To The City of London – On Behalf of the Council of Canadians | London Chapter | Environment & Climate Change Protection Committee

City of London,

Planning Committee

Dear Controller and Councillors,

June 17 2007

My name is Kevin Lomack and I would like to begin by stating how much

I appreciate this opportunity to address everyone on the Planning

Committee directly with my thoughts and those of the Council of

Canadians – London Chapter – Environment and Climate Change Committee,

on the topic of establishing a moratorium on any new drive-thru


The question of whether establishing a moratorium on businesses in

London wishing to be permitted to operate under this increasingly

environmentally insensitive model has been on our minds for some time.

We have been thinking that this idea made complete sense in

conjunction with our overall desire to do absolutely everything we

could to promote the reduction of unnecessary vehicle idling in every

situation where this is possible in this city and region.

It is our contention, that anything less than diligently and

persistently thriving to achieve this goal is not at all responsible

to the unfortunate individuals in our community who are currently

experiencing major medical challenges such as respiratory and heart

conditions as a result of vehicle emissions. We are also concerned for

those of us who will undoubtedly be afflicted ourselves at some point

in time if we as a society should fail to make significant strides in

the appropriate direction in each and every instance where we can

improve the environment.

Through the course of the last several months, with the two Public

Participation Meetings as well as the open invitation for submissions

from the public, you have heard from myself and many of my

counterparts and other concerned constituents from the community

regarding the ‘Big Picture’ issue of Climate Change and Global

Warming. We have mentioned specifically how we would like you to

connect the dots to the present question which is determining whether

this city and region can or should tolerate any additional facilities

with a drive-thru component. I will not specifically speak to the

‘big picture principles again as I trust that all of you share with us

an appreciation and understanding of what is continuing to happen to

our environment as a direct result of the actions of the human species

over the past few decades.

When I spoke to the Planning Committee – that some of you were a

part of on November 12 2007, my hope was that I was able to clearly

articulate to everyone present that it was then and continues to be

our belief that if you were somehow able to conclude that it could be

considered rational, defensible and reasonable, from a public policy

perspective, given the vast body of scientific evidence supporting the

conclusion that more serious and forward thinking decisions will need

to be made by Council to mitigate against some of the dire

environmental consequences we are witnessing today, we would do our

best to try to understand. However, we are not at all convinced, and

we truly believe that you are not either, that the issue of excessive

and unnecessary idling can be ignored.

Considering the fact that the well being of our fellow citizens

is an integral part of the City of London’s vision statement – and I

will quote from the web page : We are a caring, responsive community

committed to the health and well-being of all Londoners. The actions

we take will be socially, environmentally, and fiscally responsible so

that our quality of life is enhanced and sustained for future


It is in this context, that I think that I would like to make some

comments on what has been mentioned in the Official Plan Zoning

Refinement Review, prepared by staff for the Public Participation

Meeting on May 26th. And the resolution that was passed by council on

November 19 2007

On page 27 (F) of the report, it is mentioned that the planning

staff do not have the specific expertise to address the question of

the health and environmental impacts of drive-through facilities. We

respectfully are in agreement with this conclusion. And certainly when

one looks at the resolution that was passed by council on November 19

2007, it is clearly evident that planning staff were not expected to

provide any conclusion or direct opinion on these points. The mention

that an independent scientific opinion on the information brought

forward by the public and industry would certainly indicate that a

conclusion on this sort of a serious scientific topic was respectfully

beyond the reach of the department’s background. In fact, it would be

our desire to have this question determined through another standing

committee such as the Environment & Transportation Committee in

conjunction with the appropriate inside and outside experts. Having

someone `hired by the industry, prepare a report with the expectation

that everything contained within would be taken at face value can not

be considered responsible.

On page 28 (G), the question from 14 ( b) of the resolution “the

impact of a complete moratorium on drive through uses” is commented

on. We are also in agreement with the conclusion that it would indeed

need to be a conscious effort by Council to not approve any new drive-

through facilities. This is precisely the kind of thinking that we and

many others in the public believe Council should be engaged in given

the critical and crucial need to capitalize on each and every

opportunity available to foster positive change to our environment. We

would further expect that any sort of increasingly restrictive

policies that should need to be fashioned and implemented into the

Official Plan as has been suggested, would be prepared and presented

as per the standard practice.

In the report, under the above heading, it is mentioned that the

“financial implications to the drive-through industry are unknown”.

With all due respect to the industry, it is our hope and expectation

that this Council would not be in the position to make its assessment

of the merits of this environmental and health related question based

on the financial consequences to an industry that clearly uses

business models elsewhere without a drive-through component with much


Further on page 28 (G), the question from 14 (c) of the resolution

“the impacts of restricting drive- through uses on persons with

disabilities” is commented on. It is not at all lost on us and we

fully appreciate that since the introduction of the drive-through in

around 1970, those with mobility difficulties have felt themselves to

be more appropriately accommodated. We are confident that those from

the industry and the people with disabilities could come up with some

innovative and creative solutions that don’t involve excesses idling

when a moratorium is introduced. Those who have contacted us from this

community have not indicated that their desire to be accommodated by

the industry and public policy regulations should trump the overall

desire to maintain or enhance the quality of the air we all breathe.

This is all I feel I need to comment on from the report prepared

by Charles Parker that is connected to the environmental and health

consequences of the drive-through industry.

I would like to ask you to turn your mind to the document

prepared by Jamie Skimming and Jay Stanford entitled “Environmental

Statement on the Need to Reduce Idling in London”. It would be our

conclusion that these two competent and trusted gentlemen clearly see

the detriment in not pursuing measurable actions toward the reduction

of idling in London. Funds have been requested to pursue additional

idling initiatives in the 2008 budget and were not supported.

The statistics given in this report should prompt anyone to choose

to park and walk in rather than use the drive-through. The fact is

that the message is not getting out to the public adequately and the

environment can’t wait for this to happen. They also speak to many

instances where there is a major divergence of scientific opinion

between the RWDI study and the generally accepted authorities.

We are completely aligned with most of what the author’s state

including the statement that in all cases, the decision to leave the

automobile engine running is a voluntary one, and one that usually

serves no useful purpose except to provide comfort and convenience.

With this in mind, I ask you, how can ones own personal comfort and

convenience trump the severely negative consequences to the


Our instincts would lead us to agree with Mr. Skimming and Mr.

Stanford that it is imperative that Tim Horton’s and the other members

of the Ontario Restaurant, Hotel and Motel Association should become

part of the solution to reduce idling. In a general context – any form

of adherence to the definition of Corporate Social Responsibility

would require them to be more mindful of the impacts of pushing back

against this moratorium challenge. We have yet to see signs of CSR

from the TDL group to the environmental challenges that this industry

is now and will continue to experience. In fact, when we asked,

repeatedly, that they consider the concept of offering a nominal

discount for individuals who choose to walk in rather than use the

drive-thru we did not even receive so much as a reply.

We, in our capacity as volunteers under an NGO banner, are not

currently capable of providing any sort of in-depth scientific

response to the RWDI Study which has been presented, but we certainly

agree with what this staff report has suggested regarding concerns

with certain limitations, the use of certain assumptions and some of

the conclusions drawn. The thought that vehicles lining up as they do

each day at many thousands of locations across the country, without

causing any environmental detriment is preposterous.

There are many more instances cited in the report where the City of

London staff have inferred that the conclusions and related data in

the RWDI report are not able to be relied upon as they don’t

accurately represent a true picture of the environmental impact of the

drive-thru industry. So much for the value of the peer review that we

waited all those months for.

Staff have made some significant and very progressive recommendations

as to what should be happening in this city with respect to the issue

of vehicle idling. Many others in the community are doing their best

each and every day to play a part in improving our environment. It

would be such a shame to have any or all of the value of these

initiatives negated by the fact that concerns surrounding taking away

certain individuals personal convenience and optimism that the

appropriate corporate environmental responsibility will soon be

exhibited, prevented this committee from making the consistently

environmentally responsible decisions we all need you to make on our


Council of Canadians

London Chapter

Environment & Climate Change Committee


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