EA Study Failings
This EA Study is now 25 years out of date – the first draft of the EAS Terms of Reference originated in 1993. These Terms of Reference, which rely upon now significantly out of date information, set out the legal roadmap for the conduct of the entire EA Study leading to its final approval in 2002 under the EA Act.
The following land use and environmental protection statutes did not exist in 2002 when the Bradford Bypass Environmental Assessment was approved:
- Lake Simcoe Protection Act, 2008 – Plan issued 2009.
- Oak Ridges Moraine Conservation Plan, 2002
- Greenbelt Plan, 2005
- Places to Grow Act, 2005 – Growth Plan for the Greater Golden Horseshoe, 2006
Furthermore, the Go Transit Barrie train and bus service was not considered in the EA Study as an alternative method of undertaking. As of December 2019, Metrolinx reported average daily ridership of 2,343 persons from stations associated with the study’s Problem / Opportunity Statement. Once we recover from the current COVID-19 restrictions, this ridership level is forecast to increase significantly as a result of electrification of the Barrie train line and implementation of frequent all day service. This will have a significant impact on the need and justification for the proposed Bradford Bypass controlled access highway or any other major controlled access 400 – 404 linkage highway in this area.
The key question now is: how can MTO or the Province possibly justify the need for a controlled access highway anywhere north of Highway 9? The only other controlled access highway linking Highways 400 and 404 is the 407. This highway is a major, long distance, east – west toll highway in a far more populated portion of the GTA. There are many more areas north of Hwy 407 which would likely have a much higher need for a dedicated controlled access highway link between highways 400 and 404 than Bradford and none of these corridors would cross a provincially significant wetland such as the Keswick Marsh.
MTO conducted their Bradford Bypass EAS with extreme tunnel vision. MTO refused to consider any undertaking that was outside their mandate to build highways:
- Study Objectives: “to prepare a preliminary design for those aspects of any transportation improvements that may be associated with the preferred alternative and which fall within the jurisdiction of the MTO.” [emphasis added]
- “it is recognized that there is not likely to be a single facility or improvement which addresses all of the problems and opportunities noted above. Consequently, a combination of measures may therefore be appropriate. In this context, however, the current study can only deal with those elements of the total solution which fall under the MTO’s proponency or mandate”.
Concerns with this project
- Outdated Environmental Assessment
- This project is still being considered using an environmental assessment that was conducted by the province 24 years ago (1997).
- These studies are out of date. The EA process and requirements have changed drastically throughout this time frame, and so has the environment. The province should ensure a new robust EA is conducted. Construction should not start without a proper EA in place.
- At the same time, the old assessment did not consider whether the province could help congestion issues by increasing public transit or improving existing roads. Engineers believe the government must study other options, so as to ensure Ontarian’s tax dollars are used wisely.