Agriculture Business Community

Chapters: Perth East, Perth South, Wilmot West

.
Agriculture Business Community of Perth East,
Perth South and Wilmot West
C/o 3649 Road 107
RR#2
Tavistock, Ontario
N0B 2R0

May 29, 2009

Charles Organ C.E.T.

MTO South Western Region
Project Manager
Planning and Design Section
659 Exeter Road
London ON
N6E 1L3

Brenda Jamieson, P.Eng.

Consultant Project Manager
AECOM
300 Water Street,
Whitby, Ontario
L1N 9J2

In response to your letter to the Agricultural Business Community (ABC) dated April 21/2009 in which
you formally respond to our Volume 3 comments regarding PIC #2B. For purposes of clarity our further
comments found below reference specific pages of your April 21st letter.

Initially we must say that ABC applauds the consultants and MTO for maintaining an open dialogue
around key agri-business issues pertaining to the corridor's planning. Secondly we very much
appreciate the time and effort devoted to input and concerns of ABC including your detailed letter of
April 21st. We recognize that you have many conflicting stakeholders to serve and satisfy. However
some of these stakeholders are directly affected, most notably the agricultural landowners, so we expect
you will understand our need to firmly reiterate our main positions.

1.Screening Criteria for the Long List of Corridor Alternatives (Pages 3,4)

“The screening used a 'reasoned' approach in which there was no weighting of the screening criteria
against one another. The results in all screening criteria have the same weight. ...... Potential
impacts are not quantified at the corridor evaluation stage.”

While we understand the methodology referred to above, we still firmly believe that any 'reasoned
approach' which lacks quantifiable data must inevitably involve a hierarchy of subjectively preferred
values. The trade-offs in any list of 7/8 corridor options is not enviable. Does the province wish to
further advocate food production or pavement? Is a wetland more or less important than heritage
buildings? These decisions ultimately involve value preferences. ABC is not opposed to the application
of value preferences. Indeed, all difficult decisions require value guidance. We only ask for their
recognition and transparency when applied.

C / O 3 6 4 9 R OA D 1 0 7 , R .R . # 2 • TAV I S T O C K , O N • N 0 B 2 R 0
PHONE: 519-655-2631 • EMAIL hwy7and8@gmail.com
2.Agriculture Land Receives Lower Weighting in Decisions (Page 5)

“We are enhancing our approach by giving agriculture its own evaluation factor and by splitting
agriculture into two evaluation criteria: a) the CLI Class; and b) the type of farm
operation/infrastructure.”

ABC views that this is a significant enhancement to the evaluation methodology and we are pleased with
your creative flexibility given the overwhelmingly tight parameters which constrain the EA study. As we
understand the methodology, these new relative weightings will be applied to agriculture in the next
detailed planning phase, where quantifiable trade-offs can be assessed for specific route planning.

3.Rural Heritage is Absent (Page 6)

ABC will continue to advocate for protection of agricultural and rural heritage, both built heritage and
cultural heritage. The biases we noted in our two earlier briefs regarding rural heritage remain un-
addressed. Therefore, this points to a serious flaw in the current design of MTO Class EA studies, which
will need to be rectified.

“It should be noted that it is premature to assume location-specific potential heritage impacts since a
preferred corridor has not been selected.”

ABC wishes to advise you that when route planning begins we will be monitoring and acting on any
perceived threats to rural heritage presented by either the selected corridor or routes within it.

4.Questions of Need (Pages 7, 8, 9)

We continue to respectfully disagree about estimates made by both your firm and MTO regarding
population and transportation needs.

a) The population projections for regional growth are based on questionable estimates for the Greater
Golden Horseshoe and are not credible.

b) The 7/8 transportation survey, done in 2004, has a 'summer-traffic' bias and precedes the recent oil
and energy crisis which is adjusting travel patterns.

c) Truck and commercial vehicle surveys for the province may have been considered but any that
specifically apply to this corridor have not been done.

d) Your traffic projections have already been challenged by municipal experts and yet your estimates
continue to remain un-revised.

“Widening Perth Line 33 ... may provide sufficient theoretical capacity to accommodate future
demands .... [But] the use and widening of municipal roads is an area transportation option that is
not being carried forward ...” (your emphasis)

For most local residents further upgrading of Line 33 is a logical traffic management technique for
reducing density on the existing 7/8 corridor and this has been so for decades. Yet this option was
unwisely ruled out even before the first set of corridor options were presented in the summer of 2008.

C / O 3 6 4 9 R O A D 1 0 7 , R . R . # 2 • TAV I S T O C K , O N • N 0 B 2 R 0
PHONE: 519-655-2613 • EMAIL HWY7AND8@GMAIL.COM
5.Drainage (page 10, 11)

“The engineering standards for this work are rigorous state of the art requirements of the MTO
Drainage Manual, which is used as a reference by many authorities including many municipalities.”

ABC does not dispute the quality of professional engineering standards to be applied but ABC is
concerned about their actual field implementation. The experience of many farmers is that MTO road
contractors do not satisfactorily complete drainage obligations or else they do not understand their
central importance.

ABC very much appreciates the undertaking and commitment by MTO to pay for the costs associated
with system modifications by licensed drainage contractors to mitigate impacts on agricultural private
tile drainage systems.

However, MTO is asking all affected municipalities and private land owners to 'have faith' in its
professional staff regarding their planning for drainage and to 'believe' that road contractors will
understand and complete all the work to the satisfaction of affected parties. To protect affected parties,
ABC will continue to press for a viable option for 'peer review' of any drainage plans devised for the
selected corridor and route.

6.Public Consultation (Page 11, 12, 13)

Despite your protestations about the reputed efficacy of the PIC's, ABC will continue to ask for formal
presentations by the consultants and MTO followed by question and answer sessions as an alternative
to the PIC’s. We believe that communities need to hear their voices together. We very much appreciate
that the consultants and MTO staff have from time to time agreed to such formal meetings and hope
they will be open in future to such alternatives.

The extension of PIC's to 9:00 p.m. was duly noted by ABC and was seen as a positive step to encourage
rural participation. The consultants and MTO should also be mindful that the end of June is one of the
most hectic periods in the farm calendar.

Conclusion

ABC remains committed to seeking solutions for Highway 7/8 alternatives that will minimize the
impact on the agricultural land base and on agricultural businesses while still encouraging future road
development and enhancing public safety. We thank you for your attention and for this opportunity to
express our positions.

Linda Dietrich p.p.

Agriculture Business Community of Perth East, Perth South and Wilmot West

C / O 3 6 4 9 R O A D 1 0 7 , R . R . # 2 • TAV I S T O C K , O N • N 0 B 2 R 0
PHONE: 519-655-2613 • EMAIL HWY7AND8@GMAIL.