Everything you've ever wanted to know about the environmental assessment process.
If Brampton City Council had their way, there’d be an LRT running through the sensitive, flood-prone land of the Etobicoke Creek Valley. It was only when the councillors brought their preliminary transit plan to the Toronto and Region Conservation (TRCA) for environmental review that the project was stopped in its tracks.
“There was no way TRCA staff would ever, ever approve that,” says Beth Williston, Associate Director of Environmental Assessment Planning at the TRCA. “It went against almost every policy we have.”
The TRCA is one of several oversight bodies responsible for reviewing, and in some cases conducting, environmental assessments (EAs) on infrastructure projects in the GTA. The mandatory process ensures that as urban growth happens, it considers all environmental, social and economic factors, taking into consideration questions such as species protection, valley land protection, flood and erosion control and ultimately human health and safety.
So when TRCA staff looked at Brampton Council’s request to build in the valley, the answer was no. City staff took the request to its board, and the answer remained categorically: No. The decision cited impacts to flooding, the natural habitat, and the integrity of the valley corridor, none of which could be mitigated, all of which went against policy, and with respect to flood control, might even jeopardize public safety if built.
We spoke to Beth Williston about why we need environmental assessments and how the process works.
What kinds of projects require an EA?
The process is mandatory for all public and some private infrastructure projects— buildings, roads and highways, transit systems, sewage and water pipes, treatment facilities, airports and landfills. Brand new projects, like an airport or highway, go through a comprehensive “individual” environmental assessment to identify impacts to the natural environment, and potential social and economic impacts aren’t necessarily known or predictable.
On the other hand, projects that are more routine, and when impacts are predictable, are reviewed through a scoped or “class” environmental assessment process. Things like a road widening or extension to a sewer pipe are some examples. In these cases, alternatives are considered—like whether to widen the road to one side or another—but there’s no need to delve too deep into whether or not the widening should actually occur, since that will already have been decided in the master plan.
Why are EAs so important?
While the term “environmental assessment” implies a focus on wildlife, the primary objective is to make sure the built environment fosters safe and pleasant communities for residents. Severe flooding in Houston, Texas following hurricane Harvey in August is one tragic example of how communities suffer in the absence of EAs. There, development has largely gone unchecked. Paving over wetlands—critical habitats for flood control—and other sensitive ecology isn’t out of the ordinary. The fallout, as we’re seeing, is disastrous, not just for the environment, but for the citizens of Houston.
“When you look at how safe we are today in Ontario from flood risk,” says Williston, “we’re not perfect, but relative to what’s happening around the world, we’re really good.” That’s in large part thanks to the environmental assessment process.
“EAs allow us to look at the project and evaluate why we need it, and then how best to achieve it, through natural environment, social and economic lenses,” says Williston. Indeed, it’s not just the environment that benefits when EAs are done right. The process ensures the public that the environment is respected, their tax dollars are being well spent, that the choice made makes economic sense, and that the needs of society are met. “Without an EA, there is no way to find a balanced solution,” Williston adds.
What does the process involve?
The proponent of the project—whether it’s a municipality, the province, the federal government or a conservation authority—starts with an assessment of what is needed. That includes a traffic assessment, a sewage capacity assessment, etc., and identifies gaps based on both current demand and future growth projections.
These studies form the basis for a needs assessment to decide whether or not the new infrastructure is necessary. With that information, the proponent puts together a master plan. Each project in the master plan requires an EA. The master plan also sets out the timing, and the proponent completes the projects according to this schedule.
“There is always a chance for the public to have their say,” Williston notes, through open meetings and sometimes advisory committees.
Once the EA is done (this can take a couple years) and the public has had its say, the proponent starts the detailed design process. TRCA issues permits for many of these projects. The detailed design and permitting process can take as little as six months, but sometimes years, depending on the technical issues, the number of permit approvals required, and whether the proponent needs to acquire land. Once permits are issued and lands acquired, contractors are hired and project construction can begin.
So what does this look like in action? Here’s an example.
Metrolinx approved their master plan “The Big Move” a few years ago. The community got involved and demanded a few things, including 24/7 service and electrification versus diesel. Fast forward, and Metrolinx has prioritized which GO lines should be expanded, completed the environmental assessments, and at the same time, did another assessment for electrification.
Today, Metrolinx has started the detailed design work for the prioritized sections and is working with TRCA to get permit approval before starting construction. TRCA, in turn, is ensuring flood and erosion impacts are addressed, and that there will be appropriate compensation for the trees that will be lost as the system is expanded.
Why might a project be rejected during the EA process?
“Throughout the EA process, TRCA is making sure there’s nothing unconscionable that we can’t support,” says Williston. For example, if a municipality wants to build a road through the middle of a river valley, the TRCA will almost certainly take issue with it and suggest they go back to the drawing board.
The conservation authority’s primary concern is flood mitigation, erosion control, and making sure there’s as little impact as possible on the terrestrial and aquatic ecologies. If the proposed infrastructure would increase risk of flooding, for example, or destroy the breeding grounds of the endangered Blanding’s turtle, TRCA will object. “First we want to avoid harm, then we want to mitigate it, then we need compensation if the project is necessary, and [environmental harm] really can’t be avoided,” Williston explains.
What happens if the TRCA takes issue with the proponent’s plan?
Either they scrap the plan altogether, or they adapt it to comply with the authority’s standards.
Take the Major Mackenzie Road widening project. The TRCA agreed with the proponent, in this case York Region, in their assessment: Yes, there was a need for more road space in the area. However, widening the road would mean infringing on the natural area, which is not ideal, but in this case, unavoidable.
At that point, the TRCA staff worked with York Region to determine what concessions could be made to make sure there’s a net gain from a terrestrial, aquatic, and community standpoint. They decided that, as they widened the road, they would also build lanes for a future transit way. “It means they won’t have to come back in 20 or 30 years and do more disturbance to the valley system,” Williston says.
The project also involved widening the bridges that go over the Humber River and its tributaries along Major Mackenzie; it addressed concerns around the Redside Dace, a federally recognized species of concern; and incorporates trail systems and a new pedestrian bridge. To compensate for the trees that will be lost, there is a comprehensive restorative planting plan for that space. “We thought overall, there was a win,” says Williston. “And we’re always looking for a win.”