Doug Ford and Caroline Mulroney are determined to press ahead with the Bradford Bypass – a controversial scheme which opponents say will cause environmental damage to Lake Simcoe’s delicate eco-system and to prime Grade 1 agricultural lands in Holland Marsh.
“By eliminating duplication and streamlining processes, we are shortening timelines, reducing delays, and focusing the province's resources on projects that matter most to Ontario communities.”
Regulation 697/21 applies only to the Bradford Bypass.
“We have exempted the Bradford Bypass project from duplicative requirements of the Environmental Assessment Act by way of regulation. The regulation sets conditions for the assessment process going forward and for continued environmental protection and consultations. No other Ministry of Transportation projects have been exempted from the Environmental Assessment Act as part of this regulation.”
Since then, the Ford Government has made a commitment to fully fund the Bypass which they say will “relieve gridlock”.
They are also carrying out early construction works in advance of all the necessary environmental studies being completed. On 26 November the Province issued a “Request for Proposals” to build a bridge crossing for the Bradford Bypass.
In its comments on the (then) draft regulation, the Ontario Public Health Association “strongly urged” the Government to reconsider exempting the Bradford Bypass from the requirements of the Environmental Assessment Act.
“The Bradford Bypass project which received individual EA approval in 2002 with conditions, but has not yet been implemented, would no longer have to meet some of those conditions. The conditions included a requirement to prepare a Transportation Environmental Study Report (TESR) and a Design and Construction Report (DCR). The TESR would have outlined: potential environmental impacts, measures to mitigate impacts, and consultation.
It is still not immediately obvious (at least to me) what environmental reports and studies are mandated and the extent to which the public will be consulted – and who decides whether or not to consult. And if that decision can be challenged.
Last week officials from the Ministry of Transportation did their best to square the circle in a presentation to members of York Regional Council. But they fell short, obfuscating as much as they clarified.
How much will the Bypass cost?
Markham Regional Councillor Jack Heath innocently asks how much the project would cost – give or take half a billion dollars. But the officials refuse to give a figure on the grounds that it’s early days and much could change. An exasperated Heath fumes:
“It astonishes me that somebody at the Ministry can't do that (give a rough estimate)… We should have invited someone who could at least give us a general idea what this is going to cost. If the staff can’t do it then the politicians can do it and maybe we should have invited one of them.”
Georgina Mayor, Margaret Quirk, tells us that her Council is “supportive of the project” but they worry about the impact on Lake Simcoe as
“the health of the lake is of great importance to us.”
Her Council wants to involve the Lake Simcoe Region Conservation Authority but doesn't see any need to press the Federal Government to get involved.
“The Federal Government has made it clear in responses last year that they were not going to be doing that. So instead of knocking on that door again…”
Since then, of course, we have had a Federal Election and we have a new Minister of the Environment and Climate Change – but that is all lost on Georgina’s Mayor.
Hard to believe
She tells us about a letter from the Ministry sent to her Council which says
“the Bradford bypass will be located South of Lake Simcoe and will not directly impact Lake Simcoe…”
She says that's really hard to believe.
“It will (impact). We know that. It's not rocket science. But how the Province will mitigate that is what we want to know.”
Now we hear from East Gwillimbury Mayor, Virginia Hackson, who also supports the proposed bypass believing it will
“move traffic off our local roads and on to one provincial road”
But, like Margaret Quirk, she wants to see the Lake Simcoe Region Conservation Authority have a role.
Quirk and Hackson give every impression of being supplicants, begging the Ministry to listen to the conservation authority and others while restating their own support for the bypass.
Taylor demands clarity
Now Newmarket Mayor, John Taylor, steps forward, seeking clarity in all the obfuscations and circumlocutions from the Ministry. Newmarket has already called for a Provincial Environmental Assessment and, if that’s not forthcoming, a Federal Impact Assessment.
But the Province is now moving ahead under a regulation – specific to the Bradford Bypass – which exempts it (the Province) from key requirements of the Environmental Assessment Act 1990.
Taylor wants to know what they don’t have to do now (under regulation 697/21) that they would have had to do before. He wants the Ministry to give him a table showing the differences. And what if changes are made to the project? Will there be consultations on these?
He also wants to know why the Ford Government insisted on a review of the North York Wastewater Treatment plant in East Gwillimbury after an environmental assessment process that lasted six years. And why is the very same Government taking the Bradford Bypass project out of the established EA process and fast-tracking it?
We get a torrent of explanations from the Man from the Ministry leaving us none the wiser.
Like everyone else, I wait to see the table promised by the Ministry. All will then be revealed.
See also report in Newmarket Today on 13 January 2022.
Update on 22 January 2022: From Newmarket Today: Letter to the Editor: Time to put the brakes on Ford Government's dismantling of environmental protections
Click the link below to see transcript of Thursday's presentation and debate.
Update on 10 February 2022: Federal Government will not intervene
Presentation on the Bradford Bypass by the Ministry of Transportation to York Regional Council on Thursday 13 January 2022.
Larry Sarris (MTO): Before we get started with the presentation I just wanted to know whether there are any opening remarks from Jennifer or do you just want me to get right into the presentation?
Jennifer Harkness (Assistant Deputy Minister, Ministry of Transportation): I can I just wanted to thank everyone for letting us join you today. My name is Jennifer Graham Harkness and I'm the assistant deputy minister for transportation infrastructure management within MTO as well as the chief engineer. And I’m just joining today for both the conversation around the Bradford bypass as well as the (Highway) 413.
I wanted to say thank you for being here today as well as to let you know that we do have a number of things happening with respect to the Bradford bypass including an invitation that you'll be receiving shortly related to our first upcoming municipal advisory committee that will be starting in January. And Larry is going to provide an update on all of the things that have been happening with respect to the Bradford bypass. So I don't want to use up too much time. I know your agenda is full so I will turn it over to Larry and the team to make the presentation. So thank you.
Larry Sarris (MTO): Thanks Jennifer. Sonia, do mind sharing the PowerPoint presentation? Can everybody see the first slide of the Bradford bypass PowerPoint presentation?
Regional Chair Wayne Emmerson: Yes.
Larry Sarris (MTO): As Jennifer noted my name is Larry Sarris and I am one of the project managers with the Ministry of Transportation. So today I'll be presenting an update on the status of the Bradford bypass. (Land acknowledgement follows)
Next slide please. So just a quick overview of the purpose of the presentation which is to provide an update on the status of the Bradford bypass preliminary design and project specific assessment of environmental impacts in accordance with Ontario regulation 697/21. So we'll start with a quick project location background. We will discuss the regulation 697/21. Give you an update on the project current status. Discuss early works briefly and just give a quick overview of next steps.
Next slide please. OK so the Ontario Ministry of Transportation (MTO) has retained AECOM Canada to undertake a preliminary design and project specific assessment of environmental impacts according to Ontario regulation 697/21for the proposed Highway 400-404 link known as the Bradford bypass.
MTO previously completed a route planning study for the Bradford bypass in 1997 and a subsequent Environmental Assessment and recommended plan were approved in 2002 to a planning level of detail. As you can see on the map the study area is within Simcoe County specifically within the town of Bradford West Gwillimbury and the Regional Municipality of York, specifically within the Township of King and the Town of East Gwillimbury.
The project team is looking at general alignments within a designated controlled access highway corridor that is defined as the EA (Environmental Assessment) approved right of way that was approved in 2002.
During this preliminary design the Ministry is working to refine the alignment based on design and environmental constraints and considerations. So we're currently in preliminary design and as we proceed through it the design will be refined based on continued discussions with indigenous communities, municipalities, regulatory agencies as well as other stakeholders, feedback from PIC1 (Public Information meeting) that was held in May of 2021 as well as ongoing advisory group meetings and refinements based on ongoing technical work.
Next slide please. So I'll turn it over to Sonis Rankin of AECOM to provide an update on Ontario regulation 697/21.
Sonia Rankin (AECOM): Thank you Larry. So this study is or will be following this streamlined assessment process as set out in Ontario regulations 697/21 issued on October 7th 2021.
The project team will carry forward previous environmental commitments made during the 2002 route planning and environmental assessment study as set out in the regulation, as well as the Simcoe County Road 4 widening environmental assessment study where applicable. Alternatives within the project study area have been generated and are being evaluated based on technical and environmental factors and in consultation with indigenous communities, public stakeholders, municipalities and government agencies.
As part of the project specific assessment of environmental impacts under the regulation the Ministry will prepare and file a draft environmental conditions report - with an acronym a ECR - and a draft environmental impact assessment report – or EIAR.
The ECR is a new document and consultation item compared to the Class EA (Environmental Assessment) process. Both documents will be reviewed and a final report posted on the project’s website in accordance with the regulation.
So this is the current project status. The team is currently assessing and evaluating the preliminary design refinements and alternatives based on feedback from PIC1, field work and additional technical work as part of the preliminary design and assessment of environmental impacts in accordance with the Ontario regulation 697/21.
This is a preliminary design study with a future detailed design phase that will be undertaken to adhere to commitments made during the preliminary design and obtain the required permits and approvals. The study will meet the consultation, transportation and documentation principles including preliminary environmental impact assessment studies, continued consultation with local municipalities, regulatory agencies, indigenous communities and residents and stakeholders.
Project notifications and communications as well as project website, individual and focus meetings and public meetings are all part of the consultation process. We will solicit feedback, provide responses and consider that feedback throughout the design. The team will evaluate and select preliminary design refinements and alternatives for the preliminary design and this is indicated at the star (on graphic) (showing) where we are now.
Then we'll move on to develop the preliminary design for the highway interchanges, structures and other project components. And then there will be the documentation as required under the regulation including the ECR and the EIAR and the preferred refinement locations will be presented as part of PIC2 which is anticipated in the fall of this year.
So the Ministry is advancing early works at County Road 4 and completing the project specific assessment and environmental impacts for early works in accordance with the Ontario regulation. The project team will review and carry forward the previous environmental commitments made during the 2002 route planning study and advance this and build upon the environmental assessment study for the Bradford bypass project and environmental commitments made during the Simcoe County Road 4 widening environmental assessment study.
The process includes the assessment of location specific potential impacts and develop site specific mitigation measures to be carried forward to the further design and construction for these works.
Within the study process for early works, the project team has conducted site specific environmental assessments to document existing conditions, conduct impact assessments based on design-build-ready design and prescribe necessary mitigation measures and/or next steps.
Some of these studies include (indistinct) ecosystem assessments, archaeology assessments, cultural heritage, hydrogeological assessments, waste management and contamination assessment and noise assessments. An early works report has been prepared to document the design and environmental study for this advanced work and it will be available for public review from January 13th to February 12th of this year.
The request for proposals for the early works to advance the design-build-phase has been issued and an award is anticipated for March this year. I'll turn it over to Riaz for our next steps.
Riyaz Sheikh (AECOM): Thank you Sonia. So, in regards to the next steps for the project, the field investigations and data collection has commenced since the beginning of this study and it is ongoing and will continue through 2022 as is required. With respect to the evaluation or preliminary design alternatives that was presented in PIC1 for the Bradford bypass project, it is anticipated in early 2022. There's ongoing consultation and meetings with indigenous communities, municipalities, federal and provincial agencies as well as interested stakeholders as well.
So, for example, over the last few months the project has met with several First Nations within the study area and that includes but not limited to Williams Treaty First Nations here and Wendat First Nations and Scucog First Nations. The project team recently met with the municipalities as well - including Bradford West Gwillimbury staff in November and Town of East Gwillimbury staff in December as well as meetings and ongoing discussions with utility companies and stakeholders as well.
There's also ongoing discussions with adjacent property owners as well. And, in addition, separate advisory group meetings have occured and will continue throughout the study. Municipal advisory group meeting 1 is anticipated early 2022. Federal/Provincial advisory group meeting 1 is also anticipated in early 2022. Environmental community agricultural committee meeting 2 will be anticipated later in 2022. And the project team held the first ECA meeting with invitations sent to over 20 environmental, community and agricultural groups in December 2021.
The project team is in the process of preparing meeting summaries and will provide further information on our project website. We will continue to meet with advisory groups for a second time to reconnect and discuss evaluation and the refinement of the preliminary design that has been selected. And (we will) discuss future commitments and considerations for the project.
The project team will also continue to answer comments received from the public. The early works request for proposals was issued on 26 November of 2021 and the draft early works report will be posted for review shortly. And we will have a period for review. We will continue to issue the draft environmental conditions report in accordance with the regulation. Complete the associated consultation and file the final ECR on the website.
Public Information 2 (PIC2), as I mentioned, is anticipated to happen in Fall 2022 and (we will) present the outcome of the evaluation of alternatives which is currently ongoing.
And then will proceed to issue the draft environmental impact assessment report in accordance with regulations that Sonia and Larry touched upon earlier to complete the issues resolution process.
The final EIAR will be posted to the website. And the preliminary design will be completed to advance the project to the next phase of design. And, with that, we will open it up to questions if time allows.
Regional Chair Emmerson We will take questions and do this one and then will do highway 413 after questions. Councillor Jones. Go ahead, Sir.
(Regional Councillor Jones (Markham) asks question about the orientation of the bypass.)
Regional Councillor Heath (Markham) asks about the location of the bypass and its cost… What is the general estimate of cost?
Larry Sarris, Ministry of Transportation (MTO): With respect to costs… apparently, right now… We’re going through a competitive process with respect to the study itself so we don’t have any costs to share at this time.
Regional Councillor Heath (Markham): So you can’t say that we expect the cost to come in at $2.5 billion give or take a half a billion? You can’t even go that far?
Larry Sarris, Ministry of Transportation (MTO): At the Ministry we are currently undertaking further design and environmental work to refine the engineering and update the study to reflect the changes since the 2000 approval. So construction costs will be updated as these engineering plans are further advanced.
Where we are right now in terms of design… PSC1 showed a number of refinements. They showed freeway to freeway connections. They showed mainline refinements and interchange design refinements so until we have established what those will be, our preferred options, we are not really too familiar with the overall cost right now. There is still a lot of alternatives we’re considering and the preferred alternative will be shown at PSC2 later this fall.
Regional Councillor Heath (Markham): Wouldn’t that apply to things like the Ontario line? You know… the subway through Toronto and maybe the Yonge North? Yet we have a general idea of what the Yonge North subway extension and a general idea of what the Ontario line will be. Now we know that the refinement is the same process. It’s the same Ministry. It astonishes me that you can't say that we know it's going to come between, what I just said, between two and three billion (dollars). I don't know the number it could be $1.5 to $3.5 (billion). It astonishes me that somebody at the Ministry can't do that.
Larry Sarris (MTO): “Yes. Again… I'm not able to share what the costs are right now because there are many refinement areas that we haven't confirmed yet. So, I can take that back…
Regional Councillor Heath: I think that answer is inadequate Mr. Chair. My suggestion is we should have invited someone who could at least give us a general idea what this is going to cost. If the staff can’t do it then the politicians can do it and maybe we should have invited one of them. I appreciate it. Thank you.
Regional Chair Wayne Emmerson: Thank you. Mayor Quirk.
Mayor Margaret Quirk (Georgina): Thank you MTO for coming today to give this update. As some of you from MTO probably realize we did have a letter on our agenda at Georgina council yesterday from the Lake Simcoe Rescue Coalition - and I believe Jennifer (Harkness) is on this meeting. She replied. She provided us with a letter with some great information and good details that we did receive as part of that discussion.
What we did do yesterday was to reaffirm the motion that Georgina council had passed unanimously in August that does state our support for the Bradford bypass. But also asking the Ministry to cover a number of concerns that we have. Because we are on the shorelines of Lake Simcoe the health of the lake is of great importance to us.
So, yesterday, we did ask again for the government of Ontario to commit to involving the Lake Simcoe Region Conservation Authority for voluntary project review as permitted by the Conservation Authorities Act.
The letter on our agenda was requesting that we ask the Federal Government to do their impact assessment. And the Federal Government has made it clear in responses last year that they were not going to be doing that. So instead of knocking on that door again we've requested again that the Province look at doing that voluntary view with MTO.
We also ask that the letter that was sent to our council… we don't know who else received that letter… that answers be provided to the questions that that letter raises. We did ask for MTO to provide that information to us.
I will say we are supportive of the project. As I said we're concerned about Lake Simcoe. It wasn't stated here today but it has been stated at other presentations and it's in this letter… the statement that the Bradford bypass will be located South of Lake Simcoe and will not directly impact Lake Simcoe… that's really hard to believe.
I'll say it that way because even though it doesn't run over the top of Lake Simcoe it's going over tributaries and rivers that flow into Lake Simcoe so making that sort of statement really diminishes in many people's eyes the Province’s look at the impact that this (road) will create. It will. We know that. It's not rocket science. But how the Province will mitigate that is what we want to know.
So any information you can provide to our council on those mitigation efforts is what we're looking for at Georgina. I don't have any direct questions maybe to the presenters I just wanted to make it clear what we had done yesterday at our Council and if there are any comments from any of the MTO staff that are here today I'd be happy to hear them.
Regional Chair Emmerson: I assume they’re gonna be coming to your Council in the near future Mayor Quirk… but anything Larry from MTO?
Larry Sarris (MTO): Yeah. I can start and then maybe I'll pass over to one of the environmental specialists. You're absolutely right Mayor Quirk. The project does fall within the jurisdiction of Lake Simcoe Region Conservation Authority. And we can commit to assessing the impacts under the Lake Simcoe Protection Act and the Lake Simcoe protection plan through things such as water quality and quantity. We have a stormwater management plan that we will be preparing for both the early works as well as for the overall Bradford bypass project.
There will be groundwater management, landscaping and ecological restoration measures as well as fluvio geomorphological designs for water courses, (indistinct) control prevention and other protection measures. But what I can say with respect to consultation on Lake Simcoe… we will still be doing that. And that is a requirement under the regulation 697/21 to submit for review and comments some of these environmental discipline reports.
We would be required to submit these to the local conservation authorities. I believe we touch on the Nottawasaga Valley Conservation Authority as well and we will include the Lake Simcoe requirements as well as other standards and practices to develop an effective and efficient drainage system for the highway while addressing the potential impacts to the lake.
Sonia, I’m not sure if there was anything to add to that. But, like I said, there are stipulations in the regulation to provide Lake Simcoe Region Conservation Authority (with) review periods and (opportunities for) comments on our reports that we will be submitting.
Sonia Rankin (AECOM): In addition to those studies there's also a fisheries impact assessment work being done as well as terrestrial ecosystem studies which will capture the natural areas, the river habitat associated with the rivers that are part of that watershed. And we are consulting with Lake Simcoe Region Conservation Authority. That will be part of our agency committee meeting which is coming up soon with them as well. And Nottawasaga Valley Conservation Authority is also part of the consultation as well.
Mayor Quirk: The bypass does not go through Georgina directly but just to the South of us. But certainly our council and our residents are always very concerned about the health of Lake Simcoe, wanting to ensure that it's protected and that mitigation measures are put forward. So I look forward to the conservation authority being involved. And as you say I'm not sure if that's exactly what we've been asking for - there is a voluntary review process that I think we're still wanting to see… but certainly involving them is in our minds very key because we see them (the conservation authority), as the chair can appreciate, as a key player in this whole process of the bypass and the protection of the lake. So thank you.
Regional Chair Emmerson: Mayor Hackson
Mayor Virginia Hackson (East Gwillimbury): Thank you very much Mr Chair. I just wanted to thank the staff from MTO for the work that they are already doing. Mayor Quirk has spoken a little bit about some of the items that I wanted to speak to as well - particularly about the Lake Simcoe Region Conservation Authority. And I wanted also to thank you for meeting with the staff of East Gwillimbury. They do report back on a regular basis to council but I'm just wondering if there's not an opportunity for you to come forward at the right time to meet with our council and just bring us up to date as well, as indicated.
It (the Bradford Bypass) is going through the middle of East Gwillimbury. We are certainly supportive of having this opportunity to move traffic off our local roads and on to one provincial road. But I just think it would be helpful for perhaps your reporting out as well to the community to meet with our council and we would certainly open it up to the public to ask questions as well there. I just leave that with you and thank you for the work that you're doing so far. We are concerned about the lower landing and we know that you're working on that so we can deal with that at a different time very specific. Thank you very much.
Mayor John Taylor (Newmarket): Could someone from MTO or staff just explain - because it's kind of on the same line as Mayor Hackson and Mayor Quirk - what would be the role of the conservation authority in a full EA (Environmental Assessment) process and what is their role under what you are proposing in this process?
Larry Sarris (MTO): Sonia, do you mind taking the lead on that?
Sonia Rankin (AECOM): Sure. Conservation Authorities are our key stakeholder that we engage through the environmental assessment process. They're involved in the hydrogeological modeling information that we receive. And we work with them with respect to the drainage system as well as we solicit their feedback and information and we consult with them with respect to the natural environment within their jurisdiction. They are not an approval authority on the Ministry projects so don't seek an approval under their regulation but we do consult with them and take their input and feedback very seriously as part of the assessment process.
Mayor Taylor: So am I hearing you saying that basically the conservation authority's role is the same in the EA as it is in this process? Is it the same role?
Sonia Rankin (AECOM): Yes
Mayor Taylor: OK. And I’m wondering if there's a significant change to a major project like this under an EA process what would occur… with a significant change midway? Or just prior to, or after, the EA was completed? What would be the process for a significant change?
Larry Sarris (MTO): Sonia I can take that on if you prefer.
Sonia Rankin (AECOM): I can jump in.
Larry Sarris (MTO): Sure. So, right now we're following the regulation 697/21. And in the actual regulation - we can send you the link to the regulation if you like but I can just give a quick update…
Mayor Taylor: First, I'm asking how would a significant change be handled under the EA process? Because it was under an EA.
Larry Sarris (MTO): Right. Absolutely. If we were doing a typical EA process… if there was a significant change we would prepare, at this level, a transportation environmental study report. Then we would have to do a transportation environmental study report addendum if it was considered to be a significant change by the proponent because the class EA process is a self-regulating process. We will determine if it is a significant change. If it was, we would file a transportation environmental study report addendum. We would notify all of these stakeholders and indigenous communities, public, members of agencies on our project stakeholder list. And we would send a notice of addendum and we would post that for a public review period.
So that would be a Class EA process. Under the regulation 697/21 there's a section called “project changes”. I’m solely relying on memory here so excuse me if I don't have the wording correct. But once we finish this project… so in this case we're filing at the end of the preliminary design… we are filing what's called an EIAR. An environmental impact assessment report. If there are any changes to that EIAR once we filed a report at the end of preliminary design – it’s called a statement of completion. If there are changes, we would determine as a proponent if the changes are insignificant or significant.
If the changes are insignificant then we would still be required to document what those changes are and post that on our public website. If the changes are significant… let's say there is a significant change from preliminary design to detailed design then a similar process would follow. We would issue an addendum to the original environmental impact assessment report. We would notify indigenous communities members of public agencies etc as stipulated on regulation 697/21. We would send out a notice and gauge their feedback and post the addendum and the description in the addendum as to what the changes are. So, basically, it's a description of the change, the reasons for the change, identification of the updated changes (and) assessment of the environmental impacts mitigation and future commitments.
So, essentially, with the regulation there still is a project change criteria that we would have to follow with Ontario regulation 697/21 for anything that is different from the original environmental impact assessment report.
Mayor Taylor: But can either of you or yourself, Ms Harkness, indicate that if there's a significant change (then) different groups and organizations have to be notified? It doesn't express a process involving a commenting period etc
Larry Sarris (MTO): Yes. So it depends on the significance of the change. If the way the Regulation is written… if we determine it is a minor change you still have to document and post it. If it's significant change then that would require notification and it (would) require updates to the EIAR or early works report.
It's kinda in two steps. We just gave a general synopsis. But it goes into much more detail in the actual regulation on project changes.
Mayor Taylor: So my question I guess would be this: I find it impossible to keep up with and understand what would have been occurring under an EA (Environmental Assessment) and what is being proposed under this regulation.
I know you can send me the links on what's under this regulation but is there any chance you could provide us with a table of the two processes – and what’s different… under an EA this would be done and under this regulation this is being done so we can begin to understand what's different?
I simply can't begin to understand the various differences between one process and another.
Larry Sarris (MTO): I think we could do that. I think we can give you a bit of a summary of each - what a Class EA is and what is regulation is. That's fine. I think we can, Sonia, pull something together and give you a bit of a summary if everyone would be interested in that.
Regional Chair: You send it to the Region of York and we’ll get it to Members of Council.
Sonia Rankin (AECOM): I was gonna say that mirrors comments that we have received from the public as well. So we are aware that there is some general understanding of comparison between the Class EA and the regulation. They are very similar in a lot of ways.
Mayor Taylor: Thank you. I'll just make a brief statement, like Mayor Quirk, about where our council is at, in part. Like Mayor Quirk I received a letter also in response to our council’s deliberation and position. And the letter also stated the Bradford bypass will be located South of Lake Simcoe and will not directly impact Lake Simcoe. And that was from you Ms Harkness.
Perhaps you didn't anticipate how that would be received. But when one reads (that) letter that line jumps out very starkly to anybody who's sat on the conservation authority or is on a municipality in the watershed.
I've been I've been taught, literally taught, and I'm happy to learn. But for the last 15 years that development in Newmarket directly affects Lake Simcoe.
And if the highway (which is) far far closer doesn't… then I guess I shouldn't worry so much about low impact development and the impacts of phosphorus loading and other kinds of issues and impacts. So that's a bit concerning because we're relying on the government, MTO and others to have environmental stewardship. And that line makes me feel like there's a different sense of the level of environmental stewardship required or the perception of what is impact or not.
I go on to say that our council (Newmarket) took the position unanimously that there should be a provincial environmental assessment and, in the absence of that, a Federal EA. This has been going on for some time. I'm holding in front of me here an environmental assessment board report in 1975 about a similar route - slightly different than this one. Imagine, this was before the 404 so it wasn't a link between the two highways but it was certainly a corridor addressing some similar issues. This has been going on so long I can't imagine another year or two for an EA couldn’t be done.
And also find it very confusing that the same government believes that a six-year Environmental Assessment completed on upper York isn't sufficient for a water reclamation plant but needs an expert panel to review it. But a highway – Bradford bypass highway - going through sensitive areas doesn't require a full EA or an updated EA.
It's interesting that in 1975 - when I think we can all agree environmental standards were significantly less - the Board wrote in their opinion and they didn't fully approve it… and that's the value of a full Environmental Assessment… They wrote that in the opinion of the Board the absence of such studies represents a serious deficiency. During its deliberations the Board found there was lacking sufficient information as to the impact on the natural features of the marsh, whether or not alternatives existed with less environmental impact, and whether or not the identified impacts could be satisfactorily mitigated.
That's in 1975. And those concerns were front and centre and resulted in a qualified EA approval. And so I think that something this significant… that the public trust in the process… our council (Newmarket) unanimously feels that a full Provincial or Federally Environmental Assessment is required and is the proper way to go moving forward.
I hope that somewhere some of that is still being considered. Thank you.
CHECK AGAINST DELIVERY (The video is here)