Allandale25
Senior Member
There was some discussion in the Brampton: Queen Street RT thread on the value of public consultations and studies for transit projects/technology choices. Rather than respond in that thread, I thought it might be helpful to create a new one specifically on EAs and TPAPs. This topic could also be useful if the new government decides to make any legislative or regulatory changes to EAs/TPAPs.
Background documents (may add more later):
I reached out to Steve Munro to get his thoughts and any background information, and with permission I've copied his reply below.
Quote:
No, I have not written [on his blog] about the TPAP process specifically. It was created to, in theory, shorten the time needed for what used to be called an “EA” by eliminating some of the more tiresome parts of the EA such as a needs analysis, but also got rid of a lot of the true “alternatives analysis” we used to see. The assumption was that the need for the transit projects was already evident and they would go ahead no matter what.
Where things run aground is that the TPAP still contains some “EA” type things like endangered species, but this stuff is almost quaint given the lack of attention to alternatives.
Some of that alternatives work still occurs while a project is being formulated, but by the time it gets to the TPAP itself, a project is pretty much a done deal.
The purpose of the clarification was to explicitly say that any RER-related work, some of which would not have been considered as “Transit”, was able to use the same fast-path process.
TPAP is a double-edged sword. It allows projects to get through that stage faster, but the quality of overall project review depends more now on the professional dedication and courtesy of the proponent and project team.
I do not agree that the consultation is a sham, although this varies from project to project. As I said, it depends on the good will of the proponents. However, the TPAP provides a mechanism whereby a sham consultation is not hard to run.
What is frustrating is that we still have some purely environmental issues that get detailed review (animal habitats, heritage, etc) left over from the normal EA process, but that the meat of issues can be swept aside by the assumption of a technology and alignment before the TPAP begins.
You have to remember that TPAP goes back to the comparatively liberal, well-intentioned era of David Miller and Dalton McGuinty when we just wanted to get things done with reasonable but not excessive consultation/review. The process we actually got had obvious holes in it if used by an agency who just wanted to push aside meaningful participation.
Toronto is still doing a lot of up front work on projects before launching the TPAP, and this incorporates some of what was once in the EA, but less formally.
End quote.
Background documents (may add more later):
- https://www.ontario.ca/page/guide-environmental-assessment-requirements-transit-projects
- https://www.ontariocanada.com/registry/view.do?postingId=17623
- http://www.scarboroughsubwayextension.ca/what-is-a-tpap.html
I reached out to Steve Munro to get his thoughts and any background information, and with permission I've copied his reply below.
Quote:
No, I have not written [on his blog] about the TPAP process specifically. It was created to, in theory, shorten the time needed for what used to be called an “EA” by eliminating some of the more tiresome parts of the EA such as a needs analysis, but also got rid of a lot of the true “alternatives analysis” we used to see. The assumption was that the need for the transit projects was already evident and they would go ahead no matter what.
Where things run aground is that the TPAP still contains some “EA” type things like endangered species, but this stuff is almost quaint given the lack of attention to alternatives.
Some of that alternatives work still occurs while a project is being formulated, but by the time it gets to the TPAP itself, a project is pretty much a done deal.
The purpose of the clarification was to explicitly say that any RER-related work, some of which would not have been considered as “Transit”, was able to use the same fast-path process.
TPAP is a double-edged sword. It allows projects to get through that stage faster, but the quality of overall project review depends more now on the professional dedication and courtesy of the proponent and project team.
I do not agree that the consultation is a sham, although this varies from project to project. As I said, it depends on the good will of the proponents. However, the TPAP provides a mechanism whereby a sham consultation is not hard to run.
What is frustrating is that we still have some purely environmental issues that get detailed review (animal habitats, heritage, etc) left over from the normal EA process, but that the meat of issues can be swept aside by the assumption of a technology and alignment before the TPAP begins.
You have to remember that TPAP goes back to the comparatively liberal, well-intentioned era of David Miller and Dalton McGuinty when we just wanted to get things done with reasonable but not excessive consultation/review. The process we actually got had obvious holes in it if used by an agency who just wanted to push aside meaningful participation.
Toronto is still doing a lot of up front work on projects before launching the TPAP, and this incorporates some of what was once in the EA, but less formally.
End quote.