Protect neighbourhood safety. 

To: The Mayor and Members of St. John’s City Council

We are asking St. John’s City Council to deny the request to rezone 18 Mount Cashel Road. What is being proposed?

The application seeks to rezone 18 Mount Cashel Road from Residential 2 Cluster (R2C) to Apartment 1 (A1) to permit two three-storey apartment buildings containing 66 two-bedroom units.

This is not simply a decision about whether two buildings can fit on a property.

 

Residents have repeatedly raised safety concerns that are documented in submissions to the City and are part of the public record.

Yet the Traffic Impact Study states: “No specific safety concerns have been noted in this area.”

▪  Known safety events and repeated resident concerns were not reflected in the traffic study’s findings. Before the study was completed, residents had repeatedly raised road-safety concerns that were already part of the public record, and a documented collision involving a cyclist required an ambulance response. Despite this information, the study states, “No specific safety concerns have been noted in this area.” This conclusion could not reasonably be relied upon when it was made because relevant safety information had not been incorporated into the analysis. The subsequent June 2026 incident, in which a vehicle narrowly missed striking a child, further heightens our community’s concerns.

▪  The traffic counting methodology did not comply with the City approved Terms of Reference. Traffic counts were conducted on different days and then expanded to estimate daily traffic, rather than being collected simultaneously as required by the Terms of Reference established by the City.

▪  Critical data was not disclosed. The observation date and raw data for the purported simultaneous New Cove Road and Torbay Road traffic counts,, that were conducted by the City, not the proponent, were not provided, preventing independent verification of the methodology or conclusions.

▪  School related traffic and child pedestrian activity were not comprehensively assessed. The study did not adequately examine school arrival and dismissal periods and the traffic generated by these predictable daily activities in their calculated estimates.

▪  Compliance with the required traffic-safety engagement has not been demonstrated. The City-approved Transportation Assessment Scope expressly required public engagement with residents and stakeholders regarding traffic and safety concerns. The study refers generally to engagement completed by KMK and lists four broad transportation topics, but it does not identify who participated, when or how the engagement occurred, whether key community stakeholders were consulted, or how documented safety events and repeated concerns on the public record informed the analysis. Without this information, compliance with this requirement cannot be independently verified.

Resident count following the June 2026 child safety incident raises concerns about the study’s traffic volumes accuracy. Following the high-potential traffic safety incident in which a vehicle narrowly missed striking a child, residents initiated a one-day traffic count on Mount Cashel Road west of Tiffany Lane. Over 11 hours (7 am- 6pm), residents counted 1,266 eastbound and 1,760 westbound vehicles, for a total of 3,026 actual vehicle movements. The consultant counted 807 eastbound and 1,172 westbound vehicles, for a total of 1,979 actual vehicle movements over 12 hours at the same section on October 7, 2025. The resident count was 1,041 vehicles, or approximately 53 percent, higher, despite covering one fewer hour. The counts were conducted on different dates, the resident count was an informal community initiative rather than a professional traffic study, and no resident count was completed east of Tiffany Lane. Nevertheless, the substantial difference between the two actual counts raises grave concerns and warrants independent verification under current conditions. No daily estimation or 1.3 expansion factor has been applied to either count in this comparison.

 

▪  Vulnerable road users were not adequately considered. This neighbourhood includes school children, seniors and other vulnerable residents whose safety must be explicitly assessed and protected.

▪  No comprehensive road safety assessment was completed. The study focused primarily on traffic volumes and vehicle movement. It did not evaluate the full range of hazards experienced by residents, pedestrians, children, seniors and drivers on Mount Cashel Road.

▪  Known shortcutting routes were not observed or measured. Traffic associated with the Mary Queen of Peace parking lot and the Baird’s Lane shortcutting route was omitted. This shortcutting route was flagged by residents because of the safety hazards introduced to children. This leaves a significant gap in the assessment of actual neighbourhood traffic patterns.

▪  Critical road conditions remain unresolved. Sightlines, roadside parking, winter snow accumulation, narrowed travel lanes and realistic emergency vehicle access were not adequately assessed.

▪  Compliance with the City approved Terms of Reference has not been demonstrated. The available report does not establish that every required element was completed, documented and incorporated into the final analysis.

▪  Essential traffic-count methodology and vehicle-matching information were not disclosed. The study does not explain whether the turning-movement counts were completed manually, by camera or through automated equipment. It does not identify the number of observers, where they were positioned, whether all approaches were continuously visible, or what quality-control procedures were used. Although the count sheets classify vehicles as light, medium or articulated, they do not explain how vehicles were distinguished or validated. For the shortcutting analysis, the study states that the City observed both ends of Mount Cashel Road simultaneously and identified individual vehicles travelling through the neighbourhood, but it does not disclose the observation date, the recording method, the vehicle-matching criteria, the time threshold used, the raw matching data or the potential error rate. These omissions do not establish that the counts are incorrect, but they prevent residents and decision makers from independently evaluating the reliability and reproducibility of the methodology.

 

 Deny the rezoning application for 18 Mount Cashel Road.

We are not opposed to housing but it cannot come at the cost of safety on an already overburdened road and neighbourhood that has already been intensified to its limits.

 

Please sign and share this petition.

 

Submitted by concerned residents of Mount Cashel Road, Horwood Street and Tiffany Lane.