November 20, 2024 BILL #212:…

November 20, 2024

BILL #212: MCN! submission to Environmental Registry of Ontario (ERO #019-9266)

NOTE: This document with all *hyperlinks* is ATTACHED (3p PDF)
Also published on our website at: https://misscyclingnow.ca/bike_lanes/#bill_212_ERO

Text of the submission by Mississauga Cycling Now! to the Environmental Registry of Ontario (ERO #019-9266) concerning Bill 212, Reducing Gridlock, Saving You Time Act, 2024 - Framework for bike lanes that require removal of a traffic lane.

WHO ARE WE? We are former members of the Mississauga Cycling Advisory Committee (MCAC) for the 2015-2019 term, since then collaborating on advocacy as Mississauga Cycling Now! Our objective is to create the digital infrastructure necessary to support and promote citizen cycling advocacy and provide a reference/archive for cycling issues in Mississauga. We are presently providing input to the 2024 Mississauga Cycling Master Plan Update.

We submit the following comments regarding Bill 212:

INTRODUCTION: Mississauga, Ontario's third-largest city, is a city of significant barriers, the legacy of being planned and designed around cars. Segmented by seven (7) major highways plus wide and fast arterials and railway lines, as well as the Credit River and myriad creeks and streams, Active Transportation retrofits are needed to connect the City's historic communities and meet the City's ambitious targets for 50% sustainable mode share for pedestrians, cyclists, and transit-users by 2041. Meanwhile, whole neighbourhoods are isolated without car use.

1. MAIN ROADS: Mississauga is largely suburban in design with winding streets and disjointed connections. Only the main roads, such as Bloor Street which is used as an example in this document, provide direct north-south or east-west connections. There are no parallel "secondary roads" or side streets that could be meaningfully considered for designated bike routes. Like drivers, people on bikes look for the direct route and when these are available, can reduce the ever increasing number of cars on the roads. Mississauga's Changing Lanes project is reclassifying the streets, roads and major arteries in the City, to ensure our streets are safe and more convenient for all users.

2. INTEGRATED ROAD PROJECTS: Increasingly in Mississauga, street design changes in accordance with the City's Vision Zero program are planned when roads come up for repair, thereby saving tax dollars. These projects include a more extensive public consultation process as seen with the Bloor Street Redesign project. The intention is to improve Road Safety for all users, including pedestrians, cyclists, motorists and transit riders; one result is lower traffic speeds. Speeding is a huge source of concern in Mississauga, especially on the main roads where safe cycling infrastructure is most needed. By segregating people on bikes travelling on main roads with safe bike lanes, traffic moves more smoothly. Restricting or removing cycling infrastructure on main (high speed) roads only serves to endanger people on bikes and disrupt traffic flow.

3. BIKES MEAN BUSINESS: It's a proven fact, as the Bloor Annex BIA in Etobicoke advocated at the Standing Committee on Heritage, Infrastructure and Cultural Policy (Hearing re Bill 212) on November 18, 2024: "after bike lanes were put in, spending went up and road conflicts went down." This fact has been proven in countless studies around the world. The Centre for Active Transportation (TCAT) has recently published Bike Lanes Save Lives, Boost Business, and Can Relieve Congestion (November 4, 2024). Here’s the Evidence (November 4, 2024).

4. CYCLING TOURISM: It's an economic driver, and Visit Mississauga ties in with cycling events when possible (e.g. Tour de Carassauga 2024). Because of the disconnected nature of cycling infrastructure in Mississauga presently, opportunities are limited, but completion of main routes will enable safe access to feature destinations from anywhere in the City.

5. CLIMATE CHANGE: Mississauga's Climate Change Action Plan has ambitious goals to reduce emissions: Cut carbon/GHG emissions 40% by 2030; 80% by 2050. Achievement of these goals will require completion of a logical cycling network to enable a safe and efficient alternative to car travel and promote a greater, greener modal split. In fact, the City has just announced it is setting more ambitious targets aligned with the international goal of limiting global warming to 1.5°C.

6. HEALTHY CITY STRATEGY: Diabetes is virtually an epidemic in Mississauga and our City has developed a Healthy City Strategy per the ~Cities for Better Health (CBH) Program~ which includes "Implementing the Cycling Master Plan ... building new multi-use trails and protected cycling infrastructure." But this infrastructure must also be where people need or want to ride, and in our City that often means the main roads in order to traverse barriers.

7. MISSISSAUGA CYCLING MASTER PLAN (CMP): Public engagement was to begin this Fall on the 2024 CMP update, but is now delayed to the new year due to the uncertainty of what will be allowed by the province. Without full control over the location and format of cycling infrastructure using local municipal knowledge, the CMP Update process will be stymied and development of optimal active transportation solutions to mitigate traffic congestion will be delayed.

8. E-SCOOTER PILOT PROJECT: Mississauga is conducting a shared e-scooters pilot project per Ontario’s e-scooter pilot program running until November 27, 2029. The expectation is that cycling infrastructure will expand and support the safe use of micro-mobility devices anywhere in the City. Eliminating or restricting bike lanes on main roads can only result in collisions as destination-oriented micro-mobility usage grows.

9. POPULATION GROWTH: There will never be enough traffic lanes to accommodate cars for all the people coming. Ontario's *own* demographic projections in the document Ontario's Long-term Report on the Economy 2024-46 (146p PDF) highlight a continued rapid rise in population and concentration of this growth in urban areas, where the brunt of Bill 212 will be most harmful in limiting mobility options and actually compounding congestion. See Chapter 1 (p5): Demographic Trends and Projections.

10. DEVELOPMENT AND DENSITY: Like many cities, Mississauga has lowered its parking standards (17p PDF; Appendix 1: zoning amendments at Item 5.5 on PDC Agenda) to both reduce the cost of a new condominium for first time buyers and optimize the densification of Major Transit Station Areas (MTSAs) as required by the province, per the new Provincial Planning Statement, 2024. Less parking near transit stations makes sense. But without a car, new condo owners face a mobility challenge if cycling infrastructure is not installed to their door. On Bloor Street in Mississauga, for instance, several new condo buildings are planned even as the Bloor Street Redesign project is now "paused" due to the uncertainty about Bill 212.

11. CITY BUILDING: Urban mobility is a vital component of planning and developing liveable sustainable cities. Cycling is integral to solving Mississauga's conjoined issues of rapid densification and growing traffic congestion due to too many cars, especially on main roads. Successful cities around the world (2024 Top 10 most bicycle-friendly cities includes Montreal, PQ) promote cycling to benefit not only mobility but also road safety, social equity, air quality, public health, economic activity and tourism. More than 80% of Ontarians live in urban areas (including Mississauga), where municipal governments can best decide how to configure and optimize their own transportation infrastructure. See Mississauga's Transit and Road Infrastructure Plan.

12. AFFORDABLE LIVING: When owning a car (or using transit) is too expensive, a safe cycling network enables access to affordable grocery stores (or food banks) which may be further away; the opportunity for non-local employment; and more money available for housing costs. The province and the City are in the midst of both a food insecurity and a housing crisis. A balanced transportation system allowing for equitable personal mobility needs to be supported by the province, not thwarted.

13. FISCAL IRRESPONSIBILITY: With affordability an issue of great concern in Ontario, it is irresponsible to spend more taxpayer money to undo municipal investments already made in safe cycling infrastructure. We note the framework of Bill 212 mandates provincial approval for new bike lanes on municipal roads requiring removal of a traffic lane and for existing ones, where a traffic lane was removed. The framework goes even further, naming specific Toronto bike lanes which are to be removed absent any quantitative justification, at the expense of all taxpayers in the province. In Mississauga, the Bloor Street Integrated Road Project, now known as the Bloor Street Redesign project, has been "paused" (Mississauga News, November 1, 2024) pending a better understanding of the proposed legislation and any clarifying regulations. Staff has documented that over $800k was spent on public engagement and several design iterations to arrive at the chosen design (Alternative 6 - 4p PDF) involving a 4-to-3 traffic lane conversion and protected cycle tracks. Procurement has already taken place.

14. PROVINCIAL OVERREACH AND INTERFERENCE: For a government with the catch phrase "Get it Done" it is strange to see a Bill 'getting it undone'. For a government touting a Ministry of Red Tape Reduction it is strange to see a Bill layering on the red tape yet to be specified in regulations. For a government that has stated (Premier - April 3, 2024) "I believe in letting municipalities determine what is good for their communities and what is not good for their communities," it is strange to see a Bill committing the Province to micro-manage an entirely local issue and interfere with democratic municipal process. Such overreach into municipal affairs when primary provincial responsibilities such as Health, Education, the Courts system (and social services in Peel Region) are being underfunded is strange indeed. The Association of Municipalities of Ontario (AMO) expressed this in their submission (4p PDF) to the Standing Committee on Heritage, Infrastructure and Cultural Policy (Hearing re Bill 212) on November 18, 2024: "The proposed bike lane framework is a very troubling overreach into municipal planning."

15. INTERNATIONAL CONTEXT: The content of Bill 212 and its ramifications for Ontario's largest cities are being noticed by the rest of the world. Disbelief and mockery are the reactions of cities preparing for the 21st century by installing safe cycling infrastructure. Urbanists, city planners and transportation engineers have spoken out. Uniquely in Ontario, ideology and anecdotes have supplanted data-based evidence and international best practices in the creation of Bill 212. Bikes v cars: backlash after Ontario premier threatens to tear up cycling lanes in Toronto -- The Guardian (UK) November 18, 2024.

MCN! CONTRIBUTORS:

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