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AGRICULTURE BUSINESS COMMUNITY Chapters: Perth East, Perth South & Wilmot West Community Report Volume 3

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AGRICULTURE BUSINESS COMMUNITY Chapters: Perth East, Perth South & Wilmot West

Community Report

Volume

3

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A G R I C U L TU R E BU S I N E SS C OM MU N I T Y

Submitted to the Ministry of Transportation and AECOM for the response period ending Feb. 6th, 2009.

Agriculture Business Community c/o 3649 Road 107, R.R. # 2

Tavistock, ON N0B 2R0 Phone 519.655.2631 • Fax 519.273.6367

Email [email protected]

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Table of Contents

1. Introduction 2. Flimsy Evaluation Techniques Used to Select the Three Corridors 3. Agricultural Land Receives Lower Weighting in Decisions 4. Rural Heritage is Absent in the Evaluation 5. The Question Of Need

a. Traffic Volume b. Truck Transportation Factors

6. Drainage 7. Public Consultation

8. Summary

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Introduction

he following represents the views and recommendations of the Agricultural Business Communities of Perth East, Perth South and Wilmot regarding the Short List of Corridor Alternatives.

These alternatives were presented at the Public Information Centres in November and December 2008 as part of the Highway 7&8 Transportation Corridor Planning and Class Environmental Assessment Study.

We also make recommendations to set the parameters for future phases in this work.

Our first brief to the Consultants and MTO was intended to enlighten the planning team on the nature and reality of today�s agriculture business within the study area. The business data in that report still stands and is relevant to this stage in the planning process. The section on population projections is referred to in this submission. In this report we identify serious flaws in the development of the Short List of Corridors and flagrant biases against the rural community in the weighting of pros and cons for the different options. Furthermore, we identify the neglect of critical items that are almost completely missing in the consultant�s list of criteria that are fundamental to the development or upgrading of any highway corridor.

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We recommend: R1 The work to be approved by MTO in Highway 7&8 corridor planning and

development needs to: 1. Recognize agriculture as a business 2. Protect prime agricultural land (Canada Land Inventory Class 1, 2 & 3) for the business of agriculture 3. Minimize the impact on agricultural business enterprises 4. Assume financial responsibility for all drainage costs of highway development, before and after construction

5. Acknowledge and protect our rural heritage. We believe these principles need to drive the planning process for future highway development within this study area. They represent more than idle words. They represent this community and our livelihoods.

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Flimsy Evaluation Techniques Used to Select the Three Corridors

The intent of this study is to define a specific route for highway 7&8. MTO representatives and the project manager for the consulting team acknowledge that wherever the final route is located it will disrupt lives and businesses of some members of the Agricultural Business Community.

We are therefore alarmed that the step to identify the short list of possible corridors is based on such flimsy arguments. With the payment of $1,000 to $800 per diems for professional and technical staff, we expected the consulting team to produce a higher level of information on which to base decisions. The process developed to move this project forward appears methodical but in practice is questionable with the provision of subjective information that lacks sufficient detail to make informed choices. The consultants identify 27 options in the four highway sections that are assessed and then propose three corridor options.

Section 1: From West of Stratford to Highway 7 - 4 options Section 2: Highway 7 to East of Stratford - 8 options Section 3: East of Stratford to West of New Hamburg - 7 options Section 4: West of New Hamburg to East of New Hamburg - 8 options

The study screening criteria developed to review the long list and select the short list of alternatives include the following categories and sub-categories: ! Natural Environment Factors - Terrestrial Ecosystems : Minimize loss of provincially Significant Wetlands (PSW), Areas of Natural

and Scientific Interest (ANSI), Environmentally Sensitive Areas (ESA) and core woodlots - Fisheries and Aquatic Ecosystems, surface water : Minimize number of stream crossings

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! Land Use and Socio- Economic Factors - Land Use - Resources: Minimize loss of Canada Land Inventory Class 1,2,3 agricultural land - Land Use Planning Policies, Goals, Objectives: Minimize loss of approved development lands - Land Use- Community, Industry: Minimize removal of existing development (the definition of

development does not equate economic activity) ! Cultural Environmental Factors - Built heritage- minimize loss of heritage buildings - Cultural Heritage Landscapes � Minimize loss of amenities in heritage downtown areas ! Transportation Factors. - Network Connectivity: Minimize out of way travel - Mobility & Accessibility: Proximity of corridor to population centres

Despite the complexity of these screening criteria, there is no solid empirical information provided to gauge the possible impact of each of the 27 options. The report claims that the fundamental principle underlying all of the screening criteria applied to all categories is to �Minimize loss�. Yet in the case of class 1, 2 &3 farmland no land acreages are provided or explanations provided to clarify their selected options! Instead, evaluation decisions are made on the basis of descriptions such as� significant loss, majority, fewer, lower potential�. Fewer than what? Significant to what? How can we understand the impacts of each option if we are only provided with generalities in the form of weak adjectives? The problem for our community is that no detailed and comparable information is provided to gauge each option. The stated screening criterion applied to land use is to minimize loss of Canada Land Inventory Class 1, 2 & 3 agricultural lands. So how many hectares are we talking about? In our first Brief to MTO dated September 30, 2008 we clearly pointed out the value of agricultural business within the study area and yet this corridor review analysis doesn�t even identify the simple number of agricultural businesses that will be affected by each option. How are we to understand the impacts of each option if we are only provided with generalities? Table A1 provides a sample of one of the consultant�s options. It shows the results of their screening analysis and it identifies our expectations of the minimal level of information required. No business within the agricultural community would risk their future on the level of information provided in the short list of corridor alternatives.

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We have no desire to slow the planning process down however as we will be the ones affected and living with the results. We are not prepared to have the study move one step further in the process to an outcome based on these questionable results. The planning process defined by MTO and the consultants may be effective but it must be accompanied by quality data to support the movement to a next step. This is not the quality of decision data we expect. Therefore, we recommend that the MTO: R2 Require the consultants provide a revised level of information based on

addressing the points raised in Table 1 for each of the 27 different options for the community to review and comment on prior to the selection of the preferred corridor.

R3 Require the consultants to develop more precise categories of evaluation for

use in their selection of the preferred corridor and a higher level of empirical comparative data to be used in their review and presentation of the preferred routes within the selected corridor.

While the consulting team acknowledges that the final route will disrupt lives they are prepared to move the study one step closer to the selection of final route with the use of a very flimsy analysis. We are asked to trust their judgment without clear information to substantiate their recommendations. We trust that our Municipalities and the residents within the corridors will want the screening criteria used in the analysis of the corridors to be an accurate and objective review of the collected data so the implications of the proposed corridors is understood by all residents. We also trust that the Province will require more than weak adjectives to guide and direct this process.

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Agriculture Land Receives Lower Weighting in Decisions

A hidden bias or weighting appears to be attached to some of the criteria but this weighting process is not reflected in the text.

Upon careful review of the 27 options, we note that only nine options within the four different corridor sections are recommended to be carried forward:

• Only one option (Section 4 the South By-Pass Corridor 1) would pose potential effects on a Provincially Significant Wetlands (PSW).

• Only two options have segments within an Environmental Sensitive Area (ESA) (Section 2 South By-Pass 1 &2)

• Only four corridor segments are within core woodlots (Section 3 � South corridor 1 and Section 4 � South By-Pass Corridor 1)

In ALL cases we are not provided with any real estimates of what is affected .e.g. Is it one hectare or is it all of an unknown acreage.

There is not one option that does not impose on the screening criteria defined as the protection of agricultural land. The majority of the options to be carried forward are defined as �majority of corridor within agricultural lands�. The texts of two of the options that reduce agricultural lands imply that they will minimize the impact on agricultural land as these options are near the rail line. The text reads �utilizes lands previously disturbed adjacent to the railway corridor�. The railway corridor was constructed in the 1850s and this hardly seems relevant.

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Most options are recommended to carry forward as there is no encroachment on Areas of Natural and Scientific Interest (ANSI), Environmentally Sensitive Areas (ESA), and Provincially Sensitive Wetlands (PSW), yet these same options indicate that the majority of the corridor options are within agricultural lands and recognize there will be �moderate or significant loss of Class 1 agriculture�. The reader can only conclude that agricultural resources are the second or third cousin to Areas of Natural and Scientific Interest (ANSI), Environmentally Sensitive Areas (ESA), and Provincially Sensitive Wetlands (PSW). It is also clear that a designation of �Provincially Significant� only counts if it is for areas of natural and scientific interest or provincially significant wetlands: but not NATIONALLY significant designations. Agricultural lands are designated based on a National system for land classification, whereas ecological significance is developed from a provincial perspective. When class 1, 2 and 3 agricultural lands are lost to development, they are lost to the province and to the country as well as the community. Surely the importance of nationally significant agricultural land should have at least an equal priority and weighting in the case of this study, to a provincially significant designation. If the Senate of Canada can foresee the value of protecting agricultural land for Canadians surely consultants working at the regional level should reflect these national priorities? 1 Therefore, we recommend that the MTO: R4 Require the consultants to rank the potential loss of class 1, 2 and 3

agricultural lands with the same subjective and objective weight as the potential loss of other ecologically recognized landscapes of provincial significance.

R5 Require the consultants to clearly identify and recognize the weighting

strategy used in their ranking between and among these natural resources for a more transparent community review. Transparency should be there for all factors directing the decision making process.

1 BEYOND FREEFALL : HALTING RURAL POVERTY, Final Report of the Standing Senate Committee on Agriculture and Forestry - June 2008

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Rural Heritage is absent in the Evaluation “Family farms serve a larger purpose than agricultural production …. They are the core foundation of community life.” – Glen Elder Jr. University of North Carolina.

Cultural landscapes are those landscapes made or modified by humans in the course of their daily lives. Cultural landscape has been referred to as nearly everything that we can see when we go outdoors. Moreover, all human landscape has cultural meaning, no matter how ordinary that landscape may be. In Ontario, cultural landscapes have been defined as �the use and physical appearance of the land as we see it now as a result of man�s activities over time in modifying pristine landscapes for his own purposes. A cultural landscape is perceived as a collection of individual man-made features into a whole�.

The screening criteria for this study recognizes �Built Heritage� and� Cultural Heritage Landscapes� but it would appear that in the eyes of the consultants, these attributes are ONLY found in the urban areas of the planning area. In the rural environment they only note the Fryfogel Inn, our churches and cemeteries.

The screening criteria are weighted in favour of the urban environment and against the rural environment. In the description of the screening results in the summary for each option, the loss of heritage areas or the potential displacement of

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heritage buildings and amenities in the urban environment is identified as part of the rational to not carry forward an option. Yet, if you look carefully, agricultural land comes with homes, barns, outbuildings and settlement patterns that date back to the early 1800s. Our cursory review of rural heritage within one of the suggested agricultural corridors up for potential road development shows these features. Of the homes reviewed 18 out of 26 homes are over 100 years old. 54% of the homes are made from brick, 31% are constructed of stone, 12% are frame and 3% are original logs. Many of these brick homes were built from brick made right here in the area. �Some of the first brick houses in South Easthope were built from the local clay and for many years, brick making in the northwestern part of South Easthope was a thriving industry.� 2 Since this area was laid out and surveyed by the Canada Company, our roads are the original roads set out by �the survey party � surveyor Mahlon Burwell and included surveyor John McDonald and William �Tiger� Dunlop, the Canada Company�s warden of the forests.� 3 The eastern border of the Huron District falls on the present day boundary of Wilmot and Perth East. The Huron Tract was the property of the Canada Company, and by 1837, 25,233 acres in South Easthope, 27,560 acres in Downie, including roads, had been surveyed. By 1838, the Canada Company had paid 1738 pounds 10 shillings to open a sleigh road between the townships of Wilmot and Goderich.4 The Development costs of an up-graded highway 7 & 8 will be much higher. Once the Huron Road was constructed (Highway 7 & 8 is part of this road), surveyor John McDonald set out to lay out the first concession on each side of the road. The Canada Company had developed a new survey system for its townships. This was based on a 1000 acre section surrounded by road allowances. Each section or block would contain ten 100 acre farm lots in two rows of five each. The four sides of a section measured 1 ¼ miles each. This meant that each farm was ¼ mile (20 chains) wide and 5/8 mile (50 chains) deep.5 These 100 acre farm lots are still recognizable on the landscape today. Even as property has changed hands a cursory discussion with residents point out how easily the boundaries of these farm properties can be identified.

2 Country Roads, The Story of South Easthope 1827-2000; p.10

3 Country Roads, The Story of South Easthope 1827-2000; p. 2 4 Canada Past, Present and Future, WH Smith,, Vol 2 1851 (. p-156-157)

5 Country Roads, The Story of South Easthope 1827-2000; p. 3

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Many of the original farmsteads still have the stately old brick homes to remind us about the past. These are the homes that show up in designer magazines and are the envy of many taking Sunday drives through the countryside. Therefore, we recommend that the MTO: R6 Require the consultants to develop screening criteria for Rural Heritage both

representing built rural heritage and cultural rural heritage landscapes and include this evaluation in their screening criteria for the 27 options and in the next steps of this planning process.

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Questions of Need Traffic volumes seem to be driving the need for this planning process. It is also presumed that traffic volumes and accident trends will determine when the provincial government allocates funds to develop the chosen route. Traffic volume figures need to be an accurate reflection of present circumstances and wise projections for the future.

Trucking firms move industrial, retail and agricultural goods, and more needs to be known about the daily travel patterns of trucks on the existing 7/8 corridor and south-west.

Traffic Volume We understand that traffic volume projections are developed with a review of historic traffic volumes, based on MTO records and population projections. In the ABC brief dated September 30, 2008 we reviewed population growth and decline within the study area and cautioned the consultants about the application of population projections based on the Greater Golden Horseshoe Study Perth East and Perth South are showing small declines in total population and these two municipalities remain dominantly agricultural. No readily available evidence

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currently exists to support the notion that population growth in any part of Perth County may suddenly accelerate along the lines of Waterloo region. While recent projections for the Greater Golden Horseshoe (GGH) suggest massive population growth in various Toronto centered regions, these trends do not currently extend to Perth. The GGH does not mirror the conditions, population, growth and development conditions of the majority of the study area. Neither do the conditions of Kitchener, Waterloo and Cambridge mirror the development or potential for the City of Stratford. Census statistics are generally used as a basis for population projections by cities, towns and other municipalities. However, population projections are often quite optimistic. Projections are based on 'assumption models' and the main problem is that people move around and make other decisions that cannot really be reflected in these models. Most projections are simply best guesses. Therefore, we recommend that the MTO: R 7 Require the consultants to re-evaluate and confirm their population

projections for the study area based on accurate information and discuss their findings with the County of Perth and the Regional Municipality of Waterloo BEFORE proceeding to input this information into the development of the traffic volume projections for the year 2031.

It is our understanding that traffic volumes drive these projects and it is projected traffic volumes that will trigger the type of highway design to be proposed and built. The highway design will determine the land requirements for highway construction and in turn this will impact the agricultural community. Traffic volumes and accident reporting will also be used as part of the argument for future timing for the provincial government to support funding for highway development and how long the community and affected landowners are held ransom before any action is taken. It has come to our attention that the MTO and consultants for the Highway 7&8 study are presently in consultation with the engineering staff of the Region of Waterloo to discuss and confirm the traffic volume numbers. Part of this discussion is to review and confirm variations in their different model calibrations so as to confirm the data to be used in the next stages of this work. We understand that the existing numbers tracked by MTO in their Average Annual Daily Traffic (AADT) and similar methods of traffic volume tracking used by the Region are being discussed. The Region of Waterloo prepared reports dated November 18, 2008 and January 27, 2009. (Report P-08-110 and P-09-010) and submitted them

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to MTO. These reports both question the traffic volumes estimated by the consultant and propose interim solutions to be examined. The interest of the Region of Waterloo stops at their boundaries and their modeling for future consideration will also be focused on meeting the needs of their taxpayers. The fact that the major length of the proposed corridor is outside of their jurisdiction is not their concern. Presently the consulting team, MTO and the Waterloo Region professional engineering staff are developing and reviewing traffic volume estimates as the precursor to highway design. This work will confirm which traffic volume and population projection estimates will be used to develop the MTO required projection to the year 2031. These are internal working documents and not available to the public. We understand that similar meetings are NOT being held with Perth County or the Townships of Perth East or Perth South. The largest portion of the proposed highway is in Perth County, yet the validity of the data being used to determine the need for this project is being confirmed through traffic models developed by and for the Regional Municipality of Waterloo. The models used by the MTO and the consultant are without adequate input from Perth County. The MTO data clearly states that the AADT in the Region of Waterloo is almost double that in the highway stretches in Perth County and they are also growing at a more significant rate. These figures show that the Average Annual Daily Traffic from Perth Road 107 (Shakespeare) and Waterloo RR1 have only increased 1.38% per year for the period 1988 to 2005 (from 8,400 to 10,600). The AADT for the highway section from Shakespeare to the Stratford City Limits have only increased 1.5% per year (from 7,900 to 10,200). This same data indicates the most significant increase within the length of the study area is within the Region of Waterloo where total AADT almost doubled during this same time period. Therefore, we recommend that the MTO: R 8 Require the consultants to include representatives from Perth County, the

Municipality of Perth East and Perth South in their discussions and deliberations regarding decisions on traffic volume data and population projections that will impact our community.

The Agricultural Business Community relies on Perth County, the Municipality of Perth East and the Municipality of Perth South to see that the interests of the community are served. They cannot be served unless our local governments are given the opportunity to contribute to this planning process at critical points where technical decisions are being made that will direct future actions.

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Truck Transportation Factors For several years local observers have commented on increasing concentrations of truck and passenger vehicle traffic on the existing two-lane highway 7/8 between the train overpass where the road narrows to two lanes and Shakespeare. It is an item of local lore that passenger vehicles often take risks on this section in order to pass trucks that are generally observing the speed limit. Truck drivers, in turn, are said to see it as especially hazardous because certain hills and valleys limit forward visibility and reduce truck momentum which invites cars to attempt passing, sometimes blindly. Previously, concerns were also expressed about large transport trucks passing through downtown Stratford and along Ontario St. Last year the City of Stratford made extensive repairs to Ontario St. on either side of Romeo St. and upgraded that section to four lanes. Prior to that work being done the City of Stratford passed a by-law (Annex 1) and notified trucking firms that a truck bypass route was being brought into effect. Signage was then posted to prevent westbound trucks from crossing C. H. Meir and heading downtown and to prevent eastbound trucks from crossing O' Loane Ave. Exceptions applied for local deliveries and pick-ups but violations were subject to fine. We believe it is important to have some idea of perceptions of trucking firms regarding their needs and the proposed highway and corridor alternatives. The agricultural business community relies on effective and efficient truck activity both for inbound shipments and for outbound deliveries. Increasingly, very large transport trucks are being parked in fields when grains are harvested and these loads are then driven long distances and consolidated in shipping terminals, rather than at local 'elevators', as in earlier decades. Large livestock and poultry shipments are a daily feature of trucking in this corridor. Under today's 'integrated management practices' many farm buildings are only used for one segment of the life-span of a cow, or pig or chicken and the whole barn may be emptied and turned over every three or four months as new stock arrives and as current stock moves to the next linking facility in the integrated chain. The high numbers of dairy farms in the area, require milk pickup every other day. Consequently, large volumes of milk (281,oo0 litres)6 are picked-up daily, by a variety of milk transport trucks. Pigs are consolidated at the stock-yard at the junction of Lorne Ave and Line 33 and also the stockyard on the Perth/Oxford Road. Consequently, effective truck movement is a common retail, commercial, industrial and agricultural concern for Perth County and its cities. Major resources would be needed to

6 Dairy Farmers of Ontario data

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mount a comprehensive assessment of the needs of trucking and transport industries but this is well beyond our limited means. So we asked ourselves, what can we do? Our area is home to several large regionally based trucking firms, and notably, these are independent family-based operations with exceptional reputations in their industry. We decided to approach a small sub-set of these companies and solicit their perceptions about existing road conditions and patterns of travel as well as their reactions to MTO corridor alternatives. A simple interview guide was developed (Annex 2) and principals in five firms were approached for face-to-face discussions. Their comments to our questions are distilled into a few relevant categories in the next sections. We do not claim these comments are statistically representative but they certainly are qualitatively accurate. The absence of any public information in the MTO/TSH study on the perception of needs for truck and transport industries makes these inputs all the more relevant. 1. What use is made by trucking firms of the existing highway 7/8 from New Hamburg to Stratford and beyond, or vice-versa? Very little truck activity actually follows a direct route from New Hamburg to Sebringville. Use of the 7/8 corridor by trucking firms very much depends on the location of the main assembly yard for each firm. The firms with truck yards east of Stratford, in say New Hamburg, send the majority of their trucks out eastbound on 7/8. Of course their trucks also travel westbound but their destinations are usually the bridges at Windsor and Port Huron. Therefore their drivers turn onto the Perth/Oxford Rd and travel through Tavistock and then take 26 (Harmony Rd.) to Highway 7 and subsequently follow various routes through either Embro or Thamesford to reach 401/402. Only a tiny fraction of their mileage goes westbound up either the # 8 corridor or across country to the # 4 north-south corridor. Firms based within Stratford tend to move goods out of town for Stratford industries, such as auto parts suppliers. They use Romeo St., Lorne Ave and Erie St. to access portions of 7/8 and principally travel in one of two directions. They either go eastbound via Lorne Ave. and Line 33 ( Pork St.) to Line 107 and then north to Shakespeare and 7/8 or south on # 59 to Woodstock and beyond, or else they go southwest via Lorne to Erie St. and # 7 and then travel via Embro or Thamesford to 401/402 and on to London and the border bridges. Other firms are based west of Stratford, in the # 8 corridor, and for them Stratford can be either a destination or an impediment. The most common patterns for 'getting around' the city are for southwest bound trucks to use Avonton Rd. (130) and St. Paul's Rd. (20) to #7; for eastbound trucks to use Line 36 and then Line 37 to Line 107 into Shakespeare; and for southeast bound trucks to use Avonton Rd. to Lorne Ave. and then continue on Line 33 (Pork St.) to Line 107 and then down to Tavistock and 59.

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Again, we reiterate that the majority of regional truck traffic on or close to 7/8 does not follow a direct route from New Hamburg to Sebringville or vice-versa but rather it scatters widely toward other multiple destinations, mainly southwest. 2. What are the top traffic or safety concerns for drivers using the current highway 7/8 corridor? Trucking firms report that drivers of passenger vehicles on that highway simply don't understand what a truck can and cannot do. It's seen as a matter of respect. Passenger cars are seen as engaging in unsafe passing activity on the two lane sections of 7/8, particularly from the train trestle on. Travelers seem to get into a 'four-lane' mind-set and then don't rethink this when 7/8 reduces to two lanes. Truckers report that this is really a speed enforcement issue and not about the quality of the roadway or the traffic volume or the traffic lights. Truck drivers follow prescribed routes and distance reduction is critical to gas mileage. Traffic lights and stop signs are not a problem for truckers but blind hills and hidden entrances are hazardous when cars seek to pass them. The current Stratford truck by-pass using O' Loane Ave. on the west side is thought to be inadequate. The corner radius is not adequate, there are no paved shoulders, there is no centre-line, there are no rail crossing barriers, and it is adjacent to new residential areas. The corner at Lorne Ave is at the bottom of a hill which is a concern in winter. When O' Loane is closed due to weather conditions the only option is to go downtown. This route is not presently viewed by truckers as a real truck by-pass. 3. Is a new four lane controlled access highway from New Hamburg to Sebringville necessary? Truckers indicate that in the best of all possible worlds every route would have four- lane controlled access but most recognize that this is an unlikely possibility. Most said 'absolutely not' to this question, even those based west of Stratford, as there is no justification in their view based on truck volume. Their perception is that Stratford is growing slowly and there is very little truck traffic into Stratford that is seeking to get beyond it. The majority of their concerns are about getting better routes built towards southwest and southeast destinations. Trucking firms recognize that added infrastructure is an asset that could make Stratford more attractive for more manufacturing and tourist sector growth. Truckers also believe that any new southern bypass must have better access routes into the city's industrial areas. 4. What options to a fully controlled access highway might be useful? Trucking firms focus on transportation pragmatics rather than grand designs. Their suggestions about the current 7/8 are all in the domain of provincial responsibility.

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• Paved shoulders and passing lanes, even on two lane highways, give truckers

some room to maneuver when cars attempt to pass unsafely. These changes could be made to the existing 7/8 corridor, particularly from the train trestle to Shakespeare.

• A three lane system, on the existing 7/8 corridor, with alternating passing lane

sections from the train trestle to Shakespeare or even all the way into Stratford was indicated to have immediate impact from a safety perspective. In the stretch of road east of Shakespeare there are some hills and dips which could be flattened out during road improvements to assist in forward visibility.

• The section of 7/8 from Stratford to Shakespeare could be made into a four-lane

boulevard. This could be combined with a third �passing lane� added to the existing 7/8 corridor from Shakespeare to the train trestle and the trestle widened and upgraded. Shoulders on the three lane section could also be paved.

• Further separation of truck and car traffic at the east entrance of 7/8 to Stratford

from where the four lanes begin to C. H. Meir would be helpful. A two-lane southern truck by-pass (a 7/8B) linked to an upgraded Lorne Ave. by designating some existing roads as provincial and modifying them.

• Better enforcement of speed and traffic regulations were also indicated.

5. If changes to other roads between New Hamburg and Stratford could help trucking firms in the next two to five years, what would it be? Trucking firms use many county and city roads to access various portions of 7/8. These suggestions involve the responsibilities of the City of Stratford and the County of Perth. However, there are important aspects of regional transportation that will be influenced by any provincial decision on the 7/8 corridor. It becomes obvious from the comments below that an appropriate solution to the 7/8 corridor must involve coordination and collaboration of several parties and probably some transfer of road responsibilities.

• Truckers would prefer to see some current county roads built up and weatherproofed or converted to provincial use. They encourage parties to make them wider, with paved shoulders etc. so they would be safer and allow for potential improvements to roads further west and south-west.

• For example, truckers would prefer an upgraded and paved continuation of Pork

Street (33) all the way to the Perth/Oxford Rd to get to and from the Stratford industrial area. If that road were not subject to weight limitations, trucks heading south and west would use it more often and this would reduce the tendency to go through Tavistock. Lights at 107 and Pork (33) were also highly recommended.

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• Failing that, large directional signs were recommended coming into Shakespeare

from the east indicating that trucks need to turn South on Rd 107 to get to the Stratford industrial area via Line 33.

• The trucking firms located on the Highway 8 corridor west of Stratford would like to see development of Lines 37 and 36 north of the current 7/8 to increase economic development for the north end of Stratford, as well as Milverton and other towns west.

• They suggest that Lorne Ave. desperately needs a third lane or else a four-lane

upgrade and the four-lane sections of Erie St. are too narrow for trucks. • The O' Loane/Lorne Ave temporary truck by-pass is unsafe, and needs

immediate attention either to be fixed or else rerouted.

6. Other comments? Truckers recognize that infrastructure is critical to economic growth. They are in favour of incremental changes, such as improvements and upgrades to existing roads rather than a four lane end-to-end solution. They believe that signage must be done correctly and put in the right place to get trucks efficiently into the city. They think there is no need for a full-face reconstruction when only a face-lift is required. Therefore, we recommend that the MTO: R 9 Instruct their consultants to use this brief overview as a qualitative guide

to pragmatic solutions offered by everyday highway users, and that MTO and the consultants follow our work with more in-depth probing of trucking firms, their travel patterns and their actual needs.

R 10 Actively discuss with Perth County and the three municipal councils the

re-designation of certain county and township roads to create some two-lane 7/8 B truck corridor options that would further reduce truck volume and use of the existing 7/8 highway.

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Drainage

The consultants to MTO have minimized the role of drainage in the development of various corridor options and almost completely ignored the Municipal responsibility for drainage.

This is a major missing element in the Class EA assessment as undertaken to date.

It is imperative to all taxpayers that the effective movement of rain water and snow melt be a major component of any environmental assessment. At present, it is not. In the background report, prepared by MTO consultants - Report F (Part 1) Environmental Conditions and Constraints - watersheds, creeks and drains are placed under the heading Fisheries and Aquatic Ecosystems. They are given only passing attention in a brief one page description (p.31) about surface water movement into the Grand and the Thames. Water drainage is also completely missing as an element of Municipal Infrastructure/ Public service (Section 4. 2. 7 page 46). Heavy storm water management as well as the movement of snow melt during successive winter thaws has, in recent years, become a prominent feature of regional weather. There are always up and downstream implications, often covering many jurisdictions. Any newly paved corridor, but particularly a four lane paved highway, will have significant drainage requirements and will effect both agricultural drainage patterns and municipal drainage infrastructure in villages and towns. Four lane paved highways always produce escalating volumes of surface water and increase flash flood loads.

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Municipal drainage maps indicate the existing 7/8 corridor from New Hamburg to Sebringville as well as the recently proposed corridor just south of the railway line require our water to move east, west, north and south. Seven watersheds are affected; the Nith River, Horner Creek, North Woodstock, Trout Creek, Avon River, Black Creek and the North Thames Branch. Countless municipal and private drains are included in these proposed corridor areas some being headwaters to the seven watersheds, and, therefore, at the top of the flow. Potential drainage issues are three-fold:

. The effect of a four lane highway corridor on municipal drains;

. The effect on private drains;

. The associated drainage costs to individual landowners resulting from highway development.

Municipal drains are an important element of municipal infrastructure requiring constant care and attention to avoid liability disputes. They are a community resource requiring long-term stewardship. Good municipal drains are an essential requirement for discretionary private drainage decisions, and both have an enormous impact on land use and its valuations. The local experience of agricultural business operators with farm drainage and expanded highway development has not been uniformly positive. Often an increase in highway surface water flow involves surprising turns of events and hidden costs that can take years to resolve.

. Private drains may become overloaded or crushed or cut off from their outlets and ditches; . Sub-mains and extensions may need to be developed across large cultivated fields; . The recharge of deep wells may be affected; . The availability of water in shallow wells and stock ponds may be affected.

A drainage specialist with OMAFRA informs us that the widening and expansion of Highway 16 in Eastern Ontario into Highway 416 parallels circumstances of the proposed new highway 7/8 corridor. The development of Highways 416 and 403 have set precedents for MTO where financing for municipal governments and individuals was made available on matters of drainage. It is our understanding that under common law surface water generated by large infrastructure projects, such as highway construction, has no natural right of drainage. The key factors under consideration then are the concept of �sufficient outlet�, as referred to in Section 15 of the Drainage Act and �subsequent connection� to drainage works which is affected by a change in land use as noted in Section 66 of the Act.

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We trust our municipality will want to thoroughly assess the implications of highway expansion for our drainage infrastructure. Therefore, we recommend that the MTO: R 11 Agree that drainage is a serious municipal concern, particularly for any four

lane expansion, and that assurance will be given to municipal councils, before any approval of the selected route, that surface water volumes from the proposed route are manageable and not disruptive to municipal drains. In other words, assurance is needed that surface water can be brought to sufficient outlet.

R 12 Agree that for each existing municipal drain impacted by the highway

project, the municipality should appoint an engineer under the Drainage Act to investigate the impacts of the highway project on the municipal drain, specify in the engineer�s report any necessary changes to the drain and ensure that the drain has the capacity to accommodate the additional flows. MTO agrees to pay the full cost of this work.

R 13 Agree to cover the entire costs for every adjacent landowner and

agriculturalist whose private drains may be affected by the selected route to facilitate them in selecting and hiring the services of an independent tile drainage contractor, licensed under the Agricultural Tile Drainage Installation Act, to assess and resolve any potential impacts on private drainage systems including laterals, ditches, culverts, sub-mains and other items associated with any potential new drainage demands.

R 14 While there are many municipal drains in the area, it is possible that the

additional runoff generated by this project may create areas that have no suitable drainage outlet into an existing municipal drain. In those situations, MTO agrees to not direct their water onto the adjoining land. MTO agrees to petition under the Drainage Act for a drainage system that will properly drain the water generated from the new highway.

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Public Consultation

We understand that the consultants are following the directives developed by MTO in their Request for Proposal (RFP) to undertake Public Information Centers (PIC) in each of the planning phases. While the community appreciates the opportunity to comment on each of these proposal stages, we find the format of the PIC unsatisfactory. The individual natures of each of the conversations and the great variation in the questions that are asked have led many to conclude that different answers are being provided to similar questions. We appreciate that the very nature of one-on-one communication lends itself to different interpretations; however, as the study results are becoming more focused: We recommend that the MTO: R15 Direct the consultants to change the format of each of the future planned

PICS. Future community gatherings should include an opportunity for individual review of the options and conversations with the consultants followed by a Public Meeting format. The public meeting should include a formal presentation by the consultants of their findings to date along with their recommendations followed by a question and answer session with the public.

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Summary

The members of the Agricultural Business Community appreciate the opportunity to respond to the ongoing work of the Highway 7&8 project and we look forward to receiving a response to our recommendations.

Our Brief outlines several immediate actions to be taken by the consultant before the selection of the preferred corridor is presented to the community in the spring of 2009 and we have also highlighted a new form of public presentation for future planned events that we believe will be more useful to the community in our ongoing dialogue.

When the final corridor is proposed followed by individual routes, the selection process must be clear, the rationale for actions need to be transparent and inclusive of the needs of the Agricultural Business Community as outlined in our Brief dated September 30, 2008 and the recommendations in this brief.

Data must be provided to substantiate proposed new directions. The consultation process must not just occur to be checked off from a list by the consultants. Consultation must be based on the provision of opportunities to be sure the community understands the repercussions of the proposed work. We will be living with the results, not the consulting team or MTO staff. We want the best solution.

We have also included recommendations for the MTO to set in motion prior to the selection of the final route whereby they will agree to become active participants in the payment of professional and technical fees, to address drainage issues that will arise from route development. The taxpayers will be paying for the road development. Individual taxpayers along the chosen route should not also be asked to carry the financial liability resulting from highway development.

We look forward to receiving a written response to each of our recommendations and participating in the future planning for the Highway 7&8 Corridor.

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ANNEX 1 - Stratford By-Law 20-2008

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Annex 2

Regional Truck and Freight Transportation - Highway 7/8

Question Guide

1. Do your firm's trucks use the existing highway 7/8 from New Hamburg to Stratford, or vice- versa? If so, how often?

2. What are the top traffic or safety concerns when your drivers use the current highway 7/8 corridor? 3. Imagine your trucks are west of Stratford traveling eastbound on highway 7 and they need to get beyond Stratford - what route would they likely take? 4. Imagine your trucks are west of Stratford traveling eastbound on highway 8 and need to get beyond Stratford - what route would they likely take? 6. Do you think that a new four lane controlled access highway from New Hamburg to Sebringville is necessary? 7. What possible options to a fully controlled access highway would you see as useful? 8. If one significant change to roads between New Hamburg and Stratford could help trucking firms in the next two to five years, what would it be? 9. Any other final comments? List of Firms Interviewed Luckhart Transport; Erb Transport; Grant Transport; Woodcock Bros., Steed Transport.

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