Staff Report to Council: Not Good Enough

This is the letter we sent to Mayor and Council yesterday. The report will be either accepted, rejected, or deferred at Tuesday evening’s council meeting.

Re: Wellington Street Extension Report #15-208

We are writing to urge you to reject this report for the following reasons:

1) The first recommendation is not in keeping with Council’s motion of March 3. Council advised staff to prepare a report for May to define the scope of exploring alternative transportation solutions for the Inner Harbour in place of the WSE. Council asked for the opposite of a new EA for the WSE.

2) The report contains a number of omissions, questionable assumptions, incorrect facts, biased and misleading statements and exhibits. It does not constitute the “comprehensive report… that provides factual information of all aspects directly or indirectly related” or “provide full transparency” stipulated by the March 3 council motion. It does not acknowledge any of the critiques of or alternatives to the EA proposed publicly over the past few months.

Below is a summary of some of the most serious problems with the report.

Throughout, the report fails to present evidence for its defense of the WSE. The WSE is presented as “critical infrastructure” (263) and the only way to provide a “functional transportation network” to enable densification (269). These claims are unfounded, as alternatives are not explored. Many of the report’s claims about the necessity of the WSE are purely speculative. For example, it states that “further remediation and re-development of… sites… such as the Davis Tannery Lands… will in part be dependent upon improving access and capacity…. without the significant improvement to the existing road network, the re-development potential of the Inner Harbour area could be significantly constrained” (10). The report implies that removal of the WSE would lack “land use planning rationale” (11), without actually saying how or why. It says that revised models for the TMP “re-confirm the needs justification for the WSE” (13) when alternatives have not been considered. The report does not contain a justification for the northern section of the WSE, other than vague claims that it “is required to permit access and service some of the lands” (19). There are many other examples of this sort.

The list of key bullet points on p. 264 is only focused on negative impacts and contains unsubstantianted presumptions. For example, claims are made that:

o   not building the WSE would “reduce the city’s ability to effectively revitalize the Inner Harbour area.” In the absence of further study, this is not known.

o   development of the K&P Trail is contingent on the WSE being built. This is a choice, not a fact.

o   improvements of Fluhrer Park are contingent on the WSE being built. This is a choice, not a fact.

The report claims that the Fluhrer Park revisioning exercise “demonstrated that the park use, the cycling active transportation and the WSE can co-exist” (263)  and celebrates “significant public involvement and input” (269) when in fact persistent opposition to the WSE was a defining element of the public meetings.

More generally, the report celebrates ample public consultation in a number of contexts without acknowledging that the public has repeatedly been blocked from discussing the WSE in consultations. For example, the agendas and terms of the Fluhrer Park consultations were insistently resisted by members of the public who did not wish to discuss park revitalization with the WSE in the picture. More recently, at a Waterfront Master Plan meeting, the public also repeatedly raised opposition to the WSE. Similar things happened at Transportation Master Plan public meetings. The city has been actively and consistently blocking public opposition to the WSE.

Repeatedly, the report ties alternatives to or challenges to the WSE to the WSE, so as to create a general but non-logical sense that the WSE cannot be escaped. This is an unprofessional sleight-of-hand. For example, the report claims that “Public Policy has identified a new north-south arterial road as necessary to significantly improve pedestrian…access to the downtown core” (267). Seriously? It claims that “smart growth… will result in the creation of a higher volume of automobile… traffic within the downtown” (272), which depends entirely on how you define or imagine “smart growth.” The report states that “without the tools to encourage private investment… the City will be under considerable pressure to expand the urban boundary to accommodate growth in the next 20 years” (273), but it does not consider any tools other than the WSE.

The report attributes material to the EA that we cannot find there. It claims that “the EA addressed … why a setback less than 30 metres is appropriate” (269). In our extensive reading and rereading of the EA, we do not find a justification for the overriding of the required “ribbon of life” setback from waterfront. It also describes rationales for the EA’s dismissal of the one-way street solution (276) that we never found.

Despite its insistence that the “PPS policies should not be separated and read in isolation of one another” (269) and that “the overall purpose and intent of [the Official Plan]” must be considered rather than individual policies within it (270), the report does not manifest objectivity, and is biased against green and sustainable perspectives. It contends for example that “transportation corridors require significant long term planning… to protect the future uses and once gone would be disruptive to property owners and extremely expensive to replace.” The same ought to be said for waterfront, parkland, and habitat, but the only descriptor used to describe the affected space is “transportation corridor” and that is the only risk that concerns the authors of the report. The report speaks vaguely of “expensive local road improvements” (273) without acknowledging the far greater expense of the WSE. And so on.

We look forward to a report in May, based on current planning practice and an imaginative approach to the future of our beautiful city, that will define work to be done by consultants to reassess need and, if need is confirmed, develop alternatives to the WSE. Only if the alternatives are prohibitively expensive or clearly inadequate will an expensive new EA have to be done at all.

Sincerely, Laura Murray, Anne Lougheed, Mary Farrar, and Sayyida Jaffer
for WellingtonX

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