I am writing to outline my…

I am writing to outline my concerns with multiple aspects of Bill 212, primarily Schedule 3 but also Schedule 2.

Schedule 3 focuses on Highway 413 and beginning early works before the environmental assessment has
been completed. The Highway 413 proposed route goes through a large area of what is currently
protected under the Greenbelt Plan. On the Ontario Government’s own site
(https://www.ontario.ca/document/greenbelt-plan), it defines the land protected by the Greenbelt Plan as
areas “where urbanization should not occur in order to provide permanent protection to the agricultural
land base and the ecological and hydrological features, areas and functions occurring on this landscape.”
The areas build a resilience to and mitigate climate change, protects agricultural lands, and “protect the
natural heritage and water resource systems that sustain ecological and human health.” Yet, this bill
intends to fast-track the construction of a highway that would go right through those lands, defeating
exactly what the Greenbelt Plan was enacted to protect in the first place.

Because of the environmental importance of the Greenbelt areas, Tim Gray, from Environmental Defense,
has submitted a letter requesting Highway 413 to be designated for a federal Impact Assessment as part of
the Impact Assessment Act (see attached). It goes through the negative environmental effects that
building the highway will have on multiple habitats and currently endangered species that rely on those
habitats. Severe damage to these areas of the greenbelt may already be done and not reversible if the early
works are allowed to continue before the environmental assessment is complete. This also goes against
the prescribed order for a project. If work is completed before all studies are performed and the risks are
assessed, what happens if the environmental assessment outlines several mitigations that need to be
performed to reduce the negative effects but can no longer be implemented, or if the project is decided to
be too damaging/not worth it? Money and materials will have already been wasted and the damage would
have been done.

Building the highway will have a negative effect on Canada’s greenhouse gas emissions targets as well. A
study on US cities, performed by Gilles Duranton at the University of Toronto, had found that vehicle
kilometers travelled increases proportionally with the amount of highway present and has an effect that
leads to an, “increase in driving by current residents; and increase in transportation intensive production
activity; and an inflow of new residents”. The study has been included as an attachment for reference. If
Canada’s overall goal is to reduce greenhouse gas emissions, will building Highway 413 lead towards that
future? The Environmental Defense letter made an estimate that CO2e emissions may increase by 0.57
metric tonnes per annum. This new highway will cause a large amount of CO2e emissions during its
construction, and keep emitting due to drivers using the highway in personal vehicles over possible
alternatives. It will push more people to use personal vehicles as their main method of transportation
instead of considering alternatives that work towards our greenhouse gas emission targets.

It is also difficult to understand why Highway 413 must be constructed, who will benefit from it, and how
much it will cost. The Ontario Government’s website for Highway 413 (https://www.highway413.ca/)
states that “someone travelling the full length of the route would save 30 minutes compared to the time it
would take via Highways 401 and 400.” Yet there are other studies, some performed by the Ministry of
Transportation themselves, that shows that using the 407 will be even faster than what is possible using
the proposed Highway 413. This is covered in the Toronto Star article: Will Highway 413 actually cut 30
minutes from your commute – A Ministry of Transportation Analysis
(https://www.thestar.com/news/gta/will-highway-413-actually-cut-30-minut…-
ministry-of-transportation-analysis/article_2ceab5ed-342e-54cf-8c94-518c344d3800.html). I have also included a PDF of the article for review. The main claim of saving people time is being brought into
question by the government body in charge of the project.

Highway 413 had first appeared in the public space approximately 20 years and has been amended a
handful of times over the years. Many things have changed in the last decade alone with regards to the
population of Canada and Ontario, the economy, and the climate. There should be proper assessments for
not only the environmental impacts that Highway 413 and other Highways may have, but a new
assessment on whether these proposals are even beneficial to the people of Ontario and worth the
financial and environmental costs. Are alternatives like using the money to subsidize 407 tolls for trucks and people a viable option instead of building a new highway? This would make better use of existing infrastructure and can be implemented immediately instead of within a decade.

Many of the points I have mentioned above are with respect to Highway 413. But Schedule 2 of the Bill outlines other highways that it is attempting to fast-track. Will those fast-tracked projects, and others in the future, follow in the same footsteps of Highway 413 if this
bill is accepted and implemented?