Updated May 31 2008

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News & Status > Follow up Correspondence on the 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.

Follow up cover letter
Follow up document
Minutes from January 21 2008 meeting with MTO (pdf)
Original February 2007 bump-up cover letter
Original February 2007 bump-up document
Original APPENDIX A: Air quality map for Ottawa
Original APPENDIX B: Chronicle of correspondence on speed limit question

Follow up cover letter

May 22 2008

The Honourable John Gerretsen
Minister of Environment
12th Floor, 135 St. Clair Avenue West
Toronto, Ontario
M4V 1P5

Dear Minister Gerretsen:

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 11 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
  • Westboro Community Association
  • Citizens for Safe Cycling
• Sierra Club of Canada (Ottawa Group)
• Transport 2000 Canada

This letter provides an update to our position with respect to our bump-up request letter written on February 23 2007 in the wake meetings with the Ministry of Transportation (MTO) in January of this year.

Although some of the concerns raised in our original bump-up request have been addressed, a number of very key issues have not been satisfactorily resolved and for that reason, we still request a rejection or bump-up of the Environmental Assessment (EA) conducted by the MTO for Highway 417 (Ottawa Queensway) from Highway 416 to Anderson Road.

The Environmental Assessment Act requires that all reasonable alternatives be studied in an EA with open and transparent public consultation. This study remains lacking on both counts. It still does not include a comparison with more environmentally sustainable transit options. The handling of the speed limit question remains incomplete. Downstream effects particularly in the Centretown area have not been adequately quantified nor mitigation recommended.

We have attached a more detailed explanation for each point (both for the ones that have been resolved and those that remain outstanding), which we ask you to review in your decision. We also included a copy of the January 21 2008 meeting report and a copy of our previous bump-up letter for reference.

If implemented, the recommendation to accommodate more cars on the Queensway will increase air pollution and undermine Ottawa’s Transportation Master Plan modal share target for transit. It should be emphasized that local air quality measurements done this year confirmed that the worst pollution in Ottawa is found in proximity to the 417 and that this highway is already within 200 meters of a dozen schools and 15 parks or sports fields. There is no other potential road expansion project in Ottawa which could put as many young people at higher risk. Highway expansion in this instance cannot be seen as environmentally sound or sustainable.

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, MPP Ottawa Vanier
Honourable Jim Watson, MMP Ottawa West-Nepean
Yasir Naqvi, MPP Ottawa Centre
David Lindensmith, Senior Project Engineer, Ontario Ministry of Transportation

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Follow up document

TABLETABLE OF CONTENTS: Follow-up to January 2008 meeting with MTO 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), MTO

Issues resolved as a result of meeting with the MTO in January 2008
1) Similar highways dealt with under Class EA
2) Accommodation for neighbourhood Area Traffic Management
3) Air quality reports

Issues outstanding in support of the Part II Order Bump-up
1) Duration of study period
2) Lack of transit comparison
3) Speed limit reduction
4) Downstream effects in Centretown

Issues resolved as a result of meeting with the MTO in January 2008

1) Similar highways dealt with under Class EA

At our meeting on January 21st the MTO noted that “the QEW widening through St. Catharines, which is similar in characteristic to the Queensway, was completed as a Class “B” study” and that “the QEW widening from Burlington to Oakville as another example.” On the assumption that the QEW in these locations is comparable to the Queensway in terms of vintage of design and geometry, the Queensway cannot be considered unique. We accept that assessment.

Looking at aerial photos after the January meeting did reveal qualitative differences in adjacent land usage in comparing the Queensway and the QEW: there is a much larger proportion of schools, parks and sports fields near the Queensway than the QEW. It is unusual by modern standards to locate such a large emitter or pollutants so close to facilities at which children are active. This qualitative difference is a concern from a public health perspective and regrettably we weren’t in a position to make this challenge at the January 21st meeting.

To summarize: we accept the argument in terms of vintage and geometry of design that the Queensway is not unique but we remain doubtful that another similar length of highway could be found in proximity to about 12 schools, 15 parks and 3 retirement homes. Is this land usage difference enough to consider the Queensway unique?

Given the health sensitivity of the young and the elderly to air pollution, we maintain widening the Queensway to accommodate more cars is unwise but that is an argument against the conclusion of the study, not necessarily an argument about whether a Class EA or Individual EA should have been employed.

2) Accommodation for neighbourhood Area Traffic Management

Area Traffic Management in Ottawa is severely backlogged. The wait list for any new study or new recommendations is currently beyond a decade owing to the number of already approved measures which are in the queue but with limited resources for implementation on an annual basis. 2007 was the worst year with $0 in capital funding. In this climate, neighbourhoods with Area Traffic Management plans must ensure that we that advantage of any road reconstruction to ensure measures are implemented “while we are at it”. It is not acceptable to have reconstruction work done with the promise of re-visiting or studying the need for traffic calming down the road. Any ramp changes which risk aggravating neighbourhood cut-through or reducing safety should include mitigation measures concurrently. This would ensure no unwanted side effects from day one and would avoid making the existing city-wide Area Traffic Management backlog worse.

It was welcome to have the MTO acknowledge that measures would be included as part of the Lees ramp realignment in Old Ottawa East to prevent traffic from proceeding straight through onto Chestnut. While we understand the specific measures to be used cannot be decided upon at this stage, the commitment that measures to prevent cut-through would be included in the design of the new intersection would address the original objection to the ramp realignment. The undersigned organizations remain opposed to Queensway widening but would not oppose realignment of the Lees ramp so long as the straight through movement onto Chestnut is never allowed.

We hope the MTO can make a similar commitment to the Glebe with respect to the changes proposed for Chamberlain as a result of proposals for the Bronson offramp.

3) Air quality reports

The Green House Gas (GHG) report prepared for this 417 study was found to be flawed in that the same number of cars was used in the GHG forecast in all sections of the highway in both the build and in the no-build scenarios. As a result, the GHG forecast showed roughly a 1% reduction in GHG emissions from the widened Queensway because it failed to account for a roughly 4% increase in traffic on the highway. The MTO acknowledged the error and committed to correct it. The updated GHG report now shows a net 3% increase in emissions from the 417 in the build scenario. We no longer object to the GHG report and are happy to see the net increase in emissions documented in the revised report.

Issues outstanding in support of the Part II Order Bump-up

1) Duration of study period

This 417 study was started when a previous Transportation Master Plan (TMP) was in effect in Ottawa with a lower transit modal share target. The current TMP included a significant increase in the transit modal share target to 30% and as a result the fundamental assumptions in the 417 study were revisited before any recommendations could be advanced. The issue before us now is that Ottawa’s TMP is due for another significant revision later in 2008. There has been considerable upheaval since the current TMP was included in the Official Plan: the electric light rail plans which had been the backbone of transit in the TMP have been shelved in favour of potentially more ambitious plans, which are the current subject of public consultation. The lost years before implementation and the more ambitious light rail plans indicate the strong possibility of a more aggressive transit strategy. As well, Ottawa’s method of calculating transit modal share was recently changed from the afternoon to the morning rush hour, which should require a recalibration of the 30% transit modal share target to a higher figure. Currently Ottawa’s transit modal share is measured at 23% in the morning as opposed to 17% in the afternoon. There hasn’t been a 6% increase in transit usage, only a change in when it is measured. This recalibration of the modal share has not been factored into the 417 study. The latest revisions to the TMP will be confirmed later this year with an update to the Official Plan.

This 417 study will have spanned three iterations of the TMP but will have only factored in the significant changes from the first to the second iteration. The MTO’s response to this issue at the January 21st meeting was that “TMP impacts may not result in modifications to the content of the Queensway plan, but may alter its implementation schedule”. This response is insufficient for two reasons:

1. The previous update to the TMP merited revisiting basic assumptions in this EA and so should the TMP update which is imminent. The 417 study is not a stand alone transportation assessment because the city’s Official Plan and TMP should take precedent in setting the context and the priorities.
2. The opportunities for public intervention in the detailed design phase are much more limited and it would be too late to revisit this study’s recommendations to widen sections of the 417.

It is reasonable to expect that widening might not be recommended depending on how much more aggressive Ottawa’s transit needs are judged to be in the 2008 TMP.

2) Lack of transit comparison

The recommendation to widen the 417 is forecast to accommodate in the order of 8000 additional vehicles daily or roughly 4% more traffic. Most of that traffic would be in the form of single occupant vehicles. A question that an individual EA, which would include a comparison with transit options, could answer is: how many more people could a transit alternative move daily for a similar investment and with how much less impact on the environment? This study fails to answer that question because transit alternatives were screened out as described in the Transportation Environmental Study Report (TESR) and not carried forward for comparison. This was done because the 30% transit modal share target is treated as a maximum and is assumed to have been achieved. Why is it not possible to entertain exceeding the 30% transit share but it is OK to exceed the modal share for cars? Other cities have gone beyond 30% transit and the environmental/health benefits of exceeding transit share are clearly more sustainable than exceeding the share for single occupant vehicles. It has become clear with the upheaval in the current TMP that Ottawa needs help achieving the transit target. Ottawa will have to exceed 30% modal share for transit. Our transit modal share target should only go up over time and should never go down. The current value should be regarded as a minimum not a maximum. Unmet commuting demand should not by default revert to the road network but rather to the transit system.

The notes provided by the MTO of the January 21st meeting state: “MTO is convinced that the recommended alternative (Queensway widening) is an appropriate component of a balanced transportation plan in Ottawa”. We object strongly to this notion as it presumes we are starting from a balanced state. There is a huge imbalance currently in the current transit funding compared to roads in Ottawa. Factors contributing to the imbalance include:

• There have been many years of no transit funding from the Province of Ontario under Mike Harris while there has never been a hiatus on road building in Ottawa.
• The rules governing how Development Charges can be spent ensure that 90% to 95% of that money can be spent on roads but cannot be spent on transit.
• Road projects have benefited from a faster and simplified Class EA process while all transit projects in Ottawa have been subject to longer and more rigorous Individual EAs. Our bump-up request is in effect asking for a leveling of the playing field which has been unbalanced for years.
• Road capacity in Ottawa has grown faster than the population while transit capacity has not kept up with population growth (in the last 30 years Ottawa’s population has increased by about 40% but in the same time 75% of our road cover was built).
• Transit vehicles are full during rush hour but most cars in the rush hour commute have only 1 occupant making them only 20% to 25% full. Passengers are routinely left sanding at bus stops due to over-crowding. In terms of capacity utilization transit is undersupplied and has no capacity in reserve but the same cannot be said of the private automobile in Ottawa.

What is balanced about investing even more to increase capacity in the mode of transport which has received disproportionately more funding and which is so much more wasteful? We would welcome a balanced approach which will compensate for past imbalances as opposed to building on past biases.

To conform with the EA act, the 417 study should provide an evaluation and comparison of all reasonable alternatives. There is no cost or environmental comparison of any transit alternatives in the 417 study. One only finds comparison of road widening compared to no road widening. Transit is a reasonable alternative and it must be compared regardless of whether it is in the final recommendations

3) Speed limit reduction

In our bump-up request of February 23, 2007 we documented correspondence with MTO of the course of the study where the MTO repeatedly promised to respond to the potential alternative of speed limit reduction but never did. As well, the minutes of the first two PAC meetings in January and May of 2003 acknowledged the question being brought up and that “a reduction in the speed limit on the Queensway is still under review” by MTO and their consultant. The TESR was completed without any mention of this question or any response being given to PAC members. Had we not made this bump-up request, it is clear no review, indeed no answer would ever have been given. Saying you will do something repeatedly and then not doing so is not conducting public consultation in good faith.

At the January 21st meeting an apology and verbal explanation were offered. The explanation, which was not backed up by any documentation or data in the meeting, was that reducing the speed limit would not work and might be less safe. The MTO maintains the opinion that speed limit reduction is not reasonable enough to include in the TESR.

The MTO have sent us a memo on May 16th with references to support their view that a speed limit reduction would be problematic. The bulk of the references support two basic principles:

1. Drivers are more inclined to drive as fast as they perceive the geometry of the highway will safely allow rather than to the posted speed limit.
2. Increased speed differential between vehicles creates higher risk of accidents.

The assumption in using these principles to argue against a speed limit reduction is that a lower speed limit is unenforceable and would result in a bigger speed differential between vehicles. We would challenge both assumptions based on two examples, which we raised at our January 2008 meeting with MTO representatives.

These two examples demonstrate the case of reasonability for lower speed limits:

1. During the 1970s “oil crisis” many US states enacted reduced speed limits on highways with geometries that would safely support higher speeds. It was enforced and it had the effect of contributing to reduced US oil consumption. The speed limits were eventually raised as concerns about supply and cost of oil in the US diminished, not because of operational issues. Lower speed limits were enforceable in the 1970s without the benefit of safer and more effective technology such as photo-radar. How could the experience of the 1970s in the US be explained within the context of the MTOs May 16th memo?
2. Highways 7 and 8 have 80 km/hr speed limits on the approaches to Kitchener. At the January 21st meeting the MTO asserted that this comparison with the 417 was inappropriate due to different standards and design geometries. We do not accept this explanation as aerial photos and maps of both cities reveal the radii are tighter at the 417-174 junction in Ottawa than at the 7-8 junction in Kitchener. In this example we have a current highway within Ontario signed to a lower speed limit with radii less tight than the 417. How do the accident statistics for highways 7 and 8 in Kitchener compare to the 417 in Ottawa? If the assumptions in the MTO’s memo of May 16th are correct then is the accident rate in Kitchener higher than in Ottawa?

In the absence of accident data refuting why the two above examples are not reasonable, we maintain our view as that this alternative merits a technical review to document the pros and cons as either an alternative to or as a complement to solutions proposed in the TESR.

There may be political reasons to do with public opinion that would be impediments to lower speed limits today but growing environmental awareness, concern over air quality, public health and peak oil would support such a change. In either case, the role of the EA study is to provide an evaluation of all technically reasonable alternatives to inform policy and decision makers who can factor other concerns. An EA is not a popularity contest and unpopular alternatives merit an evaluation if they are technically reasonable.

We asked for hard evidence from the MTO on their speed limit opinion. The May 16th memo contains facts but the assumptions about enforceability and the correlation of lower speed limits with higher speed differentials are weak. The question has not been satisfactorily explored. The response falls short of our expectations. Given the previous avoidance of the question and misleading of Public Advisory Committee members we reiterate our bump-up request.

We expect that the technical comparison of the speed limit reduction be documented in the TESR to demonstrate that the MTO apology for misleading PAC members is genuine.

4) Downstream effects in Centretown

When we raised concerns about piecemealing of road studies our concern was not related to the previous 417 study west of the 416 but for downstream effects closer to central Ottawa.

A funnel can be used as an analogy to describe this problem. For morning rush hour traffic, the challenge is primarily getting downtown. The Centretown roads are at or near capacity. The TMP calls for intersections and roads to operate at a Quality of Service (QoS) of F in this whole area. F is the worst in terms of queuing delays and stop-and-go conditions. F is the worst for air quality and fuel consumption. F is equated with failure in terms of performance. The TMP does not include plans to remedy this situation. In this circumstance it is both difficult to push more cars through and it makes the environmental impacts such as air quality non-linearly worse. This is the small end of the funnel.

The big end of the funnel is the Queensway furthest from downtown in the morning. It has spare capacity and isn’t operating as close to F.

By widening the Queensway, the MTO is proposing to make the big end of the funnel larger. Making the big end of the funnel larger will increase pressure on the small end. This pressure will result in either

1. a perceived need to widen the small end of the funnel and/or
2. much more congestion and pollution downstream.

At the January 21st meeting the MTO claimed that downstream road widenings are unlikely due to cost and that “exiting volume will use whatever residual capacity exists on the arterial network”. However, the downtown portion of the arterial network has the least residual capacity and will have none at all as per the city’s TMP.

From a network engineering point of view, one achieves best overall network performance when a balance is maintained between capacity at the sources, in the middle and at the destinations. Ideally, if there are bottlenecks they should be closer to the source than the destination to maintain good network performance (minimizing queuing and the risk of lock-ups). Capacity should be added to the bottlenecks first and foremost. Adding a capacity at points further from the bottlenecks is either wasteful or creates more congestion due to imbalance. This latter mistake is the one the MTO is making by recommending adding capacity in the approaches to downtown.

The westbound offramp at Catherine and Metcalfe illustrates the mistake. The MTO proposal is to add a lane from the east end of town all the way to this offramp. As per this 417 study, this lane will handle an additional 800 vehicles per hour but the lane ends at the offramp. Those additional 800 cars per hour are somehow supposed to access “whatever residual capacity exists on the arterial network” from this single point. This is being treated as an article of faith as there is no supporting evidence in the TESR to demonstrate that there is any residual capacity anywhere near that exit. In the absence of residual capacity, we anticipate significant increased delays and air pollution. The TESR is incomplete in failing to acknowledge or quantify these downstream effects.

The January 2008 approval by the Ministry of the Environment of the EA for the Alta Vista Transportation Corridor further complicates the issue of downstream effects in Centretown from the 417. The arterial road proposed in the Alta Vista corridor will link into highway 417 at the Nicholas interchange. Coincidentally, that roadway is expected to also deliver about 800 more cars per hour in the morning rush hour to the 417 at Nicholas, which is the interchange immediately east of the Catherine and Metcalfe offramp. This means that between the Alta Vista Transportation Corridor road and a widened 417 an additional 1600 cars per hour (800 from the east and 800 from south) will further overburden the capacity of the existing downtown arterial network.

Ignoring downstream effects and leaving these problems to be dealt with in the future is a piecemeal approach to transportation planning.

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Minutes from January 21 2008 meeting with MTO (pdf)

Original February 2007 bump-up cover letter

Original February 2007 bump-up document

APPENDIX A: Air quality map for Ottawa

APPENDIX B: Chronicle of correspondence on speed limit question

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