or surpass the 30% transit modal share target and this 417 EA is failing to contribute options to such a plan.

Transit options which should have been explored for technical feasibility as well as to compare their impacts (e.g. air quality) include but are not limited to:

• Using the entire corridor length for a light rail line;
• Using a portion or portions of the corridor for light rail;
• Introducing dedicated bus lanes over the entire corridor;
• Using dedicated bus lanes in portions of the corridor.

Considering a single line of light rail can carry the equivalent number of commuters as 7 lanes of highway, transit alternatives should have also included converting one of the existing lanes on the Queensway to provide a net gain in number of people carried, the speed of their journey and improved rather than worsened air quality.

2) Speed limit reduction

At the first Public Advisory Committee (PAC) meeting on January 14, 2003 David Jeanes of Transport 2000 raised the question about considering reducing the speed limit on older sections of the highway. Initially this suggestion was brought up in response to the issues surrounding the safety and operational challenges of the downtown ramps which are substandard in length. Other potential operational benefits for the mainline were also mentioned.

There are a number of reasons why lowering the speed limit within the Greenbelt is an alternative worth analyzing. These include:

• safer and better operation of the ramps which currently provide inadequate acceleration or deceleration length,
• safer operation for the ramps with tight radii where rollovers are an issue,
• reduced noise and vibration,
• reduced fuel consumption,
• reduced greenhouse gas emissions and reduced pollution,
• reduced severity of accidents when they do occur,
• more efficient throughput per lane of roadway,
• reduced speeding on city streets which are fed from highway off ramps.

The potential benefits listed above was never quantified nor were the costs (e.g. travel time outside of rush hour). The optimal speed for both road throughput (i.e. cars per hour) and fuel efficiency is near 60km/hr. The current speed limit on the 417 is 100km/hr inside and outside the city core. Other cities such as Gatineau, Denver, Kitchener-Waterloo, Edmunston, and Montreal have divided highways with reduced speed limits (in the 70 to 80 range) as highways traverse the downtown area. See appendix B.

Lowering the speed limit on a portion of the 417 does not preclude other recommendations in this EA. It could be an additional recommendation but because it has the potential to improve environmental, safety and operational issues both along the mainline and for the ramps, this alternative might replace the need for many of the other more expensive recommendations. This potential was never quantified or compared with the “Build” or “No-build” scenarios.

INCOMPLETE PUBLIC CONSULTATION

1) Avoidance of response to speed limit question

The question of investigating a lower speed limit on portions of the Queensway was raised at the first PAC meeting on January 14, 2003. The same question was raised at each subsequent PAC meeting. The question was also followed up on in writing at least 7 times over the course of the 417 EA. See appendix B for the chronicle of written correspondence on this question.

In each instance, TSH (Totten Sims Hubicki) or the MTO representative indicated a response would be forthcoming. A response was in fact never received nor is there any mention of this question in the Transportation Environmental Study Report (TESR). From a process point of view this is a serious and unusual omission. The TSH and MTO design team were quite forthcoming and responsive to other questions raised at the PAC and during the public consultation but this question is conspicuous in its absence. If this issue had been raised only once, one might understand an accidental omission but given the number of times it was raised and the repeated assurances that a response would be forthcoming, the absolute absence of any mention of this question is clearly not an accident and one must conclude it is intentional.

The handling of this question has been neither clear nor transparent. It showed a lack of respect for the Public Advisory Committee and the public consultation process. Several times a response was promised. Members of the PAC were misled and this question has in effect been hidden from the public record.

2) No integration with City’s Area Traffic Management plans

In at least 3 instances, the plans for ramp modifications failed to be integrated into neighbourhood traffic plans. The 3 instances illustrate that the process to arrive at final recommendations was too narrow and ignored neighbourhood specific traffic plans in Old Ottawa East, in the Glebe and in Centretown.

In Old Ottawa East the recommendation to modify the eastbound off ramp onto Lees Avenue disregards the principles of the neighbourhood transportation plan. In 2000, the Region of Ottawa-Carleton sponsored the Main Street Transportation and Streetscaping Study which recommended measures throughout Old Ottawa East to mitigate improper driver behaviour and cut-through traffic. As a result of the 2000 study, a number of traffic calming measures have been implemented and more are planned. The proposal to align the Lees Queensway off-ramp with Chestnut Street would facilitate more cut-through traffic, particularly onto Evelyn as an alternate route to Main. Evelyn is already susceptible to cut-through by cars wanting to avoid the queue at the Lees and Main traffic light. Safety on Evelyn is a high priority due to the presence of Lady Evelyn elementary school. Additional cut-through on Chestnut and onto Evelyn in particular would be unacceptable.

The proposal in this 417 EA would require movement restrictions be added to the intersection of Lees and Chestnut to mitigate cars going straight through. As documented in the 2000 study, the neighbourhood is already plagued by drivers ignoring turn restrictions and one-way signage.

The most effective discouragement for cut-through would be to move the off-ramp to another point along Lees such that the result is a T intersection. The Ottawa East Community Association communicated this position to the study team but their requests were disregarded.

The Glebe Traffic Plan was approved by City Council in 2002. A chief objective of that plan is also to reduce cut-through traffic. The changes proposed to Bronson, Chamberlain and Imperial fail to address all the concerns of residents in the area to improve safety and reduce cut-through. For instance, part of the Glebe Traffic Plan includes a recommendation to ban right hand turns from northbound Bronson on all but the last street in the Glebe during the morning rush hour. Without the 417 EA recommendation that street would be Imperial but if the 417 EA’s recommendation for Chamberlain were implemented the question of where the right turn restriction should be applied has not properly addressed. It is further complicated because the 417 EA proposal will not allow left hand turns from Bronson onto Chamberlain and force those movements onto Imperial. This fails to take advantage of the opportunity to reduce cut-through from Imperial onto Renfrew into the neighbourhood. The Traffic Committee of the Glebe Community Association regards the problems for this area as unresolved by the 417 EA.

The Region of Ottawa-Carleton approved the Centretown Traffic Calming Plan in 1998. Its recommendations are also aimed at reducing the negative impact of cut-through traffic. The changes recommended in the 417 EA will result in an additional 500 vehicles per hour exiting at the eastbound Catherine/Metcalfe ramp headed for Centretown in the morning. There are no plans to increase capacity on the arterial roads in Centretown. There is no spare capacity to handle these cars. In the TMP, all major roads and arterials in the entire area of downtown north of the Queensway are to operate at a Level of Service (Los) of F, which is the worst and most congested state during rush hour. Looking at the current air quality situation (see appendix A), Centretown is second only to the Queensway itself in terms of density of pollution produced. Mitigation for 500 more cars per hour in Centretown and the resulting air pollution has not been addressed in the 417 EA.

The aforementioned neighbourhood traffic plans approved in 1998, 2000 and 2002 all had extensive public input and engagement. Objections from the community to proposals for the offramps at Lees, Bronson and Catherine have been rejected with less public involvement than other issues in the neighbourhood traffic plans had been. The process used in these neighbourhood traffic plans has been undermined by the 417 EA.

BENEFITS OF CARRYING OUT INDIVIDUAL EA

The Class EA process used in this 417 study is intended for routine and recurring highway extensions. The usual outcomes of such studies are recommendations to add and modify asphalt. Using a process tailored to such outcomes, it should come as no surprise that non-asphalt-based solutions are absent from the recommended alternatives. They are outside the norm of the intent of the Class EA process.

A transit solution would require an individual EA. A Class EA is insufficient to proceed with a transit solution. This 417 EA did not properly consider or compare a transit solution. This is probably the number one issue raised at all the public open houses over the course of this EA.

Judging by the response of the design team to the idea of evaluating speed limit reduction, this alternative was viewed as neither routine nor recurring. They had little knowledge and no experience with where this was already used, even within Ontario.

The Queensway as it traverses the centre of Ottawa is unusual. Even with the asphalt-based recommendations in this 417 Class EA, the Queensway would remain unusual and unique. Future studies of this section of the corridor should be individual EAs as well.

The Queensway has also the distinction of being the single largest emitter of air contaminants in Ottawa. Air quality and climate change are growing in importance and urgency. The true impact of road construction alternatives has been masked by assuming that the transit modal share target prescribes the number of cars on the road without regard for what infrastructure is provided.

To sum up, the benefits of requiring an individual in this case EA would be:

a. Use of an EA process in keeping with the unique character of the Queensway.
b. Comparing alternatives more thoroughly which could contribute positively to Ottawa’s air quality and greenhouse gases objectives.
c. Providing an answer to the question of whether or not speed limit reductions would be of sufficient benefit to merit being recommended instead of or in addition to other alternatives.
d. Including a comparison of transit alternatives.
e. Factoring in induced or displaced traffic which would more honestly forecast air quality impacts of alternatives.
f. Providing the opportunity to remain consistent with the city’s evolving TMP and to complement rather than interfere with established neighbourhood traffic plans.

BENEFITS OF REJECTING EA

The Environmental Assessment process should facilitate an evolution towards more sustainable transportation alternatives. It should not be a vehicle to re-tread the car-centric sprawl-oriented transportation biases of the last century.

Rejecting the 417 EA would send a clear signal to the members of the Ottawa public that the Province of Ontario recognizes the importance of air quality and climate change. It would also signal the need to consider alternatives which are not car-centric with a complete and detailed examination.

Rejecting the EA would indicate that the provincial government expects proponents to use up-to-date scientific analysis and planning tools, and re-enforce the EA Act’s requirement for an examination of all reasonable alternatives, in a transparent clear process.

It would demonstrate support for the principles of environmental assessment: EA is intended to be a planning tool, and EA is intended to integrate the values of the public into the decision-making process. Transit was probably the number one issue raised repeatedly at the public open houses over the course of this 417 EA. Transit has been a higher priority than the private automobile for many years in Ottawa’s Official Plan and its Transportation Master Plan reflecting the public’s desire to improve Ottawa’s quality of life. The public’s values are not reflected in a Class EA which only recommends solutions for single occupancy vehicles.

APPENDIX A: Air quality map for Ottawa

APPENDIX B: Chronicle of correspondence on speed limit question

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