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iThe Panel is aware that the GTAW EA included expectations of shifts in modal split and reductions of vehicle travel in Group #1: Optimize existing networks and Group #2: New/expanded non-road infrastructure alternatives. However, these expectations were based on unsupported assumptions that impacted the assessment of all alternatives. The Panel did not include these assumptions in its modeling.

iiNote that this total reflects the actions referenced in the text of the ATSA report; however, Table B-2 which evaluates each of the actions evaluates 62 transit actions, not 63, and thus evaluates a total of 296 actions, not 297.

iii Stage 1 of the Greater Toronto Area West Environmental Assessment recommended a suite of actions, including travel demand management, transportation system management, transit improvements, highway expansions and extensions, and a new highway corridor. The EA also considered a new transitway, and truck-only lanes are considered for the new highway but are not immediately recommended in the GTAW EA.

iv Full EAs examine two types of alternatives. First, “alternatives to the undertaking” are functionally different ways of addressing the identified problems and opportunities. The undertaking is not identified until the end of this process. Second are “alternative methods of carrying out the undertaking,” such as specific design and location alternatives. In Stage 1, the GTAW EA identifies individual alternatives, then creates four Group Alternatives, and then further identifies eight location-specific alternatives within Groups #3 and #4. For clarity in this report, the Panel has adopted the following terminology: individual alternatives are “actions,” group alternatives are “Groups,” and location-specific alternatives are “alternatives,” generally with numbering attached (ie. 3-1, 3-2, 3-3, etc.).

v The four per cent figure was originally provided in the Area Transportation System Alternatives (2011) report (p.8, A-6). The Transportation Development Strategy (TDS; 2012) supported this conclusion and elaborated that, of the four per cent reduction, 2.5 per cent was a shift from auto driver to transit, one per cent was a shift from auto driver to carpooling, and 0.5 per cent was a trip no longer taken during peak periods, or not taken at all (p.79).

vi The preferred option is similar but not identical to Alternative 4-2 as originally described in the TDS.

viiThe 2012 TDS indicated that design and construction of the new corridor would begin no earlier than 15 years from its publication, page 174.

viii The new corridor depended on the recommendations of the GTAW EA, but several highway expansions and extensions proposed as part of the GTAW Recommended Actions are permitted by other EAs or Class EAs. Some are already under construction. Independent actions should be considered as part of the base case scenario against which the value of proposed actions is compared. Therefore, this scenario is designed to estimate the unique benefits delivered by the new GTAW corridor (the +-48 kilometre new highway), independent of other actions permitted by other EAs or Class EAs.

ix Insofar that the slower growth forecast is more closely based on observed data, it may be more likely (at least at the municipal rather than neighborhood levels) than the Growth Plan (2006, amended 2013) forecasts.

x Based on the Ministry of Municipal Affairs and Housing (2014) document, Performance Indicators for the Growth Plan for the Greater Golden Horseshoe 2006, the province has recommended that several transportation performance objectives be integrated into provincial policy. These include street connectivity (a network design indicator), transportation modal split, trip distance by mode and greenhouse gas emissions. Generally, one might expect complete communities to enable more local engagement in activities and consequently more local travel (and shorter vehicle trip distances). Thus, transportation system changes that induce longer passenger vehicle trips could be interpreted as being at odds with provincial objectives to advance complete communities.

xi The Panel was unable to find detailed cost estimates for any of the alternative scenarios in the GTAW EA. Therefore, even though Alternative 3-1 was rejected on the basis of cost and constructability, it is unclear precisely what the magnitude of difference is.

xii This policy direction is also found in the Greenbelt Plan 2005 as a condition governing “the location and construction of infrastructure and expansions, extensions, operations and maintenance of infrastructure in the Protected Countryside” (Policy 4.2.1.2).

xiiiThe Panel notes that the Greenbelt Plan (2005) also references urban growth centres in a policy dealing with infrastructure that is located in the Greenbelt.

xiv As described in Chapter 4, the Panel’s own modeling results did not find sufficient travel demand between the urban growth centres in the study area to justify linking them by transit.

xvThe Panel is aware that this policy in the Growth Plan needs to be related to policies in the Greenbelt Plan and that there is provincial direction on resolving conflicts in provincial policies (see above).

xviIn 2015, the Ministry of Municipal Affairs and Housing released Performance Indicators for the Growth Plan for the Greater Golden Horseshoe. These indicators include three that are transportation-related. They are: modal split, trip distance by mode, and transportation greenhouse gas emissions.

xviiThe Panel notes that, although the application of this policy is limited to infrastructure located in the Greenbelt, this aspect of Greenbelt Plan policy appears to be aligned with the stated purpose of the EA regarding urban growth centres.

xviiiSee the August 1990 MOE Publication, “Evaluation Methods in Environmental Assessment”, p.14.

xixThese eight alternatives consisted of the “Do Nothing” alternative, TDM, TSM, improved air transport, improved goods movement by rail, improved passenger service by rail, improved transit services, and improved or new roadways/ transitways.

xxSee, for example, Actions 163, 171, 179, and 194

xxiAccording to the Growth Plan, pricing (road tolling or transit discounts) is listed as a travel demand management tool. Section 1.6.7 of the PPS (2014) includes cost as a transportation demand management strategy.

xxii See policy 1.6.2 of the Provincial Policy Statement, 2005 as well as policy 3.2.2.3 and the Guiding Principles (1.2.2) of the Growth Plan, (2006)

xxiii See, for example, Actions 163 and 194 for the first conclusion and Action 171 for the second conclusion.

xxiv For example, in the waste sector, there is advantage to grouping waste management alternatives into waste management systems because, by themselves, none of the individual alternatives that address the three Rs of “reduce, reuse, and recycle” can address all waste; however, when combined with a waste disposal alternative, the 3R alternatives can better the overall impact of waste management facilities on the environment as compared to sending all waste to a new waste disposal site.

xxv A major concern with the EA use of this additive approach arises when it is combined with a focus on benefits in a growing region. Quite simply, adding the benefits of any group of actions to the benefits of any other group of actions would very mechanically lead to an expectation of more benefits. By this approach, the most comprehensive list of actions assessed would automatically be expected to deliver the most benefits.

xxvi The four per cent figure was originally provided in the Alternatives Report (pp.8, A-6). The TDS supported this conclusion and elaborated that, of the four per cent reduction, 2.5 per cent was a shift from auto driver to transit, one per cent was a shift from auto driver to carpooling, and 0.5 per cent was a trip no longer taken during peak periods, or at all (p.79). The 10 per cent figure is also from the TDS (p.79).

xxviiTDS, page 33.

xxviii The Panel notes that despite the general claim in the EA that each new alternative group includes the previous alternatives, the Group #4 alternatives do not contain all the alternatives described in Group #3. In particular, none of the Group #4 alternatives includes expansions to Hwy 407 that the Panel believes would exceed the limit set in the Hwy 407 legislation. This departure from the GTAW EA’s general claim about the group alternatives means that the Group #4 alternatives are not affected by the Group #3 Hwy 407 problem.

xxixTDS, pg. 33.

xxxOntario tribunals have long viewed need as an implied component of every environmental assessment: see, for example, Re Steetley Quarry Products (Joint Board, March 17, 1995), 16 C.E.L.R. (N.S.) 161 at 188-9. This implied requirement comes from several express requirements of the EAA, including requirements to describe the purpose of the undertaking, state the rationale for the undertaking, and describe and evaluate alternatives to the undertaking.

xxxiThere appears to be an inconsistency between the rationale of “unlocking” land for development (see TDS page 69), while simultaneously assuming in travel demand forecasting that population and growth forecasts in the GTAW study area are equivalent with or without the GTAW Recommended Actions.

xxxiiIn fact, in subjecting an alternatives assessment strictly to a comparison of benefits exclusive of fiscal constraints (benefits relative to finite costs) or outcome constraints (what performance objectives are most desirable?), the additive approach used here would always lead to a recommendation for a new corridor.

xxxiiiAlthough these highway extensions and expansions should either have formed part of the base case scenario or been an alternative unto themselves, they were included as part of the suite of GTAW Recommended Actions.

xxxivIn addition, the Panel has identified other issues with the terms of reference regarding its time frame (i.e., 2031) and its approach to conflict between policies (i.e., most recent policy prevails). This latter issue is at odds with guidance in the PPS, Growth Plan and Places to Grow Act, 2005 related to conflicts.

xxxv Planned corridors are defined in the Growth Plan (2017): “Corridors or future corridors which are required to meet projected needs, and are identified through this Plan, preferred alignment(s) determined through the Environmental Assessment Act process, or identified through planning studies where the Ministry of Transportation, Ministry of Energy, Metrolinx, or Independent Electricity System Operator (IESO) or any successor to those Ministries or entities, is actively pursuing the identification of a corridor.”

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