Browsing the archives for the Fox Road tag.

GHG Denial in TFD EA

Climate Change, South March Highlands

Opportunity Cost

The 2010 CEAA Screening Study for Terry Fox Road Part B contains a manditory section that summarizes the effects of the project on air quality.

Amazingly, the road is assessed as having No Significant impact due to tailpipe emissions and resultant smog and Greenhouse Gas (GHG) effect!

CEAA Summary of Effects On Air Quality

Table 6-5 From CEAA Screening Study

The US Environmental Protection Agency, however, measures vehicle emissions based on the distance driven.  By creating more roads, our cities expand the opportunity for vehicles to drive (generating more GHG in proportion to the length of the road) and create a disincentive for using public transit – roads are more convenient. 

By investing in Terry Fox Drive (TFD), the City has also created an opportunity cost of $47+ M by not putting the same amount of money into public transit.  As an example of the impact of this opportunity cost, currently there is some concern over the cost of student bus passes that are now manditory.  An expenditure of less than $5 M is probably sufficient to allow all students to ride the bus for free.  The $47 M being spent on the road would have enabled students to ride the bus for free for over 9 years!

Real Disclosure

The City should have disclosed that TFD will result in a net total annual emission of 90,324 Tonnes of GHG per year.

 The calculation for this is:

  • GHG increased by volume of traffic x amount of time of traffic on road.
    • Use avg traffic volume x 24 hrs x avg GHG emission per hour per vehicle
    • Assuming peak to average ratio is 10:1 and that peak hour volume is 2 hours x morning & afternoon
    • US EPA: light duty vehicle (incl passenger car but not SUV and miniVANs) = 337 gCO2 per mile
    • US EPA: SUV, miniVAN, pickup trucks are approx 1.3 x worse
    • US EPA: Combined Cars & Trucks = 1.13 x passenger = 1.13 x 337 = 380.81 gCO2 per mile driven
    • 380.81 x 1.6 = 609.296 gCO2 per km per vehicle = 0.6 kg CO2 per km
    • TFD is 4.8 Km long = 0.6 x 4.8 = 2.88 Kg CO2 per vehicle
    • Using unconstrained modal split disclosed in the 2004 EA Traffic Study of 8950 vehicles per hour (In+Out) 8950 x 2.88 = 25776 Kg CO2 per peak hr
    • 8 x 25776 / 1000 = 206.208 tC per day from peak plus 16 x .1 x 25776 / 1000 = 41.2416 tC non-peak per day
    • 206.2 + 41.24 = 247.44 tC per day x 365 = 90,315.6 tC per annu
  • GHG absorption decreased by loss of forest cover due to clear-cutting for the road:
    • Use hectares removed by road times GHG absorption per hectare
      • 4.67 ha Dry-Fresh Sugar Maple-Ironwood Deciduous Forest
      • 0.34 ha Dry-Fresh White Ash-Hardwood Deciduous Forest
      • 5.61 ha Fresh-Moist White Pine-Hardwood Mixed Forest
      • 0.37 ha Young Deciduous Forest
      • 4.67 + 0.34 + 5.61 + 0.37 = 10.99 ha
    • 10.99 x 0.75 = 8.2425 Tonnes Carbon absorbed per year
    • According to David Suzuki Foundation, other GHG removal per hectare of forest is 60 kg/ha = 0.06 t/ha
      • 0.75 + 0.60 = 1.35 GHG per ha
    • 10.99 x 1.35 = 14.8365 Tonnes of GHG per year

 Net change in GHG = 90315.6 + 8.24 = 90323.84 Tonnes per year

Lack of Accountability

The analysis used in the previous section is based on the City of Ottawa’s own traffic study statistics which are based on unreasonable traffic volumes.  Nonetheless the City was obligated to disclose the impact based on the numbers that they used to justify the road.

The Canadian Environmental Assessment Agency (CEAA) was also obligated to ensure that the disclosure was accurate.  How could they have accepted an error of over 90 MegaTonnes of GHG emission?

We deserve much more responsibility and accountability from our public servants at both the Municipal and Federal levels!

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Harper Owes Us Minimum EA Standards

Canadian Politics, Legislative Gaps

The changes to the Canadian Environmental Assessment Act (CEAA)  proposed by Harper will withdraw or limit the Federal government Canadian Environmental Assessment Agency from mandating or participating in a wide range of Environmental Assessments (EA).

Since the federal government will not require EAs on a broader range of projects, this creates a vacume of responsibility that effectively hands over more responsibility to the provinces for assuring that EAs are actually done.

While we should question the wisdom of a federal retreat on EAs, we must absolutely insist that if the government wants to retreat, then they must ensure that a higher minimum standard is in place to be enforced by other levels or branches of government.

There are many holes in the current set of provincial standards as is well evidenced by the current Terry Fox Road fiasco in Ottawa.

For example, current code of conduct for EAs:

  1. Do not require species impact assessment to be performed when species-at-risk are threatened by a proponent of a project.
  2. Do not identify hard minimium criteria for when mitigation alternatives must be considered by a proponent.
  3. Do not require that effectiveness assessment be performed for proposed mitigation measures when the are intended to protect endangered species.
  4. Do not require a proponent to specifically address the issues raised by public consultation – they only require that public consultation occurs.
  5. Do not provide a minimum standard of practice to be used when evaluating alternatives. For example, there is no requirement to prioritize criteria nor is there a required code of practice for evaluating alternatives.
  6. Do not identify hard criteria to guide the selection of scope for an EA. Existing guidance varies by province and uses woolly terms such as “project complexity” which is to be interpreted solely by the proponent.
  7. Do not require minimum criteria to ensure provincial oversight of the EA process. The Class EA process in Ontario, for example, is a proponent-driven process with little involvement from provincial authorities to ensure that it is properly completed.
  8. Do not identify hard criteria for determining when an EA Addendum is required due to changing project circumstances. As an example, the City of Ottawa took the position that it did not need to file an EA Addendum even though it’s project planned to divert the only tributary that drains a sub-watershed.
  9. Do not require proponents to publish and entertain feedback on planned environmental measures.
  10. Do not provide a basis for appeal after completion of the EA process when new information arises that contradicts the assumptions made during an EA. For example, a poorly executed study may fail to identify species-at-risk during the EA process. Subsequent discovery should be basis for appeal.

There are many, many other improvents that can be made to the EA process. If Harper wants to retreat, then he should strike a royal commission to assemble minimum standards to be left in his wake.

Please post your own suggestions for minimum EA standards.

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City of Ottawa Kills Butternut Trees

South March Highlands

Butternut Secret

On March 28, 2010 a team of concerned citizens walked the land that is to be destroyed by the Terry Fox Road Extension. 

This team included long-time residents of the area, Kathleen Riddell, Judy Makin, Paul Renaud, as well as two-well known and highly-respected local biologists, Martha Webber and David Seburn, and an environmental photographer, Scott Newman.

 The team of Land Walkers were astonished by the discovery that, despite an attempt to mark and preserve endangered trees, the City of Ottawa has cut down two endangered Butternut Trees using an undisclosed permit obtained from the Ministry of Natural Resources to cut down canker-affected trees prior to giving them a chance to reproduce.

 This act is further evidence that the City’s hurry to fast-track Terry Fox Road expansion through this ecologically sensitive area is just plain wrong. 

The City has not performed a high-quality, comprehensive environmental assessment of the area despite warnings from Canada’s leading environmentalists that the failure to do so may lead to the eradication of the local population of Blanding’s Turtle.

 The Team also discovered a 200-year old maple tree that is in the centerline of the future roadway.  The City currently has no intention to protect it even though this tree predates the Confederation and likely even the City itself.  

Are there so many 200-year old maples in Ottawa that the City can afford to cut one down because it is in the way of  a poorly planned road?

Prior Studies

 The prior environmental assessments (EA) done in 2000 and 2007 prior to City amalgamation were poorly executed. 

The study done in 2000 failed to note the presence of endangered species at all, while the study done in 2007 notes that 3 endangered species are present but then ignores them for the balance of the assessment. 

Neither EA faithfully applies the prioritized assessment criteria that was developed during public workshops with the residents of the area (residents wanted environmental concerns to be given highest priority). 

Neither EA performed any impact assessment on the ecology of this Provincially Significant area – let alone on endangered species.

Meanwhile, protection of endangered species, such as the Butternut Tree and the Blanding’s Turtle exists at both the Federal and Provincial level.

Paragraph 32(1) Canada Species at Risk Act:  

No person shall kill, harm, harass, capture or take an individual of a wildlife species that is listed as an extirpated species, an endangered species or a threatened species.

 Paragraph 9(1)(a) Ontario Endangered Species Act:

No person shall, (a) kill, harm, harass, capture or take a living member of a species that is listed on the Species at Risk in Ontario List as an extirpated, endangered or threatened species.

The Right Thing

 It is never too late to do the right thing.  The City needs to immediately halt work on the Terry Fox Road expansion pending a comprehensive assessment of the entire ecosystem affected by this roadwork. 

This assessment can then be used to properly plan the road, its mitigation measures, and to control and guide the expansion of the urban boundary in this ecologically diverse area. 

 In the meantime, the existing federal funding for the road should be re-directed towards upgrading the relocated Goulbourn Forced Road and 2nd Line Road as well as creating an adequate ecological crossing where Kizzell Drain crosses the Goulbourn Forced Road. 

This will satisfy short-term transportation needs of both residents and animal life while a more viable longer-term plan is developed by the City.

Biologist Report

 I checked butternut trees in, and adjacent to, the section now being cleared for the Terry Fox expansion from Morgan’s Grant  to the vicinity of the railroad tracks. Butternut trees in and along the proposed route have been designated by number and fencing.

 I searched the ground around the bases of a number of the trees growing in the forest south of the cleared area, but found no remnants of shells from last year or previous years. They would have been chewed by squirrels but the hard shells take years to disintegrate.  Neither did I find young seedlings.

But at least two very old, large and still living butternut trees (trunks marked by number to designate them) were cut and piled in the section already cleared for the new highway.

Both had many live branches with healthy buds and the largest cut stump had a squirrel midden, larger than several footballs, beside the base  composed of  thousands of chewed butternut shells. 

That was the only tree in the area that I could identify to have been a major producer of  nuts through last year.  It may have been  the largest and oldest in the area, there were signs of decay in the trunk, but the tree was  vigorous and upper branches should have produced fruit for years to come.

This is the result of my sampling of the state of  butternut trees adjacent to, and within, the marked route of the Terry Fox Expansion on March 28, 2010.

Martha Webber  (www.dandelionjam.com)

Photos 

 Photos Taken by Scott Newman:

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Why Engineering Standards For Evironmental Studies Are Needed

Canadian Politics, Legislative Gaps

Ecology Ottawa conducted an analysis of political contributions made by housing developers to Ottawa City Councillors during the last municipal election.

In total, over $121,300 was contributed to winning candidates (the study did not examine contributions to losing candidates).  Top of the list was Gord Hunter who received over 49% of funding for his political campaign from developers.

Not surprising considering that Mr. Hunter is a member of the City’s Planning & Environment Committee.  Other members of the PEC that received substantial contributions are Bob Monet (32%) and Michel Bellemare (25%).

Fortunately the Chair and Vice-Chair of the committee had the integrity to decline such donations.  However, there is nothing other than personal integrity preventing them from doing so.

The municipal planning & environment committee is the only oversight that municipal environmental studies have.  The City of Ottawa has an indepedant Environmetal Advisory Committee, however, their mandate does not include quality assurance of environmental studies.

As far as the provincial Ministry of Environment is concerned, Class Environmental Assessments are conducted on a self-assessment basis.  These are the vast majority of environmental studies and the  province only requires that they be done and that they address prescribed content  - not that they be done properly!

For example the province only requires that proponents of Class Environmental Assessments consider alternatives and document their decision making process – not that they follow any specific decision making process, or even test that they have a sound process for evaluating decisions!  This is the loophole that allowed the City of Ottawa to ignore it’s own planning criteria in evaluating alternatives for the Terry Fox Road Expansion.

Another example is that the province does not provide clear-cut criteria for measuring the impact of a proposed project.  For example, the Terry Fox Road Expansion which threatens 3 endangered species (because it cuts across a Provincially Significant wetland)  is subject to the same process as the Hazeldean Road Expansion which poses no threat to endangered species (because it occurs in a semi-urban area).

So without minimum standards governing engineering practice to be followed when conducting Class EAs, there are no checks and balances in the process – other than the checks written by developers!

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Terry Fox Road Ecological Disaster

South March Highlands

Bogus Environmental Study
It took me 2 months to obtain a copy of the environmental report for the Terry Fox Road extension.    The report states:

the South March Highlands is literally unique within the City of Ottawa.  Both upland and wetlands habitat are Provincially Significant, ecologically placing them on a par with landscapes such as Algonquin Provincial Park, Windsor’s Ojibwa Park Prairie and protected areas along the Niagara Escarpment.”

Yet incredibly, the so-called environmental report is devoid of ecological concern and fails to place any priority on ecological issues.

10 Failures In The Report

1. Ms. Wilkinson, the City Councillor for Kanata, will be surprised by the fact that the environmental studies that she thinks were performed actually have no analysis, consideration, nor plan to protect endangered species.

  • Nowhere in the 300 MB of material is this important topic addressed and it is disturbing that a City Councillor may have been misled on this fact.

2. Although the environmental report recognizes that the area being threatened is ecologically significant at a provincial level, less than 25% of the report addresses the natural environment. 

  • The majority of the report examines human environmental aspects such as bus ridership, noise from traffic, etc.

3. In the ecological section, the report notes the presence of endangered plant and animal species in the area under study and then proceeds to ignore that fact for the balance of the report. 

  • One would expect that endangered species would have received deeper analysis and consideration or at least highlight the need for such a study in its final recommendations – but it did not.

4. Even though ecological impact was clearly established as being the most important criteria for the environmental study, the report selected the alternative that it rated to be the absolute worst for the natural environment! 

  • And, after selecting the ecologically worst routing for the road, the subsequent alignment analysis also failed to select a mitigation option which would minimize impact to the natural environment (given that the environmentally worst route had already been selected). 
  • This occurred in both cases because a flawed paired-comparison methodology failed to establish weights for the criteria used.

5. Incredibly, the memo on 17 April 2000 from the Planning & Development Approvals Commissioner, to the Transportation Committee failed to discuss the obvious concerns that

  • the routing alternative being recommended did not align with the highest priority criteria set by the Transportation Committee, and
  • endangered species were present in the area and that further ecological study was warranted prior to finalizing the recommendation. 

6. The only concern expressed with the recommendation was that it would lead to additional pressure to develop sensitive natural and agricultural areas.

  • The current plan sets up even more ecological problems in future.

7. The traffic volume portion of the main ”environmental study” forecasts over 1000 vehicles an hour during peak periods but does not provide a forecast of animal deaths caused by this volume. 

  • The mitigation strategy that it recommends consists of posting animal crossing signs to alert drivers.  This is outright ecological irresponsibility. 

8. The alignment study provides for a single passageway but does not provide an analysis of how effective that would be considering that slow moving turtles are unlikely to hike down to the passageway just to cross the road. 

9. In fact in no place in the report is the magnitude of ecological impact assessed.

10. The City of Ottawa’s own report shows that current plan for the Terry Fox road extension is the worst possible ecological option both short and long term.  This is a flawed project that must be stopped immediately and sent back to the drawing board.

Call To Action
Construction activity has already started and significant habitat damage is about to occur to the Blanding’s Turtle.  The soil temperature in the spring is crucial for the survival of the turtle population.

 
The truth about this flawed environmental study needs to be brought into the sunlight of public awareness.  With informed public opinion, it will be easier for Council to make the right decision to stop this impending environmental disaster.

Please share these findings as much as possible so that we can stop this thing.

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