ABC Replies to Consultants

Hi everyone.

Below is the letter of response ABC sent to MTO and the Consultants. It is our reply to the April 22nd response from the Consultants in which they attempt to answer the Recommendations ABC submitted for PIC 2b.

Charles Organ C.E.T.
MTO South Western Region
Project Manager
Planning and Design Section
659 Exeter Road
London ON
N6E 1L3

Brenda Jamieson, P.Eng.
Consultant Project Manager
AECOM
300 Water Street,
Whitby, Ontario
L1N 9J2


In response to your letter to the Agricultural Business Community (ABC) dated April 21/2009 in which you formally respond to our Volume 3 comments regarding PIC #2B. For purposes of clarity our further comments found below reference specific pages of your April 21st letter.

Initially we must say that ABC applauds the consultants and MTO for maintaining an open dialogue around key agri-business issues pertaining to the corridor's planning. Secondly we very much appreciate the time and effort devoted to input and concerns of ABC including your detailed letter of April 21st. We recognize that you have many conflicting stakeholders to serve and satisfy. However some of these stakeholders are directly affected, most notably the agricultural landowners, so we expect you will understand our need to firmly reiterate our main positions.

1. Screening Criteria for the Long List of Corridor Alternatives (Pages 3,4)

“The screening used a 'reasoned' approach in which there was no weighting of the screening criteria against one another. The results in all screening criteria have the same weight. ...... Potential impacts are not quantified at the corridor evaluation stage.”

While we understand the methodology referred to above, we still firmly believe that any 'reasoned approach' which lacks quantifiable data must inevitably involve a hierarchy of subjectively preferred values. The trade-offs in any list of 7/8 corridor options is not enviable. Does the province wish to further advocate food production or pavement? Is a wetland more or less important than heritage buildings? These decisions ultimately involve value preferences. ABC is not opposed to the application of value preferences. Indeed, all difficult decisions require value guidance. We only ask for their recognition and transparency when applied.

2. Agriculture Land Receives Lower Weighting in Decisions (Page 5)

“We are enhancing our approach by giving agriculture its own evaluation factor and by splitting agriculture into two evaluation criteria: a) the CLI Class; and b) the type of farm operation/infrastructure.”


ABC views that this is a significant enhancement to the evaluation methodology and we are pleased with your creative flexibility given the overwhelmingly tight parameters which constrain the EA study. As we understand the methodology, these new relative weightings will be applied to agriculture in the next detailed planning phase, where quantifiable trade-offs can be assessed for specific route planning.

3. Rural Heritage is Absent (Page 6)

ABC will continue to advocate for protection of agricultural and rural heritage, both built heritage and cultural heritage. The biases we noted in our two earlier briefs regarding rural heritage remain un-addressed. Therefore, this points to a serious flaw in the current design of MTO Class EA studies, which will need to be rectified.

“It should be noted that it is premature to assume location-specific potential heritage impacts since a preferred corridor has not been selected.”

ABC wishes to advise you that when route planning begins we will be monitoring and acting on any perceived threats to rural heritage presented by either the selected corridor or routes within it.

4. Questions of Need (Pages 7, 8, 9)

We continue to respectfully disagree about estimates made by both your firm and MTO regarding population and transportation needs.

a) The population projections for regional growth are based on questionable estimates for the Greater Golden Horseshoe and are not credible.

b) The 7/8 transportation survey, done in 2004, has a 'summer-traffic' bias and precedes the recent oil and energy crisis which is adjusting travel patterns.

c) Truck and commercial vehicle surveys for the province may have been considered but any that specifically apply to this corridor have not been done.

d) Your traffic projections have already been challenged by municipal experts and yet your estimates continue to remain un-revised.

“Widening Perth Line 33 ... may provide sufficient theoretical capacity to accommodate future demands .... [But] the use and widening of municipal roads is an area transportation option that is not being carried forward ...” (your emphasis)

For most local residents further upgrading of Line 33 is a logical traffic management technique for reducing density on the existing 7/8 corridor and this has been so for decades. Yet this option was unwisely ruled out even before the first set of corridor options were presented in the summer of 2008.


5.Drainage (page 10, 11)

“The engineering standards for this work are rigorous state of the art requirements of the MTO Drainage Manual, which is used as a reference by many authorities including many municipalities.”

ABC does not dispute the quality of professional engineering standards to be applied but ABC is concerned about their actual field implementation. The experience of many farmers is that MTO road contractors do not satisfactorily complete drainage obligations or else they do not understand their central importance.

ABC very much appreciates the undertaking and commitment by MTO to pay for the costs associated with system modifications by licensed drainage contractors to mitigate impacts on agricultural private tile drainage systems.

However, MTO is asking all affected municipalities and private land owners to 'have faith' in its professional staff regarding their planning for drainage and to 'believe' that road contractors will understand and complete all the work to the satisfaction of affected parties. To protect affected parties, ABC will continue to press for a viable option for 'peer review' of any drainage plans devised for the selected corridor and route.



6. Public Consultation (Page 11, 12, 13)

Despite your protestations about the reputed efficacy of the PIC's, ABC will continue to ask for formal presentations by the consultants and MTO followed by question and answer sessions as an alternative to the PIC’s. We believe that communities need to hear their voices together. We very much appreciate that the consultants and MTO staff have from time to time agreed to such formal meetings and hope they will be open in future to such alternatives.

The extension of PIC's to 9:00 p.m. was duly noted by ABC and was seen as a positive step to encourage rural participation. The consultants and MTO should also be mindful that the end of June is one of the most hectic periods in the farm calendar.

Conclusion

ABC remains committed to seeking solutions for Highway 7/8 alternatives that will minimize the impact on the agricultural land base and on agricultural businesses while still encouraging future road development and enhancing public safety. We thank you for your attention and for this opportunity to express our positions.



Linda Dietrich p.p.

Agriculture Business Community of Perth East, Perth South and Wilmot West

Scribd document coming soon!

Perth Federation of Agriculture May 22,2009

Below is the PFA response to PIC 2c. Very good questions! Lets see if they answer them!


MTO Response Letter 0609

National Farmers Union Responds

Perth-Oxford Local, National Farmers Union
c/o Ann Slater,

Tuesday, May 19, 2009-05-19

To: Ms Brenda Jamieson, P. Eng.,
Consultant Project Manager
AECOM,
300 Water Street,
Whitby, ON,
L1N-9J2

Mr. Charles Organ, C.E.T.,
Project Manager
Ministry of Transportation, West Region
Planning and Design Section
659 Exeter Road,
London, ON
N6E-1L3

Re: (PIC)#2C Stratford Area Highway 7&8 Transportation Corridor Planning and Class EA Study

Perth-Oxford Local, National Farmers Union has already commented on proposed changes to the Highway 7 and 8 corridor in the Stratford area. None of our previously expressed concerns appear to have been addressed in (PIC)#2C. We continue to press for increased public transportation to reduce traffic on our roads and highways. Increased public transportation that reduces road traffic will preserve prime farm land and reduce our reliance on fossil fuels.

(PIC)#2C also presents additional concerns for farmers in our area. The proposed new road that angles from 7&8 to Perth Line 33, Lorne Ave., east of Stratford will cut through more than 1000 acres of prime farm land. Farmers in the effected area will lose access to parts of their farms. Other farmers outside the directly effected area who need to move machinery north and south across the corridor will be severely inconvenienced also.

On the west side of Stratford the (PIC)#2C diagram shows the proposed corridor following existing roads. However we wonder if wide, high speed curves will be placed at the corners of Perth Line 32 and Perth Road 125, and also at Perth Road 125 and Highway 8. Such curves would result in considerable loss of access to farm lands and likely destruction of buildings as well.

We request a clear undertaking that (PIC)#2C does not actually include those sort of curves west of Stratford.

Ann Slater, Secretary Perth-Oxford Local, NFU

Perth County Response to 2c

2009-05-22 Letter - PIC#2C

May 22, 2009 ABC Sends response to PIC 2c

May 22, 2009

Charles Organ C.E.T.
MTO South Western Region
Project Manager
Planning and Design Section
659 Exeter Road
London ON
N6E 1L3

Brenda Jamieson, P.Eng.
Consultant Project Manager
AECOM
300 Water Street,
Whitby, Ontario
L1N 9J2

Our first brief to the Consultants and MTO was intended to enlighten the planning team on the nature and reality of today’s agriculture business within the study area. The business data in that report still stands and is relevant to this stage in the planning process.

In our Feb. 6th report, we identified serious flaws in the development of the Short List of Corridors and flagrant biases against the rural community in the weighting of pros and cons for the different options. Furthermore, we identified the neglect of critical items that are almost completely missing in the consultant’s list of criteria that are fundamental to the development or upgrading of any highway corridor.

We are very dissatisfied with the response the Agriculture Business Community received from AECOM dated April 22, 2009 to our report dated Feb. 6th, 2009. We will be forwarding you additional comments in reference to this in the near future. There were significant elements that were NOT addressed.

We are disappointed that the MTO and Consultants refuse to support our Recommendation #15 from the Feb. 6th report therefore, in the interests of meeting the needs of the community we will organize and facilitate a public meeting to discuss and review your recommendations for a preferred corridor. We appreciate your commitment to attend and we will forward you our agenda outlining your presentation topics once the dates for the PICs have been chosen, the community has had time to digest your recommendations, and we have a venue booked.

The Agriculture Business Community recognizes that you have extended the duration of your PICs by one hour to facilitate our participation. Now we need to point out again that the May to August period is a very poor time of year for the MTO or the consultants to expect anything from our businesses or members in the way of constructive criticism with your plans.

The next PIC will present your proposed Preferred Highway Corridor. This step in your process may determine the fate of many producers and therefore it is critical that their schedules be accommodated to allow them to respond.

A sixty day response time is not adequate if you are truly interested in receiving comments. Farmers are working over 100 hours a week, planting this year’s crop. It is crucial to any success that an extended review period is allotted during this phase in our business cycle if you expect, and count on hearing from the ABCs. Therefore we strongly suggest that you move the response date to your proposed June PIC to September 30, to allow producers a fair chance to respond.

In response to PIC 2c, the Agriculture Business Community reiterates:

The work to be approved by MTO in Highway 7&8 corridor planning and development needs to:

1. Recognize agriculture as a business

2. Protect prime agricultural land (Canada Land Inventory Class 1, 2 & 3) for the business of agriculture

3. Minimize the impact on agricultural business enterprises

4. Assume financial responsibility for all drainage costs of highway development, before and after construction

5. Acknowledge and protect our rural heritage.

We believe these principles are still valid and have not been addressed. They need to drive the planning process for future highway development within this study area. They represent more than idle words. They represent this community and our livelihoods.

We have attached a copy of an article prepared for the Ontario Farmer by Tanya Brouwers and we ask that you reflect on its direction before you go back to the drawing board.

Sharon Weitzel
Communications Officer, p.p.

Agriculture Business Community of Perth East, Perth South and Wilmot West

***********

Canada’s Disappearing Farmland
by Tanya Brouwers

Canada is a nation of vast spaces and varied terrain. Nationwide, however, this seemingly endless land base has limited agricultural potential. In fact, 94% of Canada’s lands are unsuitable for farming. Of that small percentage of land that will support agricultural endeavours only 0.5% is designated as class 1, where there are no significant limitations to farming activity. Unfortunately, due to urbanization, poor farming practices and other non-agricultural activities, this small percentage of viable farmland is shrinking at an alarming rate. Statistics Canada, for example, reported that between 1971 and 2001, over 14,000 square kilometres of our best agricultural land had been permanently lost to urban uses. Fortunately, as more individuals recognize the importance of healthy agricultural landscapes in matters of food security, recreation and habitat conservation they are asking Canada’s policy makers and politicians why this precious yet limited land base is allowed to disappear.

Some might answer that it is Canada’s political structure itself that lends itself perfectly to this rapid reduction of agricultural land. Federal policy initiatives, like Agriculture and Agri-Food Canada’s Growing Forward program, emphasize the “how” of agricultural practices by focussing on those elements vital to a healthy and viable agricultural economy, specifically innovation, local need and best management practices. These programs fall short, however, in addressing the “where” of agricultural activity. Currently, it is the role of the provinces, regions and municipalities, along with a host of other non-agricultural interests, to decide whether keeping agricultural land available for production best meets “community need”. Unfortunately, the competitive nature of this multi-tiered, “bottom-up” approach to farmland preservation has resulted in a nationally fragmented land use system with some provinces adopting agricultural land reserve and zoning models while others, quite simply, do not.

For example, the provinces of Ontario, Manitoba, Alberta and Saskatchewan, home to 99% of Canada’s Class I farmland, are without centralized models of farmland preservation, the results of which have been devastating. Ontario, for instance, with over 56% of the nation’s Class I land has lost, in the two decades between 1976 and 1996, over 150,000 acres or 18% of the province’s Class I land to urban encroachment and non-agricultural interests. In the absence of protective policies even those provinces with a relatively scarce amount of dependable farmland continue to report losses. Nova Scotia, for example, between 1921 and 2006, has seen over 80% of its working farmland used for purposes other than agriculture.

Sadly enough, even the provinces with established farmland preservation policies are not without reproach. BC’s Agricultural Land Reserve and Quebec’s Act to preserve agricultural land, both benchmark planning policies designed to protect the provinces’ small amount of prime farmland from encroaching development, have seen a slow erosion of their original principles. Since its inception, BC’s reserve, encompassing only 5% of the province’s land, has seen a net loss of over 35,000 hectares, 72% of that in the more fertile, valuable lands of the south. Quebec, too, where only 2% of the province’s land can be cultivated, is considering removing over 514 hectares of valuable farmland around the Montreal area to make room for a highway.

In the absence of binding legislation to protect Canadian agricultural land, many concerned farmers and citizens are taking the responsibility of farmland preservation upon themselves. Some individuals are using covenants and agricultural easements to prohibit future development and division of their land. Others are donating part or their entire agricultural land base to trusts. The Ontario Farmland Trust, BC’s The Land Conservancy and Saskatchewan’s Genesis Land Conservancy are some examples of organizations that are not only conserving farmland but are ensuring that that the land is farmed in a sustainable or, in the case of Genesis, in an organic manner. Unfortunately, implementing these measures can be time consuming and cumbersome. It also puts the onus on individual farmers and non-governmental organizations, rather than the governments themselves, to preserve the fertility and biodiversity of Canada’s agricultural landscape.

Canada’s farmland is a finite resource. Once removed it cannot be recovered. Yet urban encroachment and development, poor farming practices and, loosely structured land use planning policies continue to erode the small amount of viable agricultural land available to Canadians. Ultimately, Canadians are losing the ability to feed themselves. Our federal government can justifiably be called upon to initiate legislation that will preserve farmland, indefinitely, for the good of present and future generations of Canadians. This is, indeed, a matter of national security.

Tanya Brouwers is a Consultant for the Organic Agriculture Centre of Canada. Please send comments or questions by phone to 902-893-7256 or by email to oacc@nsac.ca. One month after publication, OACC newspaper articles are archived at www.oacc.info

Christian Farmers Federation Responds to Pic 2c

More responses to PIC 2c.


Perth CFA Letter Regarding Highway 7&8

Perth South Responds to PIC2c

This document came to us sideways. Sorry about that. If you need to print it off it still looks fine.


May 19 Council - Letter Sent to MTO Re Hwy 7 and 8

Newsletter # 6

ABC would like all members to be aware that sometime in late June , we have been informed there will be advance presentations to all municipalities, showing the final recommended CORRIDOR!! We will be letting everyone know about these presentations as soon as we receive the dates.

**

We must respond to PIC 2c by May 22, 2009 as requested. Please ensure that YOU have made your comments re the last PIC. Any concerns should documented at length and sent in by the May deadline.

**

Residents need to know that the final CORRIDOR will likely be presented at other PIC's in June. ABC has complained about the PIC process and we are expecting to plan a public meeting shortly after any JUNE PIC.

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We have a concern involving the Environmental Inventory carried out on many properties in September 2008. One resident who had not received their requested copy last fall, recently called in to have it faxed to them. There was resistance from the company to sending that document out. Consequently, the resident suggested that they could charge the firm with trespassing, since the firms employees had agreed to the conditions set out by the owner last fall. Our member then received a copy of their Environmental Inventory.

We are very concerned about this apparent resistance to supplying landowners with copies of their own Environmental Inventory. Many landowners did request a copy and that was the condition set out for access to the land. ABC would like to know if you requested and have received a copy. If you have had any issues with the release of your Inventory to you, also please let us know.

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ABC has decided to add a "Community Events" feature to our website. If there are special events about the highway issue you wish to pass on to the membership, please email the details to hwy7and8@gmail.com. A contact person and a brief description need to be provided for the website. Since all members are notified when new material goes on the website, all interested parties can get in touch with the contact person.

It is important for us to know you have received/read this Newsletter. Please reply to us.

Thanks!

Please pass this information on to any residents or neighbours who may not be receiving these email notices.

Agriculture Business Community of Perth East, Perth South, Wilmot West

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