What Does the “E” in EA Mean, Anyway?

When you really look at it, the environment doesn’t really count that much

The City’s Parkway Corridor Proposals are being prepared under a Municipal Class Environmental Assessment process (we’ll call it MCEA for short). The MCEA process has the appearance of protecting the environment within cities when large public projects are planned. We found it interesting to discover that the MCEA process was designed by engineers and not urban planners, environmentalists, public interest groups or other folks interested in what roads do to cities. If you look at the real purpose of MCEAs, what quickly becomes apparent is that the environment is just one component of the evaluation. According to a nice overview of the MCEA process at the Region of Durham, the term ‘environment’ doesn’t just mean the environment but is, “broadly applied to include the natural, social, cultural, constructed and economic environments”.

So, while to the public (and to us when we first read it), the term ‘environmental assessment’ sounds like an assessment of the environmental impacts of a project, the actual factors used to evaluate the Parkway Corridor proposals can mean much, much more (and in impact, as far as the environment is concerned, much, much less).

This is troubling, because the use of a pre-defined environmental assessment process implies impartiality and an exhaustive process to look at alternatives and evaluate the full impact of those alternatives. At the end of the study, Parkway proponents can point to the EA process and say, “Look, the environment has been considered and protected. An un-biased process was followed and here are the results. How can you argue with them?” We couldn’t disagree with this assertion more.

While the environment was mentioned in the early days of the EA process, it was also clear very early on that subjects like the environment and quality of life were not really going to be part of the evaluation, at least, not in any meaningful way.

The environment as one of eight criteria for evaluation
The environment as one of eight criteria for evaluation

First, in a typical “divide and marginalize” strategy, the importance of these social and environmental factors were reduced when evaluating all the options. By dividing the criteria into eight, the importance of the Parkway as recreational greenway and parkland was lost in the shuffle. This, despite overwhelming public input into the first public meetings that our environment was the NUMBER ONE issue. Using eight criteria: Technical, Natural, Built, Social, Cultural, Economic, Financial and Overall (whatever that means), the AECOM team found the Parkway right-of-way the most preferred option for six of the eight criteria with Social criteria showing up as moderately preferred and Natural criteria showing up as least preferred. The suggestion was made that natural and social environments can be mitigated. How you mitigate the loss of a greenway trail or a park was unclear.

The idea that the EA process is a balanced assessment of the situation is simply wrong

To illustrate this, consider the image below. It is taken from one of the Public Information Centres (PIC) and shows a cost/benefit assessment for the Parkway proposals. What do you see in the cost benefit analysis? We see the costs listed are limited to the cost to build the road and the infrastructure ($66 million). The benefits: car travel time savings.

image of cost & benefits of Parkway as seen by the EA process
The costs and benefits of Parkway as seen by the EA process

That’s it. Missing from the costs are ALL the things that upset so many people about this proposal. The loss of greenspace. The loss of parks. The noise. The pollution. The health impacts. The impact on wildlife. The inconvenience to anyone who travels using any other mode of transportation other than cars. It is all about cars. Does the above cost/benefit analysis seem like a balanced evaluation to you?

To us, it appears that the entire EA process has been an exercise in “how do we justify building the Parkway”, not an exercise in protecting the environment. It certainly does not appear to be a process that protects the quality of life we have in Peterborough and it certainly does not seem open and balanced.

Yet, we are worried City Council will use it as a means to justify destroying our greenspaces and our parks.

Peterborough, it’s a natural! Let’s keep it that way – green, natural, and beautiful.

More reading…

While ultimately governed by the Province’s Environmental Assessment legislation, MCEAs are a special form of streamlined environmental assessment. While they do have to conform to Ontario’s regulations, the MCEA process was actually designed by the Ontario Municipal Engineers Association (MEA).


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