July 31, 2008
Ministry of the Environment
135 St. Clair Ae W 12th floor
Toronto ON M4V 1P5
Re: Request for individual environmental assessment under the part II order for the Frid St. extension municipal class EA
I am writing on behalf of “Transportation for Liveable Communities” (TLC), a working group of McMaster’s chapter of OPIRG (Ontario Public Interest Research Group) to request a part II order for the Frid Street extension municipal class EA.
TLC members have thoroughly examined the environmental study report and concluded that the process leading to the report and the report itself are not in compliance with sections 2 and 13.1 of the Environmental Assessment ACT. Below are our specific concerns:
Betterment of the people by providing for the protection, conservation and wise management in Ontario of the environment.
The Frid St extension class EA was supposed to follow the five transportation guiding principles for the Kirkendall neighbourhood traffic management study, which are:
1. To ensure the transportation network and other required infrastructure will be sufficient.
2. Integrated urban transportation systems which promote non-auto travel modes, and pedestrian and vehicular circulation.
3. Greenspace, pedestrian and cycling links connecting the site to larger open space networks.
4. To provide a vibrant, healthy, sustainable future as per VISION 2020.
5. To develop an integrated sustainable transportation system for people, goods and services which is environmentally friendly, affordable, efficient, convenient, safe and accessible.
Unfortunately, the drawings presented in the report do not meet any of these principles as there is an extensive focus on providing over capacity for vehicular traffic (rather than “sufficient”), little provision for cycling infrastructure, which is not well integrated with its soroundings, and no consideration of pedestrian needs.
Whereas our request during the consultation to add bike lanes have been accommodated, the majority of our requests have not received thorough consideration. Our other requests were:
1. We object to the centre-turn lane and protest the implication that it is provided for safety. The only research we are aware of (FHWA Publication No: FHWA-HRT-08-046) clearly indicates no increased vehicular safety for urban centre-turn lanes. Hence neither vehicular safety nor the intended low volume of traffic on the road justify a centre-turn lane. The vacant space can readily be occupied by the necessary wider sidewalk and a median landscaped with plants.
We should note that the report acknowledges that a centre turn lane may not be required (p. 66), indicating that a plan based on the guiding principles above could readily lead to development in the area that relies on the intended low volume of automobile traffic.
2. To create a pedestrian friendly route, a minimum of 3 m sidewalks along the whole street is necessary. Furthermore, whereas earlier plans included 3 m sidewalks in the section closest to Longwood St., the only explicit plans in the final report include 1.5 m sidewalks. These starkly disregard the principles above.
3. The response to TLC request for curb extensions at any pedestrian crossings has been a vague mentioning of “appropriate pedestrian features”. We find this unsatisfactory and request explicit accommodation of curb extensions in the drawings according to the neighbourhood guiding principle of creating a pedestrian friendly street.
4. The drawings in the report depict wide turning lanes at the intersections of Frid and Chatham, Frid and Longwood, and Frid and MIP. Such turning lanes promote speeding by turning vehicles and widen the curb-to-curb distance pedestrian must travel. Our request to provide for tight curb radii (i.e. narrow crossing for pedestrians) has not been properly addressed.
Obligation to consult
While the city complied with the mandatory requirement to consult with the public by providing an opportunity to comment, staff ignored requests from the two dominant local organizations, Environmental Hamilton and Transportation for Liveable Communities, to revise the plans in accordance with the city’s own environmentally friendly principles detailed above. Moreover, even at this stage of the process, city staff is willing to meet with us only to review our comments “and explain how they have been addressed in the completed Environmental Study Report” (quoted from a June 15, 2008 e-mail by L. Skrypniak). That is, throughout the process, city staff has not been willing to consult with us in order to mediate an environmentally friendly compromise in accordance with the city’s own guidelines.
In sum, we request a part II order mostly because our attempts to make the plans for Frid St extension environmentally friendly through communication with city staff have not succeeded.
For Transportation for Liveable Communities
CC. Councilor Brian McHattie
Ms. Larissa Skrypniak