Queensway Coalition

Dear Minister Gerretsen,

In response to your letter of August 1 2008 about the Class EA (Environmental Assessment) done for Highway 417, we would like to respectfully ask you to reconsider your decision. The reason for this request is that there remain omissions and key questions unanswered. Our understanding of the EA Act is that it requires all reasonable alternatives to be considered. We submit to you the following unresolved questions as grounds to either stay or reverse your approval of the Class EA for Highway 417.

1) Why was there no mention in your response of the two examples we brought up (both at our meeting with the MTO (Ministry of Transport of Ontario) in January 2008 and in our subsequent correspondence to you in May 2008): the 55mph speed limit in the US in the 1970s, and most importantly highways 7 and 8 in Kitchener Ontario? What are the specific technical differences between Kitchener and Ottawa including geometry and accident rates to support (or not) the MTO claims? We chose highways 7 and 8 in Kitchener because it is an example of divided highways in Ontario where the speed limit is reduced as one enters the city. Although it was claimed by the MTO in our January meeting that this was not a fair comparison because the geometry on those highways would not support higher speed, a subsequent review from aerial photos of the radii of the tightest of the curves on highways 7 and 8 in Kitchener compared to the 417 in Ottawa reveals that the 417 has the same or tighter curves. Based on the that evidence, the speed limit should be the same or higher in Kitchener but it isn't. There should be accident data per vehicle/kilometer travelled from both cities to support the claim that lower speed limits will lead to less safe conditions. Given that the MTO had been evasive on this question and repeatedly misled us that a response would be forthcoming prior to our bump-up request (as documented in our original bump-up document in in February 2007), we expect a thorough and complete response to the specifics we raised.

2) Why will the assumptions and recommendation in this Class EA not be revisited as the city's TMP (Transportation Master Plan) objectives used are now out of date? The population forecasts and modal share targets have been revised this year and should be approved by Ottawa City Council this fall. The new transit plans the City is working on now are no longer based on the 5 year old targets used in the 417 study because they are no longer considered valid. The last time the TMP targets changed, the MTO went back to the drawing board on this 417 EA. The study has gone on so long that the TMP targets are changing again but unlike the last time the EA is not being reworked. It couldn't be ignored or put off to a future detailed design study earlier in this EA but it can now?

3) How can the downtown road network accommodate hundreds more cars per hour when there is no spare capacity? On the one hand, the MTO proposes to add capacity to the 417 to enable as much as 800 additional vehicles/hr to get to the Metcalfe/Catherine exit with a stock explanation of “exiting volume will use whatever residual capacity exists on the arterial network”. On the other hand, according to the city's TMP, the road network in downtown will have no spare capacity in that area and indeed it will be operating at a Level of Service of F (failure). These two realities are inconsistent. It makes no sense to pour more vehicles onto downtown roads that are already congested to the point of failure.

4) Why was the agreement reached with respect to the Lees eastbound offramp watered down? The agreement reached at the January 2008 meeting with the MTO was that measures to prevent cut-through traffic would be implemented concurrent with the ramp realignment. The phrase "should a problem materialize" was a surprise in your letter and was absent from the meeting notes the MTO sent us after the January 2008 meeting. The addition of this qualifying phrase violates the understanding which led the Ottawa East Community Association to withdraw its objection to the ramp change in our May 2008 correspondence to you.

5) Why does Highway 417, which is the largest local source of pollution and GHG emissions in Ottawa, not have a reduction target? This question does not relate to our bump-up request per se but to the letter you sent us and to the mandate of your ministry. As you point out, the Queensway's GHG emissions will rise by 3% as a result of this project but this is then described as having "negligible impacts". The Queensway is the largest local source of pollution in Ottawa. Most environmentally responsible jurisdictions are looking at ways of reducing GHGs. The City of Ottawa signed on to the Federation of Canadian Municipalities' Partners for Climate Protection Program with objectives to reduce community wide GHGs. Having the largest source increase by any amount as opposed to capped or reduced will likely eliminate any possibility of city-wide GHG reductions.

We believe the five questions above are critical. They should be answered before the Highway 417 project is allowed to proceed. Should the top four questions in particular remain unanswered, we intend to use the communications we have received from the MTO and the MOE as evidence that aspects of the public consultation in this EA were pro-forma and that the handling of the bump-up request has condoned a public consultation which was misleading. We would be happier to have these questions fully answered.

In closing, we hope these questions will be sufficient grounds for you to revisit the Highway 417 Class EA. Please advise us if you will reconsider. Thank you for the consideration.

Sincerely,

Pierre Johnson
61 Lees Avenue
Ottawa Ontario K1S 0B8
613-234-1151

with the support of
Campbell Robertson, CCC (City Centre Coalition),
David Jeanes, Transport 2000,
Carol Gudz, Ottawa Group of the Sierra Club of Canada,
Nick Masciantonio, Ottawa East Community Association