The CSB | Mysite

The COMMUNITY SAFETY BUILDING

Or, The Community UN-Safety Building ?

Most of the IMPORTANT DECISIONS about the nature, size, location and COSTS of the proposed Sidney CSB appear to have been made 'in camera', just like the GATEWAY deals with the VAA! The 'chickens are coming home to roost'!

COSTS HAVE SKYROCKETED from the initial '$5 - 8 Million' ESTIMATE, TO $14.7 MILLION as of late 2017, and STILL COUNTING, with the latest update on the Sidney website showing costs to now be IN EXCESS OF $16 MILLION. I SINCERELY DOUBT THAT CURRENT & FUTURE RE-ESTIMATES WILL BE LOWER !!

CONSTRUCTION PROGRESS IS ABYSMAL ! The Sidney website still shows the Expected Completion date as 'OCTOBER 2017', which is both ABSURD, and incompetent! Together with the most recent financial estimate, the NEW EXPECTED COMPLETION DATE should have been made public. TRANSPARENCY! That is what our current Council have failed to provide, in so many different situations. In the case of THE BIGGEST EXPENDITURE EVER UNDERTAKEN BY SIDNEY, which THEY chose to push through without the approval of the TAXPAYERS, it is even MORE incumbent on Council and Staff to be 'up front and honest' in telling us what is going on. I don't think they have been.

In the July 15, 2015 PNR, Hewitt Helmsing had a letter published which raised many of the issues that I continue to espouse below. Note also that he voiced his 'aircraft-related safety concerns' when the proposed location was on the Mary Winspear lands. The potential disaster situation has only been made worse by the MOVE FURTHER SOUTH ONTO THE VAA CONTROLLED LANDS UNDER THE FLIGHTPATH! And it is interesting to note that even back then he mentions an estimate of $10 million for the project.

How did we end up having to settle for such a BAD LOCATION? Was there a proper, comprehensive 'study' on the various locations, scope and costs? If one exists, why does it not show up on a simple search of the Town website?

Why did the Council take every step possible to AVOID an 'Assent Vote' process on such a major expense?

How and why did the design of the structure keep changing? How much did this add to costs?

Why are the ACTUAL costs of construction vastly more expensive than the original Town estimates? Were the estimates 'low balled', or just 'bad estimates'? Who provided the construction estimates?

Progress on construction has been excruciatingly slow! Obviously, nobody anticipated the massive uptick in general construction activity? Why not? Surely this possibility was raised by the architect?

Or, is this situation because there was an 'under-the-counter, cheap deal' which has back-fired? Did the Town get a lower cost estimate based on being the CSB being a low priority work site?

If there IS an 'aircraft involved incident' at some point in the future, what is the legal impact of our Council having ignored 'legitimate safety concerns' raised by concerned citizens? Could the Town (actually, in the end, the taxpaying CITIZENS of Sidney rather than Staff or Council members) be held liable for potentially unlimited costs on the basis that they were advised of the risks at the VAA location, yet CHOSE TO IGNORE them?

IS THE NEW CSB BUILDING INHERENTLY UNSAFE?

Or , Has Sidney 'jumped from the frying pan to the fire'?

It is worth remembering that the main reason touted for the overpowering need to build the NEW CSB was that the existing Sidney Firehall had been deemed to be 'unsafe' due to the statistical probability of structural damage due to EARTHQUAKE activity!

While I can't find an estimate for the cost of remediation of the existing Firehall on the Town website, I'm sure it would have been LESS than what we are having to pony up for the NEW one, and without having had to throw in the adjacent parking lot!

On the same basis of 'considering statistical PROBABILITIES', one would be forced to come to the conclusion that the NEW CSB location, which is undeniably 'UNDER THE VICTORIA INTERNATIONAL AIRPORT APPROACH AND DEPARTURE FLIGHTPATH', lies in an industry-recognized, definable 'Public Safety Zone', VERY CLOSE to the threshold of a MAJOR RUNWAY, which implies a significantly HIGHER RISK of 'damage and death due to an aircraft-involved incident' than if the CSB had been located elsewhere, more distant from YYJ and well off the flightpath. 'How much higher' can only be determined by HAVING AN EXPERT DO A PROPER PUBLIC RISK ASSESSMENT, which our Council and the VAA seem to be reluctant to undertake!

Safety Related Issues ignored by Council

Extracts from the Emergency Management Review (Royal Roads, 2014)

Although the HVRA is detailed and fairly comprehensive, it is outdated by a few years. While the report specifies that the Emergency Program Coordinator shall ensure the community risk assessment is updated at least every five years, the UN standard is three years.
The all-inclusive list of mitigation strategies previously identified could be further enhanced by developing and prioritizing a risk-based implementation plan.
Although the HVRA is accessible on the Town of Sidney’s website, more can be done to ensure it is extensively accessible through various media and to all staff and residents. A well-informed and engaged public adds to the overall resiliency to the town.

It does NOT appear that Council has actually acted on any of these recommendations.

The most current Risk Assessment is still 2014, despite MAJOR changes in the area affecting YYJ, Hwy-17 and local road traffic

A search of the Town website does NOT bring up any link to the 'risk-based implementation plan' recommended in the Review.

It is Council’s DUTY to maintain a proper, up-to-date RISK ASSESSMENT

As a local authority, under the British Columbia “Local Authority Emergency Management Regulation”, the Town of Sidney is required to regularly document and publish up-to-date information on:

“The potential emergencies and disasters that could affect all or any part of the jurisdictional area for which the local authority has responsibility”

and

the local authority's assessment of the relative risk of occurrence and the potential impact on people and property of these emergencies or disasters'.

As far as the risks due to 'Aircraft-involved incidents' is concerned, Sidney's published Risk Assessments DO NOT seem to meet this requirement, as they do not properly consider the relative risk of occurrence or the potential impacts of such an incident.

Extract from the Community Risk Assessment (Sidney 2005)

“Due to the proximity of the Victoria International Airport, the western portion of Sidney is more exposed to the risk of crash involving large aircraft.”

(Note : NO mention of the degree of risk, or potential consequences.)

Community Risk Assessment (Sidney 2007)

“Sidney would more likely experience a crash of a relatively light aircraft, but a crash of a large aircraft carrying more than 200 passengers is possible and should be addressed in specific plans.”

(Note : again, NO mention of the degree of risk, or potential consequences.)

Community Risk Assessment (Sidney 2014)

The highlighted section under “Implications of Airport” STILL SAYS BASICALLY THE SAME AS IN 2007, despite significantly INCREASED flight and passenger traffic at YYJ.

The 2014 Risk Assessment did recognise the increase in flight traffic, and the potential for higher passenger counts in new generation aircraft.

However, the report 'conclusion' reads :

Implications of Airport: If the likelihood of aircraft accident reflects the number of flights, Sidney would more likely experience a crash of a relatively light aircraft. However, a crash of a large aircraft carrying more than 200 passengers is possible, as reflected in specific response plans.

The underline in the above paragraph highlights and brings into question the credibility of the entire report!

The use of the word 'IF' in this context is unforgivably misleading!

Worse than that, the statement indicates a complete mis-understanding of the YYJ Safety and RISK issue. It is the increasing number of flights which drives an increase in the 'likelihood of aircraft accident', not the other way around!

A search of the Town website does NOT bring up any 'specific response plans'.

Again, NO mention of the degree of risk, or potential consequences.

Risk Assessment issues specific to the CSB

An UPDATED RISK ASSESSMENT should have:

Considered the statistical PROBABILITY of a major aircraft-involved accident at the CSB site, comparing the ‘current scenario’ (essentially bare land) to the ‘proposed scenario’ (CSB complex built on the proposed site, under the YYJ flightpath) and the ‘future scenario’ (potential impacts of the planned YYJ 264m runway extension),

and,

Estimated the change in potential IMPACTS ON PEOPLE AND PROPERTY for each of the 3 scenarios as a consequence of an incident.

The Risk Assessment should also have considered that the construction of the CSB at the chosen location will inevitably have INCREASED both the probability of an incident, and the likely severity of injuries and/or damage to property (in both runway configuration scenarios) when compared to maintaining the existing ‘bare land’ option.

Future Runway Extension Planned by the VAA

The VAA has a planned 264m runway extension which would push the RESA (Runway End Safety Area) to the absolute outer limits of the Airport lands at the 'Sidney end' by Hyw-17.

The recommendations of the Canada Transportation Safety Board are for major airports to implement the ICAO minimum 300m RESA. If the YYJ runway is extended as planned, providing this 'emergency stopping space' would NOT be possible, and the VAA may well have trouble meeting even the 150m required by TP312.

SIDNEY WEBSITE MIS-INFORMATION

Website information purporting to address Public Safety Concerns related to the CSB was CONSISTENTLY INCORRECT AND SKEWED SO THAT IT PRESENTED A BIASED PERSPECTIVE.

Despite having been presented with incontrovertible evidence that some statements posted on the Sidney website were TOTALLY UNTRUE, these statements REMAINED PUBLISHED on the site.

The VAA, the very people responsible for ensuring the HIGHEST POSSIBLE OPERATIONAL SAFETY of the Victoria International Airport, appeared to be sacrificing that goal. Merely observing ‘minimum legal requirements’ does NOT constitute a pro-active approach to MAXIMISE AIRPORT SAFETY AND MITIGATE POSSIBLE CONSEQUENCES in the event of a disaster, which it is their DUTY to do!

In addition, it would appear that all of the relevant regulations that the VAA claim to follow were created FROM THE INITIAL PERSPECTIVE OF PREVENTING THE CONSTRUCTION OF STRUCTURES OUTSIDE OF THE AIRPORT LANDS WHICH MIGHT AFFECT THE SAFE OPERATION OF AIRCRAFT! The regulations ARE NOT written from the initial perspective of 'preventing aircraft from damaging US, the people that live and work in the area around the airport'!

EVERY ONE OF THE FOLLOWING 'GEMS ' WAS POSTED ON THE TOWN WEBSITE, AND WITHOUT EXCEPTION, THE 'ANSWERS' WHICH WERE POSTED BY THE TOWN WERE AT BEST 'MISLEADING' AND AT WORST 'TOTALLY UNTRUE'.

ALL OF THESE 'MIS-INFORMATION' POSTINGS WERE ON THE WEBSITE DURING THE PERIOD IN WHICH THE TOWN COUNCIL WAS 'DELIBERATING ON THE SELECTION OF THE NEW LOCATION FOR THE CSB', AND 'APPROVING THE $10-M BORROWING' FOR THE PROJECT.

IT IS QUITE REASONABLE TO ASSUME THAT MANY PEOPLE, COUNCILLORS INCLUDED, WERE LULLED INTO A FALSE SENSE OF SECURITY BY THIS MIS-INFORMATION.

Exerpts from the SIDNEY TOWN website :

Q : “Is the proximity (of the CSB) to the runway a valid safety concern?”

A : “At the outset, this question was asked of the Victoria Airport Authority (VAA). The VAA advised the Town that the land proposed for the community safety building would comply with the Airport Zoning Regulation and does not impinge on federal safety regulations. They are supportive of the location and suggested to Sidney they the conduct their own independent risk assessment on the location.”

“Our principal architect contracted Operations Economics Inc.(OEI), an aviation and transportation consulting firm with recent and extensive knowledge of VAA operations to determine if locating the CSB in the location proposed was consistent with current best practices.”

So, before it even started, the 'INDEPENDENT RISK ASSESSMENT' assignment suggested by the VAA had somehow morphed into ‘determine if locating the CSB in the location proposed was consistent with current best practices’!

HOW AND WHY DID THIS HAPPEN? I ASKED, BUT NEVER GOT AN ANSWER!

The Town of Sidney SAYS that it commissioned the report (by OEI) to answer the CSB Safety question.

A full reading of the report will inevitably lead the discerning reader to the conclusion that , whatever Sidney may have 'intended', THE OEI REPORT FAILED TO EITHER ASK OR ANSWER THE QUESTION, but does seem to have been written to bolster the case for the VAA and Omicron proposed development of GATEWAY.

This is not surprising given that OEI had had 'recent and extensive knowledge' of YYJ, having been contracted to do work there by the VAA, which puts a bit of a 'potential conflict of interest' crimp into the implied 'INDEPENDENT' aspect of the OEI report!

Another SIGNIFICANT FAILURE of the report is that it DID NOT ACTUALLY DEAL WITH ASSESSING ANYTHING EVEN CLOSE TO "BEST PRACTICES"! The OEI report concentrated only on showing that the proposed CSB development met the MINIMUM LEGAL REQUIREMENTS of then current Transport Canada regulations, which is A FAR CRY FROM 'BEST PRACTICES' AND EVEN FURTHER FROM 'RISK ASSESSMENT'.

Wikipedia : Determining "Best Practices" to address a particular policy problem is a commonly used but little understood tool of analysis because the concept is vague (due to subjectivity) and should therefore be examined with caution’, and also notes “that the work necessary to deem and practice the "best" is rarely done.”

Other sources are similarly equivocal. One common thread of informed opinion seems to be that “Best Practice analysis” is often used by public bodies to provide CYA cover for their policy positions. Nevertheless, it seems to be generally accepted that “BEST PRACTICES”, when defined, will exceed minimum legally required standards.

So, we have a OEI report which was NOT independent, did NOT perform a Risk Assessment, and did NOT consider Best PracticesI AND WE PAID FOR IT?

Then, it would appear that Sidney staff cherrypicked sections of the report, mostly 'out of context', and posted them on the website in the form of 'Question and Answer' to try to allay legitimate public concerns about the proposed location for the new CSB.

A ‘conclusion’ on the CSB Safety issue, posted on the Town website, represented as though having been taken from the OEI report on the CSB, said:

“Therefore, constructing the new Community Safety Building in this location is consistent with current best practices.”

It is my considered opinion that this constituted DELIBERATE MIS-INFORMATION, as it does NOT appear anywhere in the report, nor is there anything in the report that could lead an intelligent reader to that 'conclusion'.

It looks and sounds like the 'Conclusion' posted on the Sidney website was 'fabricated' specifically to provide the DESIRED answer to the earlier 'Safety of the CSB location' question!!

SO, WHO MADE IT UP, and WHY?

WHO POSTED IT (or caused it to be) ON THE SIDNEY WEBSITE?

Once TOLD that the statement was incorrect, WHY was it not promptly corrected?

Q 1: Is the proposed (CSB) building on an airport flight path?

Q 2: What is the risk that the (CSB) building would be damaged by a plane crash and unable to provide service in an emergency?

A : The proposed building is NOT on the approach or departure path for runway 09/27 and is NO MORE LIKELY to be hit by an aircraft than any other building constructed in or around the Victoria International Airport. This has been CONFIRMED by the VAA and Transport Canada.

The REAL answers are:

1) The proposed CSB building IS definitely under both the approach and the takeoff flightpath for runway 09/27, as CONFIRMED in print by their own OEI Report.

2) The proposed CSB location IS much more likely to be hit by an aircraft than other buildings constructed in or around the Victoria International Airport, because it is located in closer proximity to a runway end, where the PROBABILITY of a serious incident rises significantly relative to other areas of the airport and its surrounds.

The comment that “This has been confirmed by the VAA and Transport Canada” would appear to be a total fabrication!! Proof required!

The “unable to provide service in an emergency” part of the original Question 2 actually refers to the RISK to the ability of the CSB to PROVIDE EMERGENCY SERVICES IN SIDNEY!!

And THAT question remains UNANSWERED, because OEI WAS NOT DIRECTED BY THE TOWN'S "PRINCIPAL ARCHITECT" TO DO A RISK ASSESSMENT!!!

WHY NOT? WHO "MIS-BRIEFED" THE ARCHITECT on what was required, or did he just change it on his own?

Numerous reputable scientific studies (including those below, by the CANADA Transportation SAFETY Board) have confirmed that most fatal aviation accidents occur during the approach and landing phases of flight, in close proximity to runway ends, AND that the severity of the consequences is significantly increased when aircraft ‘already in trouble’ come into contact with ‘solid structures’ (like the CSB or GATEWAY!).

TSB Watchlist (Canada Transportation Safety Board)

(http://www.tsb.gc.ca/eng/surveillance-watchlist/aviation/2014/air_1.pdf)

(http://www.bst-tsb.gc.ca/eng/surveillance-watchlist/aviation/2016/air-02.asp)

Every year, millions of successful landings occur on Canadian runways. However, there is a risk that accidents resulting in loss of life, injury, and aircraft damage can occur during the landing phase of flight. These accidents include runway overruns, runway excursions, landings short of the runway, and tail strikes. Operators, regulators, and air navigation service providers need to take more action to prevent approach-and-landing accidents, and to minimize the risks of adverse consequences if a runway overrun occurs.

Overall progress to address RESA requirements at most airports continues to be slow. Many Canadian airports do not yet meet the Transport Canada guideline of 150 m, and most large airports do not meet the International Civil Aviation Organization (ICAO) recommended practice of 300 m RESAs. As a result, the terrain beyond the end of many runways in Canada could, in the event of an accident, contribute to aircraft damage and injuries to passengers and crew. Accidents involving runway overruns continue to occur. The TSB remains concerned that without further action, risks to the public remain.

The TSB remains concerned that the Transport Canada study methodology and proposed criteria may not adequately address the underlying safety deficiency which gave rise to its recommendation on runway-end safety areas.

There is currently no requirement in Canada requiring runways to meet international standards and/or recommended practices for safety areas.

TSB Statistical Summary – Aviation Occurrences 2015

(http://tsb.gc.ca/eng/stats/aviation/2015/ssea-ssao-2015.asp)

From 2006 to 2015, the greatest numbers of aeroplane accidents were associated with landing (59%) and takeoff (26%) phases of flight, followed by the en route (14%) and approach (12%) phases.

Of the 1169 aeroplane accidents with landing phase events, 22% involved collision with object, 20% involved missing or going off the runway, 20% involved landing gear collapse or retraction, and 18% involved a nosedown or overturning event. Of the 478 aeroplane accidents with take-off phase events, 29% involved collision with terrain, 29% involved collision with object, and 26% involved loss of control.

Aero19 (Boeing)

(http://www.boeing.com/commercial/aeromagazine/aero_19/approach_story.html)

According to the Flight Safety Foundation, approximately 56 percent of commercial jet airplane accidents occur during the approach and landing phases of flight and account for 44 percent of all fatalities worldwide. Between 2004 and 2013, 58% of the fatal accidents documented by Boeing occurred during descent, approach and landing.

Air France 358 - Toronto YYZ - Runway Overrun - Aug 2005

Accidents DO HAPPEN, and when they do, the results can be really catastrophic! These pictures show the results of an 'OVERUN' at YYZ, on a runway configuration VERY SIMILAR to the main runway at YYJ. It is THIS INCIDENT that lead to the TSB recommendation to increase the RESA at our major airports to a minimum of 300M, which the VAA HAS NOT DONE at YYJ!

Website statement : “Every major airport in the world has a fire hall directly adjacent to the main runway to provide crash truck and emergency services.”

YES; as does the VAA at Victoria Airport! Probably because

THEY ARE REQUIRED BY REGULATION TO DO SO!!!

BUT THAT HAS NOTHING TO DO WITH THE LOCATION OF THE CSB!

This statement on the Sidney website, yet again, seems to be a DELIBERATE attempt to influence the 'reader' (= concerned Sidney resident) to accept that building the CSB in the location proposed (and actively promoted by Council and Staff), is not just 'OK', but 'common practice' at all airports! AND THAT IS NOT TRUE!

WHY DID COUNCIL AVOID THE 'ASSENT VOTE' or AAP

Exerpts from a PNR ARTICLE AUG 23, 2016

Concern that “the powers of no” could mobilize against them has prompted Sidney town council to proceed with assent-free borrowing of up to $10 million for its new fire hall.

Mayor Steve Price said he wanted (to use) the 'assent-free borrowing option' because of the possible risk that 'certain groups'could mobilize'.

“My very real concern is that certain groups of individuals who have been spreading misinformation via petitions this year have made it clear they were ready to do it again with the CSB and potentially put our community at physical and financial risk,” Price stated in an email to the PNR Tuesday morning, referring as well to letters in the local paper which have come out against borrowing. “As mayor I can not let that happen to our residents,” he continued. “I can not risk our firefighters’ or our residents’ lives.”

Councillors Barbara Fallot, Peter Wainwright and Erin Bremner-Mitchell felt using the AAP was the way to go, after council had promised to use it during the early discussions about the project. “It’s what we said we were going to do,” said Fallot. “It isn’t about delaying it … we have an obligation to residents to do things in an appropriate process.”

Wainwright added in cases in the past where Sidney used the AAP, it succeeded cleanly. “This is the largest borrowing the Town has ever done,” he said, “and in the past, with smaller numbers, the Town has gone with the AAP.”

Wainwright said there’s already a perception in the community that council doesn’t listen. “Not doing the AAP adds to that and gives the perception that council doesn’t give people, the electorate, credit for having common sense.”

“There has been no significant, legitimate opposition to the fire hall from the general population; but there will be once certain groups get a chance to put more misleading information out there,” he (Price) said, adding he wasn’t prepared to gamble on increased costs, especially since the town intends on building it.

Coun. Mervyn Lougher-Goodey - "feels opposition, especially based on false information, is a real possibility".

Coun. Cam McLennan - “And everyone will cry when the (existing) fire hall is lost in an earthquake.”

I guess that article was a 'harbinger of things to come'? A bunch of paranoids running the circus! The 'public' has every right to voice 'opposition', and to write letters to the press, particularly when such large sums of money are involved.

By THEIR definition, if that opposition did not agree with the views of Price, McLennan, Lougher-Goodey and Chad, it must be 'false or misleading information' regardless who said it or what it said!

By THEIR definition, if you don't agree with them, your views are 'not legitimate', you are not part of 'the general public', and you are one of 'the powers of NO' that were 'mobilising against them'.

Both Price and McLennan are guilty of 'fear-mongering' with their inappropriate comments about 'certain groups', 'risking lives' and 'earthquakes'.

Under the Community Charter (or the Local Government Act),

"For certain matters, local governments are required to obtain elector approval from eligible electors before municipal council or the regional district board can proceed with its decision – such as requesting the Province to expand a municipal boundary, undertake long-term capital borrowing required to build a new recreation centre or, or to establish a new regional district service (e.g. recycling pick-up) for its citizens – before adopting the bylaw.
Local governments can obtain the required elector approval through assent voting (previously called other voting or referendum) or, the Alternative Approval Process (AAP)."

Schedule A – Local Government Decisions Requiring Elector Approval (Elector Assent) - Long-term Borrowing (Loan Authorization)Long-term borrowing undertaken by local governments to incur a liability by borrowing for any purpose of a capital nature .... requires elector approval (Community Charter, s. 179).

If one references the Province of BC document "Alternative Approval
Process: A Guide for Local Governments in British Columbia", it clearly does NOT anticipate a situation where a Council AVOIDS both the 'Alternative Approval Process (AAP)' AND an 'ASSENT VOTE (AV)' in the case of committing to SIGNIFICANT CAPITAL EXPENDITURES, such as the CSB!

But that is exactly what Sidney Council DID, because 'there is an exception to every rule'! They AVOIDED both the AV and AAP by putting together a set of cost estimates, combined with expected proceeds from the sale of assets, that allowed them to 'squeak through' under a general borrowing limit calculated based on Municipal revenues, an option that is really intended to facilitate funding of SMALL capital projects without going to the expense of an AV or AAP initiative.

While it might be LEGAL, it does NOT PASS THE SMELL TEST!!

And, with the latest escalations in costs for the CSB, it is possible that the current borrowing requirements may now exceed the permissible limits. Is THAT why Council is hell-bent on approving the sale of the current Firehall and the adjacent Parking sites is such a hurry?