Point one: Population Projections as an Underlying Assumption
In “Report A: Study Plan Technical Work, Outreach and Consultation, June 2008” the Introduction to the Highway 7 & 8 Transportation Corridor Planning and Class EA Study, page 1, sites several areas to be addressed. We assume these were outlined in the Request for Proposal developed by the Ministry of Transportation (MTO) and responded to by TSH and others bidding for this work.
We appreciate that consulting teams need to be provided with guidelines to undertake projects of this significance and that legislative and regulatory processes are required to avoid random approaches. We, like the MTO, want the best decisions to be made for the particular study area and not decisions based on a cookie cutter approach that could see the geographic names of the communities interchanged.
In the case of the Transportation Corridor Planning and Class Environmental Assessment (EA) study carried out in Perth County, we believe the (MTO), acting as an agent of the Province, negligent in not placing the Ontario Ministry of Agriculture, Food and Rural Affairs (OMAFRA) Guidelines and the Provincial Policy statements relating to the importance and protection of agriculture, as a prerogative of the consulting team. This has more relevance than the population projections of the Greater Golden Horseshoe (GGH).
Item five states: “Address the transportation policies and directions of the “Growth Plan for Greater Golden Horseshoe” (recognizing that a portion of the analysis area for this project lies within the GGH”).
A portion of Wilmot Township falls within the boundaries of the GGH and discussions with the staff at the Region of Waterloo indicate that the Region is questioning the validity of the population projections for the Waterloo Region AND they point out that even if the population of Wilmot doubled within the GGH projection period, this would be insignificant as far as the Region. Other areas of the Region of Waterloo are identified as growth centers. In addition, the majority of the study area falls outside the GGH and within Perth County .
Population Growth Statistics
Tables A1, A2, and A3[1] summarize the 2006 census population growth statistics for the affected municipalities and compares them to Stratford, the region of Waterloo and Ontario as a whole. As can be seen, Wilmot has grown very rapidly (15%) over the five year intercensal period from 2001 to 2006. This is primarily due to residential growth in Baden and New Hamburg.
Wilmot's growth is a significant part of the overall 9% increase in the population of Waterloo region over the five year period. Perth East and Perth South both declined slightly in population between 2001 and 2006 and Stratford's growth at 2.3% has been quite modest, even when compared to the provincial aggregate growth of 6.6%. A large percentage of the labour force living in Perth South and Perth East work in the agricultural industries, 20% and 21% respectively, and this industry is the dominant means of employment. In contrast, in Wilmot, those working in agriculture are 5.6% of the experienced labour force.
Census statistics are generally used as a basis for population projections by cities, towns and other municipalities. However, population projections are often quite optimistic. Projections are based on 'assumption models' and the main problem is that people move around and make other decisions that cannot really be reflected in these models. Most projections are simply best guesses.
By way of example, Table A4 shows the projections made for the County of Perth, using 1991 as a base-line and the 1996 Census counts as a qualifier. As can be seen the model predicted a population for Stratford, in 2006, of 32,028 people. Census data for 2006 actually counted 30,461 Stratford residents. Similarly Perth East's growth to 2006 was overestimated in the model by 1545 people or nearly 13%. Perth South's projected 2006 population was overestimated by nearly 17%. County staff inform us that new projections will be devised based on 2006 Census data but these are some distance from being developed.
Table A5 is drawn from a long range plan developed by the province for the Greater Golden Horseshoe. The GGH plan is an impressive expansion of the Greater Toronto Area (GTA) concept and covers most of central Ontario, including Waterloo region. Within the plan the region of Waterloo is projected to grow from a base population of 456,000 in 2001 to 729,000 in 2031, a 60% increase over thirty years.
The GGH, in total, is projected to contain 11.5 million people by 2031. Whether these figures are credible depends on many assumptions built into the models, which are unavailable for examination.
In summary, recent growth of Wilmot Township is quite dramatic and the agricultural sector must obviously compete much more vigorously for its fair share of land. This pattern may continue for many years to come. Perth East and Perth South are showing small declines in total population and these two municipalities remain dominantly agricultural. No readily available evidence currently exists to support the notion that population growth in any part of Perth County may suddenly accelerate along the lines of Waterloo region. While recent projections for the Greater Golden Horseshoe suggest massive population growth in various Toronto centered region, these trends do not currently extend to Perth.
The GGH does not mirror the conditions, population, growth and development conditions of the majority of the study area. Neither does the condition of Kitchener, Waterloo and Cambridge mirror the development or potential for the City of Stratford.
The consultant may be required to cite this initiative but the development of growth strategies for this heavily urbanized and urbanizing area of Ontario seems inappropriate to be used to set the stage for Perth County with distinctively different resources, economy and population dynamics. The influence of the policies for the GGH should have only a limited if any influence on the study area.
[1] See all Tables beginning with page 27
Point Two: Greater Stratford Area
On page 2 of the Introduction to Report A the geographic area “Greater Stratford” is introduced and used throughout the reports but does not identify what is meant by this. The term implies a metropolitan area and not a slow growing city. What does the consultant define as the boundaries of the Greater Stratford Area? It is hard to comment on something we don’t know about.
Point Three: When does the Existing Economy Count?
Six objectives are identified in Report A (pages 3-6). Objective 2, identifies the need to address long term needs for the movement of goods and people and stimulate economic growth and create jobs and Objective 4, identifies the need to conduct planning and design with an approach to avoid or minimize overall environmental impacts.
These statements imply the environment and the creation of new jobs are of higher priority than the protection of the local existing economy.
Where is the objective to avoid or minimize impacts on existing economic generators within the study area that will lead to the loss of jobs and reduced economic growth and impact the local cultural landscape?
Point Four: Unsubstantiated Issues
Report A, section 1.3 Preliminary Statement of Transportation Problems and Opportunities, page 6 identifies six problems and opportunities to be addressed by the study. Item 6 states” Area transportation planning and local land use planning in the analysis area need to be co-ordinated, in order to ensure new/intensified development associated with forecasted population and employment growth in the Analysis Area does not negatively affect or even preclude alternatives to address transportation problems and opportunities”.
Where in the report do the consultants address the “forecasted population and employment growth”? This is raised as a problem to be addressed but nowhere in all of the reports is any information provided and the implications discussed. This is just assumed. If this is considered one of six problems surely it merits being addressed.
Point Five: Where is the existing community recognized?
Report A, pages 15 - 16 identifies the Principles for Conducting the Study. It appears that the process of undertaking consultation is more important than the community being consulted. Where is the principle of doing the least harm to the community?
Point 6: We Applaud this Direction
Report A section 2.4.1 identifies the transportation engineering principles to be applied to the alternatives. Item (j) page 16 states “minimize property requirements and impacts on adjacent properties”
This is the first statement in the report that hints to the possible disruption in the community and the negative impact of this work on landowners. We applaud this principle and will hold the consulting team and MTO to this. We will be interested in the approach used to do this.
Point 7: Wetlands Trump Agriculture
Report A, under the heading Environmental Protection Principles, item (h) page 17 states:” balance the approaches to environmental protection, recognizing that the general order of decreasing preference is as follows:
. avoidance/prevention
. control/mitigation ( reducing the severity of the environmental impacts)
. compensation ( provision of equivalent or countervailing environmental features)
. enhancement ( improvement over previous environmental conditions)
It is interesting that in the provincial Greenbelt rhetoric we are all working together as land stewards but it appears no so in the case of highway development. The environment has priority in this set of priorities and the members of the community who have been stewards of the land for several generations are ignored.
We recommend that the consultants use the same template developed for reviewing environmental impacts to develop a similar priority and approach to Agricultural Business landscapes in the study area. In future studies the Ministry of Transportation must change the approach of any study protocol involving agriculture.
Point 8: Evaluation Principles LackingReport A, section 2.4.3, Evaluation Principles – (item e) page 18
“evaluation criteria to be comprehensive, fundamental, relevant, independent, measurable and well defined.”
The consulting reports reference agricultural land capability and touch on the generic features of culture within the study area.
In section 7.3, Evaluation Factors, agriculture is identified in two of the list of sixty-two criteria. Under the broad factor of Land use, agriculture is mentioned on page 110 regarding the potential to affect specialty crop areas and /or areas of CLI class 1, 2 and 3 lands. The second reference is 4.4 Agriculture, where the road has “potential to support the agricultural industry by efficient movement of goods”.
Agriculture must have a higher priority at this stage in the evaluation.
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