Professional Documents
Culture Documents
Legislative Assembly
Province of British Columbia
Vic i Huntington, M.L.A.
(Delta South)
Constituency Office:
4805 Delta Street
Delta, B.C. V4K 2T7
October 3, 2016
Michael Shepard
Project Assessment Manager
Environmental Assessment Office
increased collision risk for barn owls along the corridor. Further, the proponent does not show how
traffic volumes are expected to increase under this scenario along the length of the LAA. It should be
required to do so, as it would provide a more detailed portrait of the risk profile in different road
segments. The majority of the surrounding habitat that will have moderate foraging value for barn owls
is located along the Highway 99 stretch in Delta.
(42) 4.8.4.3: The proponent states that addressing collision risk for barn owls during the development of
the SFPR with hedgerows and fences has been effective in reducing mortality risk. The proponent does
not cite any research or data related to this experience and it should be required to do so. The
proponent also states that hedgerows and fences will be erected in high-risk areas within the Project
alignment, but does define these areas. The proponent should specify what areas will be classified
high-risk in relation to the maps provided in Appendix B (Figures 5b-5p).
(42) 4.8.4.3: It is noted that to be fully effective as a mitigation measure, hedgerows must reach 2 to 3
metres in height, which may take ten years to attain. The proponent notes that planting hedgerows in
advance of Project operation will expedite this process, but given the average age of barn owls in the
region is 2 to 3 years, this time lag may still represent 2 to 3 generations of barn owls before the
mitigation is deemed effective. The proponent should offer solutions that do not delay implementation
of this mitigation measure.
5.1 Traffic
(2) 5.1.1.1: The proponent claims the Project will reduce congestion on adjacent municipal streets,
which can provide future benefits to local area social and economic values. The proponent does not
appear to have backed up this claim with evidence. This section does not appear to contain any traffic
analysis on adjacent municipal corridors. This is particularly concerning given the potential for significant
traffic diversion once the Project is in place, as evidenced by the proponents estimates for traffic
increases at the Alex Fraser Bridge of 33,000 AADT by 2045 from 2014-2015 levels (p. 19; 5.1.2.4.2). The
proponent should model scenarios that estimate the effect the Project will have on important municipal
traffic corridors.
(4) 5.1.1.3: Assumptions related to traffic forecasts for the new bridge have been based off the Port
Mann Bridge tolling framework. The proponent should specify in more detail the exact assumptions
that have been carried forward into this analysis. For example, the Port Mann Bridge began with a
reduced small vehicle toll rate of $1.50 for the first year before increasing the rate to $3.00 in 2014 and
later $3.15 in 2015.
(16) 5.1.2.4.1: The proponent presents two model scenarios between 2030 and 2045 one tolled [GMT
(TL-RTM Tolled)], the other not [GMT (TL-RTM Untolled)] with traffic volume differences higher than
40,000 annual average daily traffic movements. This represents more than half of current daily volumes.
The proponent states that the majority of this difference applies to drivers who avoid crossing the river
at all or divert to the Alex Fraser Bridge, primarily during off-peak periods and weekends. The
proponent should specify why it believes the majority of the difference will come from these changes,
given TransLinks RTM does not permit exact estimates of travel pattern changes in terms of not
crossing the river, diversion to an alternate crossing, or changing modes.
The proponent should also provide further rationale or justification for the conclusion that traffic
diversion to the Alex Fraser Bridge would occur primarily in off-peak periods and weekends.
(16) 5.1.2.4.1: The New Bridge Growth Forecast uses an annual auto growth forecast of 0.65 per cent,
which the proponent claims is consistent with recent-year trends for Richmond and Delta traffic via the
Tunnel and AFB, and at about half of RGS population and employment growth forecasts for south-ofFraser municipalities. Annual truck growth is pegged at 1.5 per cent and based on similar recent-year
trend data. The proponent should explain the discrepancy between these growth rates and historical
data for the Massey Tunnel presented in the George Massey Tunnel Replacement Project Traffic Data
Overview (p. 1; Figure 1; Appendix B), which show no growth in AADT at the Massey Tunnel since the
late 1980s, and a slightly negative annual growth rate of -0.36 per cent between 2003 and 2014 (p. 20,
Table 1, Appendix B). Combined traffic growth from both the Massey Tunnel may show 0.64 per cent
annual increases between 2003 and 2013, but as the proponent notes The AFB has absorbed almost all
of this growth, because of the lack of available capacity at the Tunnel (p.1; Appendix B). Growth at the
AFB during this time period has increased by 1.51 per cent per year (p. 2; Appendix B). Likewise,
modelling in the Traffic Data Overview estimates that traffic through the Tunnel will grow to
approximately 100,000 vehicles per day by 2045 (p. 13; Appendix B). The discrepancy between the lack
of historical growth at the existing Tunnel and this estimate is not explained.
(19) 5.1.2.4.2: The proponent estimates daily traffic volumes will increase at the Alex Fraser Bridge
under the With Project and Tolled scenario by 33,000 AADT from 2014-2015 levels, which represents a
31 per cent increase. These volumes are 20,000 AADT higher than the comparison scenario without the
Project. Given the proponent has stated TransLinks RTM does not permit exact estimates of travel
pattern changes in terms of diversion to alternative crossings like the AFB (see p. 16; 5.1.2.4.1), the
proponent should further explain how it was determined that this increase is primarily because of offpeak diversion from the tolled facility to the untolled facility (p. 18).
(19) 5.1.2.4.2: The Project is expected to increase traffic volumes at the Alex Fraser Bridge by 20,000
AADT by 2045, in comparison to a scenario without the Project. This represents a total increase of
33,000 AADT from 2014-2015 levels. As noted in the Traffic Data Overview (p. p. 2, Figure 3; Appendix
B), AFB already experiences significant congestion during rush hour periods. This is an unsustainable
situation and the proponent should prepare analysis of an upgraded AFB and/or a regional tolling policy
in the future, as additional modelled scenarios for consideration.
(24) 5.1.3.2.1: The proponent claims the Project will support provincial and regional strategies to
encourage mode shift to transit and carpooling by providing dedicated transit/HOV lanes along the
Highway 99 corridor. However, providing dedicated lanes does not guarantee significant increases in
ridership, and is not the same as increases in service. The proponents traffic model analysis predicts
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transit mode share over the future bridge will increase between 5-10 per cent by 2045, as compared to
a scenario without the Project. The Traffic Data Overview cites 2014 transit mode share at 0.7 per cent
of daily traffic volumes (p. 20, Table 2, Appendix B), but does not cite transit mode share scenarios
without the Project. An increase of 5-10 per cent by 2045 from 2014 mode share of 0.7 per cent is of
marginal impact and it is misleading to suggest the Project supports provincial and regional strategies to
encourage mode shift to transit. While daily HOV mode share is higher, at 16.6 per cent in 2014 (p. 20
Table 2, Appendix B), a 5-10 per cent increase by 2045 from this level would only increase overall mode
share by between 0.6-1.6 per cent. Similar arguments hold for levels of cycling mode share increase
expected from the Project given how low current mode share levels are.
(14) Appendix B, Section 5: The analysis of laning requirements in this section does not indicate whether
the 8-lane and 10-lane bridge scenarios under consideration were modelled using a tolling scenario
similar to previous assumptions in other sections (e.g., Port Mann tolling structure). This is a critical
omission, as it underpins the rationale for choosing a 10-lane bridge. The proponent argues the new
bridge requires 10 lanes, as opposed to eight, to avoid peak-period congestion on opening day (see p.
29, Appendix B). There are significant differences in traffic estimates between tolled and untolled bridge
scenarios. Tolling is projected to reduce traffic volumes at the new bridge by roughly 40,000 AADT by
2045 (p. 15, Figure 5.1-2; 5.1.2.4.1). This is more than half the current volume at the Tunnel. Given these
dramatic effects on traffic volume, and given the critical importance these traffic numbers will have on
Valued Components in the application, such as terrestrial wildlife, atmospheric noise, air quality, land
use and human health, the lack of specifics is of critical concern and should be clarified before
proceeding further.
Further, the proponent does not sufficiently justify the argument that an 8-lane bridge would result in
peak-period congestion on opening day. As previously mentioned, traffic volumes at the Tunnel have
remained relatively flat since the late-1980s and have showed a slight annual decrease in volume since
2003 of -0.36 per cent (p. 20, Table 1, Appendix B).
(29) Appendix B: The proponent argues The absence of an additional lane for slow moving and weaving
traffic would lead to heavier congestion; compromising travel times for the faster moving through
traffic. This statement should be justified with reference to relevant research and specifically quantify
the compromised travel times.
(18) Appendix C: The only mention of induced demand the Project will have on traffic volumes appears
in the Steers Davies Gleave consultant report. Induced demand should be considered when evaluating
traffic forecasts under different modelling scenarios. Other scenarios used by the proponent in the
application should likewise comment further on the induced demand assumptions contained in each
scenario.
(26) 4.10.5.2: The proponent should document in more detail exactly what mitigation measures are
planned for each location. Residents and other property owners and tenants deserve a specific outline
of how their neighbourhoods will change, both with the Project and with planned mitigation measures.
the LAA, and modeled on the detailed information on ownership provided in Figure 5.3-9 and Table 5.37.
(19) 5.3.2.4: The proponent mentions Vancouver Fraser Port Authoritys land use plan without
discussing its stated desire for 2,500 acres of industrial land. This goal will have a large impact on land
use in the region and should be considered in the land use assessment.
(63) 5.3.3: The proponent distinguishes between the Project and new transportation infrastructure and
concludes that the Project will not change the distribution of population, but encourage denser, land
intensive, high quality forms of development within existing land uses. The proponent also believes the
Urban Containment Boundary and ALR will stop sprawl.
The premise that ALR land is sacrosanct and development pressures on that land will not increase as a
result of the Project is false. The proponent acknowledges elsewhere in the document that there are
development and speculative pressures on ALR land along the corridor. Additionally, multiple ALR
parcels that are involved in the Projects agricultural mitigation process are currently held by holdings
companies, including property developers. The proponent goes so far as to propose mitigating measures
(e.g., planting trees) to diminish the likelihood of the development of ALR land along the corridor after
the Project is complete. The proponent cannot reasonably conclude that the ALR, in tandem with the
Project, will lead to densification and development of existing land uses. This section is poorly argued
and should be re-written with a better grasp of current speculation on ALR land.
(66) 5.3.3.4: The proponent cites the Golden Ears Bridge as increasing land values in the region of the
bridge due to improved access. Yet the proponent also says There is no potential for the improved
[Massey] river crossing to lead to the conversion of non-development land into development land,
and Given the strength of existing land use policies such as the Agricultural Land Reserve [etc.,] any
significant changes in this regard are considered unlikely. These statements should be challenged,
particularly in light of the number of developers holding ALR land, and the net loss of 377 hectares of
ALR land in the South Coast since 2009. In addition to conducting a baseline study that looks at
purchasing trends since the announcement of the Massey Replacement Project, the proponent should
discuss what pressures the Project will place on agricultural land and land prices, and what that will
mean for food producers.
ALC
Report
2015/16
2014/15
2013/14
2012/13
2011/12
2010/11
2009/10
Ha
Inclusion
0
0
+7
+43
+39
+14
+11
Ha
Exclusion
-22
0
-56
-5
-3
-5
-400
Net
Change
-22
0
-49
+38
+36
+9
-389
The proponents numbers, allegedly drawn from the ALCs 2011-12 to 2014-15 reports, are simply
inaccurate, and do not reflect conditional and final approvals for inclusion and exclusion. The proponent
says there has been a net increase of 63 ha over that time period; the actual increase reported by the
ALC is 25 ha. However, even that number would be misleading. If you add the latest 2015/16 report, the
net increase drops to 3 ha. If you add in the 2009-10 and 2010-11 reports, which are readily available,
the ALC reports a net decrease in South Coast ALR land of -377 ha. Its imperative that accurate baseline
and trend information be used to inform the proponents analysis of agricultural impacts, and to allow
for an accurate environmental assessment of the Projects effects.
(34) 5.4.3.2.3: The proponent should provide evidence that visual landscape buffers alongside a 10lane bridge will intensify agricultural production on adjacent ALR lands and keep it from being held for
speculation.
(41) 5.4.4.3.1: The agricultural mitigation strategy relies heavily on the consolidation of adjacent
properties. The proponent says it is developing farm-specific mitigation plans in consultation with the
ALC and affected land owners. If the landowners do not agree to a consolidation proposal with former
crown lands, or if they do not develop those consolidated lands in a timely fashion, or at all, then the
mitigation of the Projects agricultural effects will fail. Agricultural plans for those former Highway 99
right-of-way lands should be established now. If agreements have been reached and mitigation plans
(i.e., strategies to develop their new lands) have been established with the landowners, those details
should be released.
(43) 5.4.4.4: The proponents agricultural mitigation primarily relies on adding Highway 99 right-of-way
lands to the ALR. However, that plan is met with significant hedging: If all 21.4 ha of the available land
within the Highway 99 ROW are eventually developed for agricultural use, a net gain of
approximately 1.4 ha of agricultural land will be achieved (emphasis added). The proponent should
provide a detailed plan and timeline outlining how and when all of the ALR offsets will succeed. If more
than six per cent of the new agricultural land is not put into production, the Project will result in a net
loss of agricultural land.
(43) 5.4.4.4: The proponent clearly breaks down the soil classification of the lands being excluded in the
main document. It should do the same for the lands that are intended to be added to the ALR, instead of
noting that It is anticipated that the land that will be made available for agricultural use would be of
similar or better capability(emphasis added). More details on this land are available to the proponent
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(see, for example, the proponents application to the ALC), and they should be included in the
environmental assessment process.
(15) 7.2.5.10: The incidence of suicide associated with the Project, regardless of any safety fencing, is
likely to be much greater than that associated with the existing tunnel. The proponent should quantify
the risk and compare it with the installation of new bridges elsewhere (i.e., bridges that did not replace
an existing bridge).
(16) 7.2.5.11: The proponent says there will be a net gain of agricultural land that can be actively
farmed (emphasis added). This language is carefully worded, as it hinges on landowners bringing the
new ALR land into production. If the new ALR land is not brought into production, then the mitigation
will have failed.
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(3) 9.1: The proponent should explain why it chose wind data from the Vancouver International Airport
instead of other monitoring stations (e.g., South Richmond; Alex Fraser).
(4) 9.1: The proponent says The Project will be designed to withstand maximum wind conditions. The
proponent should make a clear statement on the measures that ensure the Project will not be
vulnerable to a high wind event in the same way as the Pattullo Bridge, as noted in the Pattullo
Bridge rehabilitation and condition monitoring Report.
(12) 9.6: The proponent should discuss whether or not extreme wind events are likely to increase as a
result of climate change, and if so, the consequences for the Project.
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