I am writing in opposition…

I am writing in opposition to the proposed amendments to the Highway Traffic Act related to bike lane approvals.

The proposed amendments that would require municipalities to seek minister's approval for new bike lanes is redundant and unnecessary. The Environmental Assessment Act and Municipal Class Environmental Assessment process already establishes a framework for assessing potential impacts from infrastructure projects such as the redesign of roads. There is also already a process for "bumping up" Municipal Class EAs for provincial review if members of the public feel that a municipality has not followed the process correctly or has not appropriately considered impacts.

The effect of the proposed amendment will be to create a barrier to the implementation of bike lanes in dense urban areas where the public right of way is already primarily occupied by motor vehicle lanes. This places an unfair and unequal burden on dense municipalities with narrow rights of way compared to lower density municipalities with wider rights of way and is counter-productive considering the denser municipalities are in a better position to encourage cycling due to the shorter distances between destinations.

The proposed amendments to the Highway Traffic Act are also inconsistent with the recently enacted Provincial Planning Statement, 2024 and will frustrate the province's efforts to achieve the objectives of the Provincial Planning Statement.

Section 2.2 of the Provincial Planning Statement states, "1. Planning authorities shall provide for an appropriate range and mix of housing options and densities to meet projected needs of current and future residents of the regional market area by: c) promoting densities for new housing which efficiently use land, resources, infrastructure and public service facilities, and support the use of active
transportation"

The proposed amendments to the Highway Traffic Act contradict this direction in the new PPS but adding an administrative layer to the installation of new bike lanes to serve new residential development that supports the use of active transportation. The proposed amendments will have the effect of discouraging municipalities from repurposing existing motor vehicle lanes, even in areas that have surplus capacity.

Section 2.3.1 of the Provincial Planning Statement states, "2. Land use patterns within settlement areas should be based on densities and a mix of land uses which: c) support active transportation"

The proposed amendments to the Highway Traffic Act would have the effect of discouraging active transportation by adding an administrative layer to the repurposing of motor vehicle lanes for bicycle lanes. The proposed amendment will frustrate the province's objective of ensuring settlement areas support active transportation, especially in established settlement areas where the public right of way is not wide enough to accommodate new bike leans without repurposing old motor vehicle lanes.

Section 2.4.2 of the Provincial Planning Statement, 2024 includes provisions for the intensification of development around Major Transit Station Areas. This intensification cannot proceed on the basis that primary mode of transportation outside of the transit system is by motor vehicle. Bicycles and public transit go hand in hand. Including bicycle lanes in close proximity to transit stations provides an important "last mile" connection between the transit station and people's homes, jobs or other destinations. Existing Major Transit Stations are often located in denser, urban areas where the majority of the public right of way is already occupied by motor vehicle lanes, without additional space available to accommodate bike lanes without repurposing the motor vehicle lanes.

In the absence of bicycle lanes, residents in intensified Major Transit Station Areas are more likely to drive, which will result in more traffic and gridlock. If they are provided with safe space to bike, this will reduce the traffic impacts of new development. Implementing barriers to the repurposing of motor vehicle lanes to bike lanes will frustrate the province's objective of achieving greater intensification in Major Transit Station Areas.

Section 2.9 of the Provincial Planning Statement, 2024 states, "1. Planning authorities shall plan to reduce greenhouse gas emissions and prepare for the impacts of a changing climate through approaches that: d) promote green infrastructure, low impact development, and active transportation,
protect the environment and improve air quality."

Bicycle lanes promote active transportation. Prioritizing the retention of motor vehicle lanes over their repurpose as bicycle lanes, and requiring an extra bureaucratic step of obtain minister's approval, directly contradicts the direction of the PPS, 2024 and will negatively affect the Province's objective of reducing greenhouse gas emissions.

Reducing reliance on motor vehicles supports the PPS objective of improving air quality by reducing vehicle emissions and micro-particles related to rubber tire wear and brake pad wear which make their way into air and water.

Section 3.2 of the Provincial Planning Statement, 2024 states, "1. Transportation systems should be provided which are safe, energy efficient, facilitate the movement of people and goods, are appropriate to address projected needs, and support the use of zero- and low- emission vehicles."

Bicycle lanes improve the safety of roads for all users. They reduce the frequency and severity of collisions involving motor vehicles, bicycles and pedestrians.

Bicycle Lanes are energy efficient by encouraging human powered transportation options instead of fossil fuel and electrically powered vehicles that require significant resources to build, transport and operate.

Bicycle Lanes facilitate the movement of people and goods, often with greater efficiency than motor vehicle lanes because of bicycles smaller size and greater maneuverability. Delivery companies have begun shifting to cargo bikes for deliveries and food couriers on bicycles have proliferated greater in recent years.

Bicycle lanes are particularly appropriate to address the projected needs of large and growing municipalities like Toronto, Mississauga, Brampton, Ottawa, Vaughan and elsewhere.

Bicycles are zero-emission vehicles.

Any legislation that would have the effect of slowing down the installation of bicycle lanes by requiring minister approval, especially if the criteria for the minister's approval is not clearly stated, would be contrary to the direction of the PPS, 2024.

Prioritizing motor vehicle lanes over the installation of bicycle lanes by requiring minister's approval of any bike lanes that would repurpose vehicle lanes is contrary to the direction of the PPS, 2024.

Section 3.2 also states, "3. As part of a multimodal transportation system, connectivity within and among transportation systems and modes should be planned for, maintained and, where possible, improved, including connections which cross jurisdictional boundaries. "

Bicycle lanes are an important part of a multi-modal transportation system. The proposed amendments to the Highway Traffic Act do not establish any standards, criteria, or methodology that the minister would use to evaluate proposed bicycle lanes. This makes planning for a multi-modal transportation system difficult or impossible because planning authority will not be able to anticipate how the minister will determine if their proposed bicycle lanes will be evaluated.

The Province of Ontario already has an established set of guidelines for the design of bicycle lanes in its Ontario Traffic Manual Book 18, and we already have an established process for evaluating the impacts of infrastructure projects through the Environmental Assessment Act.

Section 3.9 of the Provincial Planning Statement states, "1. Healthy, active, and inclusive communities should be promoted by: a) planning public streets, spaces and facilities to be safe, meet the needs of persons of all ages and abilities, including pedestrians, foster social interaction and facilitate
active transportation and community connectivity."

Bike lanes provide safe facilities for active transportation.

Overall, the PPS does not state that active transportation should be subordinate to motor vehicle transportation. Read as a whole, the PPS provide clear direction that the Province of Ontario intends to prioritize active transportation, densities that will not function if the priority is motor vehicles, and a comprehensive response to climate change.

The proposed amendments to the Highway Traffic Act are not consistent with the Provincial Planning Statement and will in fact frustrate the implementation of the PPS. The proposed amendments are redundant and unnecessary considering existing requirements under the Environmental Assessment Act, and the proposed amendments do not provide any direction on how the minister intends to evaluate bike lane proposals or any methodology for determining the impacts of removing motor vehicle lanes.

For these reasons I am opposed to Bill 212 and the provisions related to bike lanes should be removed.