To Whom it May Concern, We…

To Whom it May Concern,

We are writing to express our concerns regarding Bill 212 - Reducing Gridlock, Saving You Time Act, 2024, particularly in relation to its implications for active transportation initiatives in the Town of Halton Hills. The core concept of this legislation raises concerns about the balance between vehicular traffic flow and the promotion of active transportation and sustainable commuting options. While the intent may be to address gridlock, there is a risk that this approach could inadvertently impact efforts to create a more integrated and accessible transportation network that encourages cycling and walking. The potential limitations on developing bike lanes, particularly where they might require the removal of traffic lanes, could present challenges to municipalities striving to enhance their active transportation infrastructure. The Town of Halton Hills has the following comments:

1- Potential Conflict with National and Provincial Strategies
The bill contradicts the Federal National Active Transportation Strategy 2021-2026 and the 2024 Provincial Planning Statement, as outlined in the OPPI statement. These frameworks emphasize the importance of promoting active transportation rather than discouraging it.
2- Tailored Approach for Different Jurisdictions
The one-size-fits-all approach proposed in Bill 212 lacks efficiency for jurisdictions with varying populations and traffic congestion levels. For instance, removing a traffic lane on lower volume roads in smaller cities or towns like Halton Hills may not significantly impact vehicular Level of Service. Instead of implementing general rules, it would be more effective to establish specific criteria, such as AADT or road LOS thresholds, to determine when lane removal for bike lanes is appropriate. This approach would better accommodate the diverse needs of different municipalities while still promoting active transportation.
3- Potential Counterproductive Effects on Congestion Management
Proper congestion management necessitates a modal shift towards alternative sustainable transportation options. By imposing additional provincial approval layers for adding bike lanes, we risk increasing congestion by not promoting safe and dedicated cycling facilities. This approach undermines the objectives outlined in our ATMP.
4- Clarification on Key Terms and Criteria
Several aspects of Bill 212 require further clarification to ensure proper understanding and implementation, such as:
• What constitutes "Prescribed Municipalities" under this bill?
• How is an "Existing Lane of traffic" defined? Does this include center turn lanes (TWLTL) and/or parking lanes?
• What are the specific "criteria for approval" for bike lane installations?
Clear definitions and guidelines are crucial for municipalities to effectively navigate the proposed approval process and understand the bill's implications for their transportation planning efforts.
• The criteria established must prioritize safety, connectivity, and accessibility rather than vehicle flow at the expense of cyclist safety.
5- Long-Term Impacts of Not properly Implementing Bike Lanes
Avoiding the removal of traffic lanes to implement bike lanes or getting provincial approval that seems a long process may seem to preserve road capacity for vehicles in the short term. However, this approach fails to recognize that extra capacity on roads tends to be quickly filled by single-occupancy vehicles over time, a phenomenon known as induced demand. Meanwhile, the opportunity to provide safe and connected active transportation facilities is lost.
6- Conflict with Current Plans for Bike Lanes
Currently, the Town has planned a potential removal of a traffic lane along Argyll Road to accommodate buffered bike lanes as per the Council-approved Active Transportation Master Plan (ATMP). However, further analysis and feasibility reviews should be conducted to explore the possibility of implementing separate facilities.
7- Burden of Data Collection Requirements
The proposed mandatory data collection requirements are resource-intensive and costly for smaller municipalities, which could hinder their ability to implement active transportation initiatives effectively.