I am writing to voice my…

I am writing to voice my dismay over significant portions of Bill 212. The overall content of the bill is founded on hypotheses that are erroneous in fact (as readily shown by the significant majority of current urban congestion research) and the measures specified cannot be expected to efficiently address the issue that they purport to address. Worse, the specified measures can be reasonably expected to adversely affect the environment, and make the problem worse over the long term. In particular, the actions specifically added in the October 31 addendum to the Act - namely the removal of existing bike lanes on Bloor, University, and Yonge in Toronto - are highly likely to induce demand for automobile traffic that will exacerbate the problem over the medium and long term future.

The preamble to the bill states that:

"The Government of Ontario:

Recognizes the need to build priority highways faster as our province grows in order to get people and goods out of gridlock and save drivers and businesses time and money."

This statement identifies that the challenge the government intends to address is gridlock, and that the objective is to save drivers and businesses time and money. While gridlock is a problem that is definitely worth solving, the implicit assumption that building priority highways is an effective solution is demonstrably false, except in the shortest of future terms. Additionally, the focus on drivers and businesses belies an unbalanced view of the problem at hand, neglecting all other stakeholders and magnifying the likelihood of a flawed proposal. This becomes evident when the proposed measures are viewed against both their likely efficacy in solving the problem at hand, and the undesirable effects they are likely to cause.

It is well understood in the current research that additional traffic lanes for cars create short-term relief followed by induced demand that magnifies the problem in the medium and long term. Conversely, a 2021 comprehensive study of congestion in 100 American cities by Mokhlesur Rahman and Jean-Claude Thill which also amalgamated and summarized the results of 30 other studies found:

"Of all the considerations tested...non-car mode share behaviors have the greatest
impacts on reducing all three aspects of congestion, travel time, congested lane miles, and the
duration of peak periods. Non-car mode share reduces congestion significantly by reducing car
use and increasing public transport and walking. While a number of authors (e.g., Bhattacharjee
and Goetz, 2012; Anderson, 2014; Beaudoin et al., 2015; Nguyen et al., 2015) have
underscored the relief that public transportation brings on congestion, the magnitude of the
effect uncovered here is quite striking. It literally dwarfs the overall effect of highway
infrastructure development on congestion (0.390 versus 0.086, Table 10). While more highway
and freeways reduce congestion by providing alternative routes to people (direct effect of -
0.92), they also invite more cars on the streets due to induced demand for travel (indirect effect
of 0.833), hence the melting of the positively contributive effect of highway infrastructure
down to -0.086."

If the Government of the Province of Ontario wishes to reduce congestion in Toronto, they would do well to heed the results of this massive study. These results clearly state that not only do "non-car mode share behaviours" (i.e., active and public transportation) "have the greatest impact on reducing all three aspects of congestion" but also that "more highway and freeways...invite more cars on the streets due to induced demand...melting...the positively contributive effect...to [a negative number]."

By proposing this bill, the Government is choosing to act counter to the interests of the majority of the people they serve, and leading in a direction that irresponsibly supports populist and vitriolic anti-cycling sentiment. The Bloor, University, and Yonge cycling lanes are routes that form the core of what has begun to be an interconnected network of cycling infrastructure. Research also shows clearly that cycling infrastructure is only effective once an interconnected network is formed. Removing these lanes in particular will not only cripple the type of activity that has a chance of dealing effectively with the congestion problem, but it will also magnify the problem in the long run by inducing increased demand for vehicular traffic in downtown Toronto.

It is worth noting, however, that this Act is not problematic only in Toronto. I have had the opportunity to both cycle and drive in a number of southern Ontario cities as well as in cities in other countries around the world. I cycle daily. I also drive very regularly. It's clear to me that improved cycling infrastructure (and especially physically segregated infrastructure) has the potential to create the kind of environment that is conducive not only to desirable cycling conditions, but desirable driving conditions as well. I would much rather drive down a Yonge Street with less cars and a 30 or 40 km/h speed limit, and countless bicycles utilizing the bike lanes. This approach would not only move a great deal more people a great deal more quickly than simply adding another vehicle lane and removing the bike lanes, but it would also be substantially more pleasant for everyone. And, as we have already found out, adding the cycle lanes have improved revenues for businesses on Yonge. The choice to remove these lanes is frankly baffling in light of the stated goals.

Finally, with respect to this Act, the requirement for municipalities to receive provincial ministry approval prior to the creation of cycling infrastructure is blatant overreach in almost any circumstance. And the pretense that this has to do with improving gridlock, already shown above as false, is also blatant overreach on the part of the provincial government and indicative of the worst form of authoritarian and baseless ideological political maneuvering. This kind of legislation exacerbates not only the very problems it purports to solve, but also the divisive politics that mire our society in ill feeling and blinkered ignorance.

The final comment that I would like to make is with respect to the Highway 413 act, Section 2 of which "provides an exemption from the Environmental Assessment Act for enterprises, activities, proposals, plans and programs for or related to Highway 413, including the Highway 413 Project and the Highway 413 early works projects."

Once again, this is an example of poor reasoning in the face of mountainous quantities of thorough research. As a result, the optics of the situation appear as willful opposition to meaningful, valuable protections against the results of that very type of activity. First, the very belief that this highway is essential is still questionable in the face of the same evidence I have provided above (and will attach to this commentary). And second, the point of the Environmental Assessment Act is to ensure that environmentally impactful projects (like highways, and particularly large 400-series highways) are undertaken only with an amount of environmental impact mitigation that is sufficient to address the challenges they create. Nothing should be exempt from the Environmental Assessment Act. The environmental assessment of the project is next to meaningless if the project is a priori exempt.

To sum up, the challenge we face is real. Congestion is undesirable. However, the hypothesis that we have more cars moving faster is a desirable alternate reality is flawed. It's not the cars that need to move faster or with less congestion. It's the *people* that need to move with less friction. There are many ways to address that problem, but more lanes for cars is demonstrably ineffective, as shown in cities all around the world and studied by many reliable scholars. There are effective techniques, and they generally include public transportation, active transportation, walkable infrastructure, and tele-work (i.e., reducing the frequency of intra-city travel), among others. From a taxpayer perspective, all of these are more cost-effective than highways, and everything is more cost-effective than dismantling steps taken by cities to move in the direction of effective congestion mitigation (i.e., first-class cycling infrastructure).