Stephen Rees's blog

Thoughts about the relationships between transport and the urban area it serves

Proponent’s response to public comments PM2/Hwy1 EA Application

with 2 comments

With no fanfare at all, and the provincial EA about to close on March 31, the Ministry of Transportation (the proponent) has produced its response to the comments made to their EA Application.

It was posted to the EA web page on December 13, but no notification was sent to those who provided comments. It is a table 152 pages long, and each comment is organised by the chapter headings to which comments were addressed. The download is 715kB.

The Ministry’s response can be readily summarised. Essentially what it says is that we looked at each comment and then paraphrased the section of our original document into the response section. None of the issues raised is therefore dealt with in any meaningful way.

The responses to official agencies – those who have seats at the working party tables such as federal ministries or local municipalities – are dealt with somewhat differently. In those cases individual agencies get letters – and the correspondence is, by now, voluminous. But the outcome does not seem to be very different. It may be that the EA under federal requirements could be different – because that is unaffected by the March 31 deadline. And so far, important issues raised by federal agencies remain to be addressed, let alone resolved.

If you sent in a comment, you might want to trawl through the table to see if you can see your name, or that of your organisation. But you will not learn anything new. Induced traffic, for example, is simply dismissed:

Traffic induced by growth in excess of that predicted by regional
and municipal landuse plans and its effects are beyond the scope
of this assessment as set out in the Application Terms of
Reference (ATOR), which identify the issues to be addressed and
the information to be provided by MOT in its Application.
source: Chapter 8 – Local Air Quality and Human Health Impact Assessment

So the traffic induced by increasing road space is not even acknowledged, and the land use effect is the responsibility of the municipalities.

Just to be quite clear about this, every major road expansion in a congested urban area has always produced an increase in vehicle kilometres travelled – and this occurs even when there is no change in land use. Equally, when the capacity of a road network is reduced – for example by a road closure or a bridge collapse – the volume of traffic (again measured as VKT) declines. And again this is not anything to do with land use. Both of these phenomena are well documented, and have been part of the transportation planners lexicon since the 1960s. These effects are not included in the GVRD regional transportation model used for this EA Application – because the total number of trips in both cases is assumed to be exactly the same. This is not due to some shortcoming in the software, or the lack of skill in its operation. It is a function of the way the model is constructed. It ignores induced traffic just as it ignores land use changes that result from major transportation investments. Neither of these assumptions is realistic.

And of course there was no examination of any realistic alternative: the only comparator used was the “do nothing scenario” supplemented later by a few extra model runs that included imaginary bus routes that no one experienced in transit modelling would expect to attract ridership – but not a simple direct rapid bus connecting Surrey and Coquitlam Town Centres. One route examined ran from Maple Ridge WCE station over the Golden Ears, along Highway 1 and then up to the Coquitlam WCE station. This route had never appeared in any Translink plan.

I really wonder why we waste so much time and effort on such a pointless exercise. Like nearly every other major provincial project, no real hard questions were asked or answered before it was decided to proceed. This is an old idea, dredged from the back of one the MoTs plan chests were it has resided for many years. The BC MoT has never been interested in transportation. It builds highways. Period. No serious consideration was given to any other method of dealing with the transportation issues of this region by the MoT or its consultants. “Out of scope” answers everything in their minds.

They indulge us with a “public consultation” process, but never intended to listen and would not dream of changing anything is response to what they heard from the public. The fight with the municipalities is similar – and anyway places like Vancouver have just rolled over. Only Burnaby has raised any serious objections. And again they might just as well have saved themselves a lot of work for all the good it has done. So the crunch question is, will the federal government do anything effective?

In advanced western civilised democracies citizens are treated with respect by their governments. That is not the case in BC.

The Premier of British Columbia wants us to believe that he cares about the environment and climate change. The decision this week on the Upper Pitt – after one public meeting – is very encouraging. But what sign is there that any of the equally well argued objections count for anything when it comes to Highways?

Written by Stephen Rees

March 27, 2008 at 11:19 am

Posted in Gateway

2 Responses

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  1. One has to wonder if the steady rise in fuel prices has even entered the brains of anybody working for the MoT. How could they even assume a “business as usual” approach when business as usual isn’t even the case anymore?


    March 27, 2008 at 12:47 pm

  2. […] of Transportation has responded to all those comments on the Environmental Assessment of the Port Mann twinning Higwhay #1 expansion. They did that in December, but kept quiet about it. No doubt because they had actually not […]

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