December 21, 2017CFN 58639 …

December 21, 2017CFN 58639 (EBR 013-1515)

BY E-MAIL ONLY contact@GGHTransport2051.ca

Katerina Minaeva
Senior Policy Analyst
Ministry of Transportation
Policy and Planning Division
Transportation Planning Branch
Environmental Policy Office (Toronto)
777 Bay Street, Suite 700
Toronto, ON M7A 2J8

Dear Ms. Minaeva:

Re: Greater Golden Horseshoe Transportation Plan Draft Goals and Objectives

Thank you for the opportunity to review and provide comments on the Ministry of Transportation (MTO)’s Draft Goals and Objectives for the Greater Golden Horseshoe Transportation Plan. We understand that the goals and objectives, once finalized, will inform the development of a plan for the region that will provide planning direction for a range of transportation modes and inform transportation policy and investment decisions to address climate change, support economic development, and promote new technology.

Through the application of The Living City Policies, the Toronto and Region Conservation Authority (TRCA) promotes natural heritage conservation and landscape connectivity throughout our jurisdiction. TRCA takes a watershed-based approach to our review of transportation infrastructure projects within Regulated Areas through a number of avenues, including service level agreements and Voluntary Project Review for projects at the Environmental Assessment stage through to and including detailed design. TRCA works with transportation agencies, municipalities and developers in the planning, siting and alignment of public infrastructure, recognizing the critical role of protecting people, property and infrastructure from natural hazards and avoiding or mitigating impacts to the natural heritage system in our watersheds. In this way, TRCA and its public and private partners take a collaborative and inter-disciplinary approach to ensuring a sustainable interface between transportation systems and the natural system that strives for resilience to climate change. Also integral to this work is TRCA’s nature-based recreation network of parks and trails on TRCA-owned or managed lands that provides opportunities for active transportation, forming an important part of the regional transportation network.

Overall, TRCA supports the draft goals and objectives of the Greater Golden Horseshoe Transportation Plan and we offer the following comments for your consideration:

Environmentally Sustainable 1.We recommend revising the second bullet to read, “The preservation of natural heritage systems and biodiversity, including valuable resources, natural areas, wildlife and wildlife passage is prioritized in planning and use of the transportation system.” Roads and other

transportation infrastructure can have direct impacts on wildlife habitat, but can also act as a barrier to safe passage between habitats. The importance of facilitating wildlife passage in the planning of transportation systems should be more explicitly stated and should recognize that it is the natural system as a whole that is of importance, including areas of local and regional importance and not just those of provincial significance.

2.While facilities should generally be located outside of the natural system, new and upgraded transportation systems often cannot avoid impacts to natural heritage, including wildlife corridors and overall landscape connectivity. TRCA agrees that the preservation of "valuable resources" and "natural areas" should be examined first. However, given the common necessity of locating transportation infrastructure within or crossing the natural system, please consider including an additional objective that speaks to ecosystem compensation that achieves, at minimum, no net loss of natural areas, and where possible, strives for a net gain. This would also contribute to achieving other objectives such as air quality, healthy living and managing risks to climate change. TRCA is currently working with Metrolinx to develop a compensation protocol, and would be glad to work with MTO in this regard should there be a consideration for this type of initiative.

Resilient 3.It is unclear what is meant by "changing engineering standards" in the first bullet. Perhaps this can be revised to read, "The transportation system is designed and constructed to manage the risks associated with climate change (e.g., avoiding natural features and hazards, but where crossings must be located in these areas, that they be appropriately sized to convey appropriate storm events, such as conservation authority regulatory storm events, and allow for natural channel movement and water balance). These objectives are important in order to protect people and infrastructure from natural hazards like flooding and erosion, and to preserve the form and long term function of these features. Components of the natural system like wetlands, woodlands, valleys and watercourses all contribute to resiliency and climate regulation by filtering air and water pollutants, mitigating for urban heat island effects, and slowing storm and flood waters, while also providing habitat that helps maintain biodiversity.

Integrated 4.In order to achieve the goal of an “integrated” transportation system and many, if not all of the other draft goals, active transportation facilities must be an integral part of the planning of new communities. Please consider adding an additional objective such as: Pedestrian and cycling facilities are integrated into the planning and construction of new and redeveloped communities, ingraining active transportation as a safe and accessible option. This should include ensuring active transportation connections are incorporated beneath highway systems through appropriately sizing bridges and culverts, and ensuring there are connections to commuter parking and transit hub areas. This would also complement and support active transportation policies in the Growth Plan for the Greater Golden Horseshoe.

Connected 5.In the third bullet, it would be helpful to clarify what is meant by “high level of transit service”. If this connotes fast and reliable service, perhaps this could be more explicitly stated. The clearer the objective, the easier it would be to measure to what extent the objective is achieved.

We would also like to provide suggestions for the Executive Summaries of the Environmental and Socio-Economic Profiles published as part of this consultation, as follows. We agree with all of the “Future Outlooks” as key considerations for the final GGH Transportation Plan, however:

Environmental Profile Executive Summary: 6.Future Outlook #2 - Cumulative effects on natural systems, but also on biodiversity and wildlife movement, are important considerations in planning and development of transportation infrastructure (please see comment 1).

7.Future Outlook #3 - While we agree that there is a robust framework for environmental protection, much of it is found within the Provincial Policy Statement and the Provincial Plans that are implemented through municipal official plan policies. In their role as public infrastructure providers, many municipal projects fall under the environmental assessment process, which is outside the scope/applicability of the PPS and Provincial Plans (see definitions of “development” in the PPS and the Plans). Furthermore, the province, as a Crown agency, is exempt from review under the PPS and the regulatory provisions of the Conservation Authorities Act. With respect to TRCA’s section 28 regulation under the Act, Metrolinx has made a commitment for voluntary project review at the detailed design stage. TRCA staff would be pleased to work with MTO in securing the same type of agreement.

8.Future Outlook #4 relates to other important factors in planning and constructing more resilient infrastructure, such as strategic stormwater management that includes a treatment train approach meeting watershed criteria (like long term erosion control and water quality treatment for both existing and new sections of roads and highways in the case of widenings and expansions). These are important considerations for managing natural hazards and improving water quality for fish habitat. Staff are concerned that “changing engineering standards” could mean adding more “hard” engineering surfaces (such as erosion protection), rather than addressing potential impacts through a more naturalized approach to mitigation and remediation based on local erosion rates, natural channel design, and/or meander belt width delineation.

9.Future Outlook #6 - Transit, active transportation modes, designated carpool lots to provide connection hubs, and support for and prioritization of electric vehicles, alternative and renewable fuels, will all be key to improving community health and reducing GHG emissions from the transportation sector.

10.Overall, increasing resilience to climate change can be linked back to protecting and enhancing the natural system that helps offset GHGs and provides green infrastructure that contributes to mitigation of flooding and erosion. The 6 Future Outlooks commonly reference impacts to natural systems, however, they do not tie back to the protection of those systems through the avoidance and mitgation of impacts; nor do they speak to the need to provide compensation for any unavoidable losses. We suggest that these links be made when developing the final transportation plan.

Socio-Economic Profile Executive Summary: 11.As referenced in Future Outlook #1, growth, intensification and development will increasingly be directed to existing built up areas and designated Urban Growth Centres, major transit station areas, corridors and designated greenfields within the region. During consultation on the coordinated Provincial Plan Review, TRCA commented that a number of major growth areas are located within flood vulnerable areas where there are opportunities for comprehensive remediation through urban revitalization projects – both private development and public infrastructure projects. These areas also represent an opportunity for closer coordination among the land use planning and infrastructure planning processes as promoted within the draft goals and objectives and provincial policy and plans. This is also aligned with TRCA’s Living City Policies document that promotes this coordination but also encourages restoration and remediation of natural heritage and natural hazards where redevelopment and intensification are taking place. TRCA’s programs in ecological restoration and flood forecasting, warning, emergency preparedness and risk assessment within flood vulnerable areas, are available to inform MTO in these areas where appropriate for the final plan.

Again, we appreciate the opportunity to provide comments on the draft goals and objectives for the Greater Golden Horseshoe Transportation Plan, and look forward to continuing to provide input in the future phases of this initiative. Should you have any questions, or would like to discuss any of the above, please contact me at extension 5217 or at bwilliston@trca.on.ca.

Yours truly,

W. Beth Williston, MCIP, RPP Associate Director, Environmental Assessment Planning Planning and Development

Cc: Carolyn Woodland, Senior Director, Planning, Greenspace and Communications

[Original Comment ID: 211612]