Comments from the Region of…

Comments from the Region of Durham’s Roads Task Force on Climate Adaptation Planning on the Draft Guide: Consideration of Climate Change in Environmental Assessment in Ontario

RE: EBR Registry number 012-5806

General Comments on the Purpose of Policy

The proposed guide appears to achieve its purpose of broadening the understanding of proponents and the public about the ministry’s expectations for considering the effects of climate change in environmental assessment. The guide also provides broad approaches to characterize a project’s greenhouse gas impacts and its resilience to a changing climate.

At the Region of Durham, we have taken the initiative at the regional level to understand the effects of changing climate on our infrastructure and vice versa through our climate mitigation and adaptation planning exercise, which is very much in line with the ministry’s intent to take climate change into account in its decision making process. Through this exercise, we now have an understanding of what elements of our infrastructure are vulnerable to changing climate, how we need to mitigate and adapt, and what information we need to achieve that goal.

The guide proposes that EA studies shall compare a business-as-usual scenario with the business-with-climate-consideration as an approach to identify potential mitigation and adaptation measures. We appreciate and agree with that approach. At the same time, having carried out the mitigation and adaptation planning exercise, we realized that we need several new guidelines and design criteria to complete a meaningful evaluation. Some of those guidelines and criteria are either under development or not formalized and time-tested. For example, the Ministry’s recommendation to use new IDF curves that were newly developed (page 35) is non-formalized (meaning not included in the Ministry’s Drainage Manuals). An example where we don’t have sufficient data will be new flood plains for future extreme storms and hence we are not in a position to identify which infrastructure (spatially) is vulnerable and needs climate change consideration.

The next big challenge will be the technical and financial feasibility of carrying forward the EA identified improvements and implementing them. An example of technical feasibility would be implementing a porous pavement to manage storm run-offs and also maintaining the porousity of that pavement after winter salting/sanding. Cities like Ann-Arbor in Michigan have spent substantial amounts in implementing porous pavement only to realize they also have to spend a further substantial amount in vacuuming the roads after salting/sanding in winter and hence financially becoming unsustainable. When municipalities have to shift from business-as-usual to business-with-climate-consideration, they will run into financial challenges and hence would require additional funding to follow through the climate change related commitments identified in the EAs.

Overall the policy sets a right direction, but without equipping the municipalities with formalized approaches, guidelines, criteria, data, technical knowhow and budget, it will be difficult to complete the comparison between the set scenarios and carry through the EA recommendations related to climate change in the design and implementation phase.

Making use of Municipal Initiatives on Climate Change

Page 22 of the guide notes that proponents are encouraged to draw upon their own climate change strategies or policies in carrying out an environmental assessment.

Durham has developed both mitigation and adaptation plans for climate considerations and has come out with recommendations with the intent of eventually mainstreaming climate change considerations into its regular business plan. Most of the recommendations of our adaptation planning exercise call for additional investigation, education and development of guidelines and criteria apart from changes to some of our ongoing operations and maintenance. An example would be our “Adaptive Culverts and Bridges” program, wherein we identified that storm structures are under high risk to future extreme storm events, but we do not have the required standards and criteria such as future design storm that should be used for evaluating and designing structure replacement, future flood plain mapping that will identify storm structures (spatially) at high risk, formalized IDF curves and so on. So, we note, unless the above master plan level information is fully available to us, it will be difficult to solve the climate problem at a project EA level as envisioned in the policy. In our adaptation plans, we have also noted that a number of those initiatives would require leadership at the provincial level as those are primarily developed by provincial agencies. (Please see the consolidated Road Adaptation Program – Appendix A). It is evident that a substantial amount of work has to be done at a higher level, before evaluating at a project level.

Conclusion

The Region of Durham welcomes Ontario’s leadership and initiative in developing this policy to consider climate change. At the same time, we would like to seek guidance and support in the areas we identified in this comment sheet and the appendix to mainstream climate change initiatives in our regular business.

APPENDIX A

Roads

Objective 6.1: Improve the performance of roads under extreme heat conditions.

Program 6.1: Resilient Asphalt Program

Description: Durham municipalities should adopt planning, design, construction and maintenance practices to reduce the absorption of heat and/or increase tolerance to extreme heat in order to prevent softening of asphalt and subsequent deterioration of roads. Such a preventive measure would maintain the expected life of road pavement, thereby avoiding an increased maintenance cost. Major cities like Toronto have identified that the economic consequence of asphalt softening will severely impact the city’s financial health, if not addressed in time.

Asphalt pavement is composed of aggregates and asphalt cement that are designed to perform over a range of temperatures. The asphalt cement binds the aggregates and it softens when subjected to temperatures higher than what it is designed for, making the asphalt more susceptible to rutting and the initiation of cracks.

Measures to address the extreme heat impact to asphalt pavement include the following: using resilient asphalt that can tolerate extreme heat; using alternative pavement surfaces such as concrete at critical locations like intersections and bus bays; using light colored asphalt pavement to reduce heat absorption; increasing urban tree cover to reduce heat impact, etc. Ontario Ministry of Transportation (MTO) has been taking a lead in experimenting with resilient asphalt that is more heat-tolerant. Municipalities can benefit from this research when planning their programs related to road design, asphalt standards, maintenance and replacement.

Sectors:
Public works;
Construction.

Responsible Agencies:
Regional and municipal works departments;
Ministry of Transportation, Provincial Design Standards Branch.

Next Steps:
Monitor ongoing impact of heat on existing pavement;
Identify and prioritize emergency and economic routes that require early attention;
Consider application of resilient pavement on priority routes including transit and truck routes emergency and evacuation routes;
Keep abreast of latest developments in resilient asphalt and modify specifications accordingly.

Objective 6.2: Improve the resilience of road systems to extreme rain storms.

Program 6.2: Road Embankment Program

Description: This program is intended to address the detrimental impact of extreme storm events on road embankments and the subsequent economic and health consequences to Durham’s community at large. Road embankments are often used in conjunction with storm sewers, culverts and bridges to allow water courses, roads, trails, railways and wildlife corridors to pass under the roadway without eroding the infrastructure.

Approaches to address the extreme storm impacts to road embankments include the following:
Upgrading critical infrastructure to withstand extreme storm events;
Using resilient erosion control treatments on shoulders and embankments Improving drainage corridors;
Increased maintenance of embankments and shoulders.

Adaptation actions covered by this program include the following:
Identification and inventory of critical infrastructure segments currently at risk for embankment or shoulder failure during storm events;
Establish a monitoring program to inspect road segments that are susceptible to failures during extreme storm events;
Upgrade of critical infrastructure segments currently at risk for embankment or shoulder failure during storm events;
Schedule and implement routine inspection and maintenance programs for road embankments;
Improve planning and engineering requirements for roads requiring embankments or granular shoulders (e.g.. consider flatter slopes of 4:1; vegetated and reinforced slopes; or reinforced shoulders);
Increase geotechnical requirements for embankments and shoulder designs to reduce failures;
Research and incorporate the use of geo-synthetic reinforcement to reduce embankment failures;
Research and incorporate the use of granular sealing on shoulders susceptible to erosion;
Research and incorporate the installation of engineered drainage systems in areas prone to erosion;
Avoid constructing new roads in areas vulnerable to extreme storm events;
Provide emergency preparedness, response and management training to field staff in case of embankment failures following extreme events;
Provide field staff with training on safely dealing with catastrophic failures of road embankments following extreme storm events;
Implement traffic management plans for areas susceptible to embankment or shoulder failures (e.g.. load restrictions, road closures or alternate routes);
Consider paved shoulders in areas prone to erosion;
Improve storm water management and drainage practices in areas susceptible to embankment or shoulder failures.

Sectors:
Public works;
Conservation authorities

Responsible Agencies:
Regional and municipal works departments;
Conservation authorities;
Ministry of Transportation, Provincial Design Standards Branch.

Next Steps:
Initiate a program to identify and inventory critical segments currently at risk for embankment or shoulder failure during storm events;
Review the existing construction design criteria for embankments to ensure ability to withstand extreme storm events;
Consider pilot projects to test various geo-synthetic materials and other reinforcement products on embankments and shoulders;
Transit and truck routes, and emergency and economic interest routes should be identified and prioritized for early implementation.

Objective 6.3: Protect roads from washout at stream crossings

Program 6.3: Adaptive Culverts and Bridges

Description: Durham municipalities should adopt planning, design, construction and maintenance practices to adapt its culverts and bridges to withstand newly projected extreme and frequent storm events. Such a preventive measure would make our transportation infrastructure more resilient and reduce the need for significant spending on restoration work after such extreme storm events. Recent experiences in Canadian cities like Toronto and Calgary serve as a vivid demonstration of impacts from such extreme storm events and the very high social, business and restoration costs. Culverts and bridges (storm structures) maintain the continuity of water courses (both natural and manmade) under roads, trails and other transportation corridors. They were designed to perform satisfactorily over a range of storm averages and extremes and will fail if they are subjected to above-design storm events, resulting in potential road and embankment washouts This program recommends the following measures be taken to adapt the Region’s culverts and bridges to face future extreme storm events: inventory and assess storm structures to determine vulnerability and to improve their adaptive capacity; modify inspection and maintenance practices to proactively accommodate future storm intensities; implement rehabilitation and capital improvements/replacements where required; initiate research and development to update the design criteria for future storms; train municipal operations and depot staff in emergency preparedness and response measures.

Sectors:
Public works;
Conservation authorities;
Transit and rail authorities.

Responsible Agencies:
Regional and municipal works departments.

Next Steps:
Conduct an inventory of all culverts and bridges to assess their capacity and current condition.

[Original Comment ID: 196170]