Introduction The comments…

Introduction
The comments set out below stem not only from my views on such matters, but also from over 30 years professional experience working on the planning and design of transportation systems (of all types) for towns and cities. This experience gives me huge insight into the need to holistically consider all forms of transportation, and their interactions with land use, the built form of the city and economic development. It is imperative that transportation analysis and development considers the merits of ALL forms of transportation and how each is best placed to contribute in each circumstance. There should not be a sole focus on a single form of transportation to the detriment of all else. And to be clear, this is reflected in my personal life where I walk, cycle, drive or take transit depending on the trip being made. Better decisions are made when one has personal experience of all the possible options.

Schedule 3 – Highway 413 Act – Exemption from the Environmental Assessment Act
I am opposed to Schedule 3 of the Bill. The Environmental Assessment Act is there to ensure a robust, transparent and credible analysis of all the environmental impacts of major infrastructure projects, such as the proposed Highway 413. Given the contentious nature of Highway 413, it is imperative to set out the environmental impacts fully, alongside the broader case for the project. To simply pick and choose what projects the Act applies to is wrong.
Of course, this exemption is for a project that itself should not be built. Aside from the obvious adverse environmental impacts, in the long term it will do little to alleviate congestion. Empirical evidence over decades has shown that induced demand, that well known phenomenon whereby traffic in urban and suburban areas simply expands to fill the available space, will return congestion to the same level. Even the MTO’s own modelling is showing this (see https://www.thetrillium.ca/news/municipalities-transit-and-infrastructu…). Experts at the Bill’s public committee hearing on Monday September 18, 2024 were of this view. Overall, Highway 413 simply locks us further into the failed 1950s car dependent planning paradigm.

Schedule 4 – Highway Traffic Act Part XII Municipal By-Laws and Bicycle Lanes
I am opposed to Schedule 4 of the Bill.
Firstly, it is egregious overreach and anti-democratic for the Provincial Government to interfere in matters best left to local municipalities. The local municipalities are best placed to consider the needs and interests of the local populace for local matters such as bicycle lanes. They will take a holistic view of all the competing demands for road space, alongside wider policy objectives around safety, improving transportation options (not just cars), equity, business impacts and environmental considerations (from micro to macro). Of note, bicycle lanes are often an integral part of complete streets that aim to recognize and accommodate the needs of all users of public space, not just those in cars. In short, bicycle lanes should be a matter for local municipalities ONLY.
Secondly, the proposal to waste taxpayers money to REMOVE existing bicycle lanes in the City of Toronto (on Bloor, Yonge and University) is counter to all contemporary thinking around city building and placemaking. Not a single credible organization has supported this proposal, with the Ontario Traffic Council, the Ontario Professional Planning Institute, the Association of Municipalities of Ontario, the Bloor Annex BIA, and 120 physicians and researchers from the University of Toronto against this proposal. To date, the Province has provided no data or evidence to support it’s assertion that these bicycle lanes are materially impacting motor vehicle congestion; only anecdotal and misleading evidence has been provided. To state that only 1.2 % of people commute by bicycle and 70% by car as justification is disingenuous and frankly fraudulent when these numbers relate to the Toronto Census Metropolitan Area (CMA), an area that stretches from Lake Ontario to Lake Simcoe and includes places like Richmond Hill, Oakville and Vaughan. When considering the case for bike lanes, a much more focused area or corridor analysis is the appropriate level for data analysis and these show much higher levels of bicycle usage on these corridors with the bike lanes. Even if the bike lanes are removed, most of these corridors will have some level of parking, such that there will still only be 2 lanes for traffic for most of the time, thus achieving no material benefit. And any material benefit will quickly be nullified by induced traffic, that will known phenomenon whereby traffic simply expands to fill the available space, thus returning congestion to the same level. In short, the proposal to remove these bicycle lanes is simply not supported by policy or evidence and they should be left in place.