May 25, 2017…

May 25, 2017

Ministry of Transportation (MTO)
Policy and Planning Division
Transportation Planning Branch
Environmental Policy Office (Toronto)
777 Bay Street, Suite 3000
Toronto ON, M7A 2J8

Attention: Ms. Monica Russell, Senior Policy Analyst RE:EBR Registry Number 013-0190 Identifying a Province-wide Cycling Network

As the Active Transportation Coordinator for the County of Essex, I am writing on behalf of the CWATS (County Wide Active Transportation System) Committee. The CWATS Committee was established in 2013 to implement a county-wide network of cycling facilities through the guidance of the CWATS Master Plan. The Essex Region Conservation Authority (ERCA), Windsor-Essex County Health Unit (WECHU), the City of Windsor, Municipality of Chatham-Kent, our seven lower tier municipalities, and the MTO all play a significant role on the CWATS Committee.

In November 29, 2016, the Chair of the CWATS Committee, Ms. Jane Mustac, issued a response to Ms. Sandi Jokic regarding EBR Registry Number 012-8772. For your reference, I have attached this letter as our response to this EBR pertains to this previous communication issued to the MTO. Review of your current province-wide cycling network proposal (EBR-0130190) reveals that none of the main areas of concern that we identified in the previous letter were addressed. It is disappointing to our region, as we are engaged in your provincial cycling concept as we sent feedback in writing in November 2016 and had many CWATS partners who physically attended your out-of-town provincial consultation sessions in 2016.

The reason that this is of great concern to CWATS Committee members, is that our feedback aligns with the CWATS Master Plan that was adopted in 2012 by Essex County Council. Our CWATS Master plan was created through sound engineering and consultation from experts in our region and consultants. We’ve been told by other municipalities and expert consultants that CWATS is one of the best practice regional rural active transportation strategies in the province. Since the inception of CWATS, it has annually had strong financial and in-kind investments from our partners which have positively lead to significant growth of cycling infrastructure and outreach in our region. As an example of the strength of our momentum, we are just completing the final build of three gaps to the Trans Canada Trail (TCT), also known as The Great Trail, which gives us 150 km of continuous cycling facilities that connect all 7 communities in our region to the TCT. As a result of our commitment, we have also over the past five years implemented 294km of cycling infrastructure in the southernmost part of Ontario and Canada! With this, we are respectfully requesting further communication from the MTO on why our previous recommendations that align with our CWATS Master plan were not addressed in your “Identifying a Province-wide Cycling Network”. Respectfully, Cathy Copot-Nepszy, M.ASc. Active Transportation Coordinator The Corporation of the County of Essex

cc:

Town of Amherstburg –Todd Hewitt Town of Essex – Chris Nepszy Town of Kingsville – Kevin Girard Town of Lakeshore – Chuck Chevalier County of Essex - Jane Mustac Town of LaSalle –Larry Silani Mun. of Leamington – John Pilmer Town of Tecumseh – Brian Hillman ERCA – Kevin Money MTO- Brad Shaafsma@ontario.caWECHU – Eric Nadalin Mun. of Chatham-Kent – Genevieve Champagne City of Windsor – Jennifer Leitzinger MTO – Danuta Mahabir ***** November 29, 2016

Ministry of Transportation
Transportation Policy Branch
777 Bay Steet, 30th Floor
Toronto, ON
M7A 2J8

Attention: Sandi Jokic, Manager, Sustainable and Innovative Transportation Office

RE: EBR Registry Number 012-8772 Ontario’s Climate Change Action Plan (CCAP)

The County of Essex has developed a comprehensive active transportation master plan to guide the County and Local Municipalities in implementing a County-Wide network of cycling facilities through the County Wide Active Transportation System (CWATS). In association with the Essex Region Conservation Authority (ERCA), the seven local municipalities, the Windsor Essex County Health Unit (WECHU), The City of Windsor and the Municipality of Chatham-Kent, and the Ministry of Transportation (MTO), a CWATS Committee was established. The CWATS Committee meets regularly to discuss common interests and are pleased to provide feedback into the development of the CCAP. Changes in government funding, Provincial Policy Statement, and other related plans and programs set the context for municipal planning and expectations, as well as raise the bar as our region competes with others that are making good progress in these areas. It’s important in ongoing efforts to create a more vibrant region that we continue to participate with the broader actions, and progress, at the provincial level. In April, 2016, cycling advocates also called on the Province to invest $200 million in cycling infrastructure over 4 years. We were delighted that the Province of Ontario announced its much-anticipated Climate Change Action Plan, including several “actions that support cycling “as there is a significant gap between available funding and the demand for new bicycling infrastructure. The Ontario Ministry of Transportation (MTO) is proposing actions to accelerate and enhance implementation of #CycleON: Ontario’s Cycling Strategy through Action Plan 2.0 with an effort to improve commuter cycling networks in Ontario. The CCAP identifies an intended investment of $150–225 million from cap and trade proceeds to support the creation of better cycling networks, more cycling facilities in urban areas, and more bike parking at transit stations and provincially owned, publicly accessible facilities. One of the actions under the Transportation Action Area is ‘Support Cycling and Walking’. As part of implementing the Province’s CCAP commitments, MTO is proposing a program that includes the identification of a Province-wide cycling network that involves extensive consultations with municipalities, trail associations, other cycling stakeholders and the public.

MTO Province Wide Cycling Strategy – CWATS Committee Comments Page 2 of 7 November 30, 2016

Key items identified in the program include:  Local Cycling Infrastructure – The Province would help municipalities build cycling infrastructure that improves safety in urban areas and supports commuter cycling between residential communities, major transit stations, employment areas and other destinations travelled to on a frequent basis. Eligible infrastructure would include on- and off-road cycling facilities such as painted bike lanes, paved shoulders, cycling lanes separated by a curb, off-road multi-use paths and associated infrastructure (e.g., cycling signals, signs).  Provincial Cycling Infrastructure – The Province would fund initiatives that will address provincial barriers (such as highways and bridges) that impact local cycling networks. Additionally, the government would make direct investments in provincial highways in urban areas to create the conditions to increase cycling for commuting and other frequent trips, where safe and feasible to do so. Infrastructure funded under this component could include on- and off-road cycling facilities (e.g., painted bike lanes, paved shoulders, cycling lanes separated by a curb, off-road multi-use paths), active transportation bridges and associated infrastructure (e.g., cycling signals, signs).  Bicycle Parking – The Province would support construction of bike racks, bike shelters, bike lockers and bike enclosures at government-owned, publicly accessible facilities, transit stations and potentially private facilities such as workplaces and condominiums, where cycling for commuting and other frequent trips is reasonable. Constructing bike storage facilities at destinations can make it easier for people to choose active transportation for day-to-day trips. Having bike parking at transit stations can make it possible for people to bike to and from transit, allowing them to leave cars at home and add physical activity to commutes. The population of bicyclists in the region is growing more diverse and plans for bicycle infrastructure and policy need to adapt to address this shift. The County and the CWATS Committee is supportive of the first two points (Local and Provincial Infrastructure) and any plans for cycling infrastructure that will utilize or abut provincial roads/right-of-way will need to be achieved in a collaborative process with MTO to mesh local programs with provincial level programming of maintenance and improvements to roads. Similarly, plans for cycling infrastructure that utilize or abut county and/or local roads/right-of-way within a municipality will need to be coordinated among the affected local governments. Guidelines for the provision of bicycle and pedestrian infrastructure are rapidly evolving. Engineering and design standards should be consistently monitored to ensure that proper flexibility and safety provisions are in place, and to ensure that proposed projects meet required standards. The plan should offer a broad range of useful tools as options for local governments to draw upon in their efforts to promote the development of bicycle and pedestrian access in their community, county, or region and not be limited to the provision of bicycle parking. It will be necessary to carefully review the entire body of zoning and subdivision regulations to ensure that new provisions requiring bicycle and pedestrian access do not conflict with or contradict existing provisions.

MTO Province Wide Cycling Strategy – CWATS Committee Comments Page 3 of 7 November 30, 2016

As requested, the CWATS Committee provides specific response to the questions identified in the EBR: Plan to Improve Commuter Cycling Networks 1. What infrastructure should be prioritized to make cycling in Ontario safer and more convenient to support commuter cycling between residential communities, major transit stations, employment areas and other destinations travelled to on a frequent basis?  The County of Essex and their partners have created a substantial network of multi-use paths, trails and other non-road infrastructure for use by bicyclists throughout the region. A significant amount of the ‘priority’ routes align with local facilities already built such as: i. Sections outlined as a primary routes have been built as safe off road facilities and are designated as Trans-Canada Trail (TCT), Waterfront Trail (WRT) and/or County Wide Active Transportation System (CWATS) facilities. The Provincial network needs to focus on other opportunities along the Provincial Highway right-of-way.  Provincial Barriers remain a concern. Lack of infrastructure at jurisdictional boundaries and safety concerns remain the most frequently mentioned barriers. Historically, multiple attempts to coordinate cycling infrastructure with the MTO has resulted in a mediocre or absent solution. Examples include: i. Rt. Hon. Herb Gray Parkway -  Direct investments in provincial highways in urban areas to create the conditions to increase cycling for commuting and other frequent trips, where safe and feasible to do so were not completed. Infrastructure that includes both on- and off-road cycling facilities were not completed at the Cabana/Todd Lane, Highway 3 intersection.  The relocation of the ERCA trailhead from the north side of Highway 3 to the south side of the Rt. Hon. Herb Gray parkway has resulted in discontinued off-road greenway. A cycling connection that is continuous, direct and convenient with grade separation would be required to connect the north side of the trail to the south side of the highway.  The new Detroit River International Bridge Crossing (Gordie Howe Bridge) is currently under development, and the main vehicular access to the plaza for the new Bridge will be via Highway 401, as a controlled access highway, and that route will not be accessible to cyclists. There is great interest on the part of many stakeholders to ensure that cyclists can use the new bridge; in order to do that, cyclists will need a way to access to the bridge plaza and safely connect to existing cycling routes.

MTO Province Wide Cycling Strategy – CWATS Committee Comments Page 4 of 7 November 30, 2016

ii. An active transportation bridge across Highway 401 was identified in the Lauzon Parkway Municipal Class EA however funding for the associated infrastructure has not been committed or secured by the MTO. iii. The Trans Canada Trail off-road trail was constructed parallel to Provincial Highway 77 however was re-routed (significant out of way travel) along County Roadways to the nearest MTO signalized intersection to allow for a safe passage as the MTO did not allow for a direct and convenient crossing along Highway 3. iv. There are some positive things happening. For example the MTO has permitted and funded the paved shoulders on a County Road at a provincial highway intersection. But there is still much work to be done before it is safe to cycle between destinations in Southern Ontario and more of these types of initiatives should be encouraged. (I.e. include all Provincial/Municipal intersections on the Provincial Cycling Plan.) 2. What evidence can demonstrate the impact of cycling infrastructure investments on the number of cyclists and on GHG emissions?  Infrastructure needs may vary depending on the type of rider (experienced versus more casual or less confident cyclists) as well as the type of trip (recreational or utilitarian) to be accommodated. Advanced bicyclists may be best served by making every street bicycle friendly whereas recreational riders and children may be best served by a system of bicycle paths and designated bicycle lanes on appropriate travel corridors.  The demand for bicycle and pedestrian facilities will be quite different in rural areas than in suburban or urban communities.  Metrics may include any/all of the following: i. Residents’ use of bicycle infrastructure; ii. Bicycle-related retail purchases; iii. Participation in bicycle-related tourism; iv. Attendance at local bicycle events. v. Leadership in embracing complete streets policies as having a major positive impact on bicycling and the local economy vi. Bicycle infrastructure investments in placemaking; a multi-faceted approach to the planning, design and management of public spaces Local Cycling Infrastructure 3. For local cycling networks, what types of cycling infrastructure would best support commuter cycling between residential communities, major transit stations, employment areas and other destinations travelled to on a frequent basis?

MTO Province Wide Cycling Strategy – CWATS Committee Comments Page 5 of 7 November 30, 2016

 Options include: shared on-street lane for bicycles and motor vehicles, designated bike lane, cycle tracks, paved roadway shoulder, off-road bicycle path, sidewalks and multi-use facilities.  A Dedicated Highway System for bicycles is recommended—officially recognized and signed bike routes that crisscross our region and ultimately the Province.  Priority routes that need to be identified in the Provincial Network include: i. Abandoned Canada Southern (CASO) Rail Line – Tilbury-Essex-Windsor - Currently identified as a blue line (secondary route) with incorrect alignment on the MTO mapping. The alignment needs to be adjusted and the priority should be identified as a ‘primary’ (preferred) route. Only a portion of this abandoned rail corridor is secured under public control and the remainder is at risk of being sold to private developers. The MTO is strongly encouraged to purchase and/or facilitate the purchase with local municipal government agencies to secure and develop the trail system as a high priority for this region. ii. Detroit River International Crossing – There has been a great interest on the part of many stakeholders and advocacy groups on both sides of the border to ensure cycling and pedestrian facilities are constructed on the new Gordie Howe bridge and supported with appropriate access and connection to the existing and planned facilities. iii. Ferry Services - The Ministry of Transportation provides year-round transportation service to Pelee Island from the Municipality of Leamington and the Town of Kingsville and should include adequate infrastructure and amenities to support cycling. 4. What types of cycling infrastructure on provincial highways would best support commuter cycling between residential communities, major transit stations, employment areas and other destinations travelled to on a frequent basis?  Remove the perception of the bicycle as a purely recreational vehicle and focus toward building infrastructure to make cycling a legitimate transportation option. Direct, convenient and safe infrastructure is required.  Historically, bike routes were only supported on side streets rather than main streets, forcing a problematic choice between comfort and convenience. This places an unintended emphasis on longer, faster commutes to work; when – with bicycle facilities on corridors people want to visit – many more could be convinced to make the slow, short jaunt to the supermarket, cafe, or doctor’s office.  Like the MTO’s Numbered Highways and many national routing systems, the Provincial Bicycle Route system should be designed to roughly follow a grid. Mainline routes are the major cross-country routes and are represented with one- or two-digit numbers.

MTO Province Wide Cycling Strategy – CWATS Committee Comments Page 6 of 7 November 30, 2016

 The MTO should focus their priority cycling routes along the same corridor right-of-ways that are provided for vehicles to allow for direct, convenient connections. Bicycle Parking 5. What types of bike parking facilities (e.g., bike racks, lockers, fee-based enclosures) are needed to support cycling for commuting and other frequent trips?  Accommodates a variety of bicycles and attachments  Provides security and longevity features appropriate for the intended location  Rack use is intuitive and affordable.  Part of a larger rest area - defined as level portions of a trail wide enough to provide wheelchair users and others a place to rest and gain relief from prevailing grade and cross-slope demands. Users can benefit from rest stops on steep or very exposed trails to pause from their exertions and enjoy the environment. Rest areas are most effective when placed at intermediate points, scenic lookouts, or near trail amenities and are furnished with benches, bicycle repair station including an air pump, water fountain, restroom, map of area bicycle facilities etc. 6. What types of government-owned, publicly accessible facilities should have bike parking?  Provide bicycle parking in public rights-of-way. Provide well-located secure bicycle parking at popular destinations in business districts and at other public sites.  Install bicycle parking at public centers.  Install bicycle parking on public rights-of-way in neighborhood commercial and downtown business districts.  Encourage private businesses to provide bicycle parking for their customers.  Install bicycle parking at transit stops and in parking garages.  Encourage the installation of high-security bicycle parking at existing worksites, schools, and high-density residential developments. 7. What types of transit or transportation stations should have bike parking to support improved cyclist access (e.g., GO Stations, LRT stations, bus terminals)?  All transportation stations (transit, rail, ferry, air, etc.) should accommodate cyclists.

MTO Province Wide Cycling Strategy – CWATS Committee Comments Page 7 of 7 November 30, 2016

8. What types of private facilities could potentially be eligible to receive provincial funding for bicycle parking facilities?  Any private entity interested in improving health outcomes, promoting conservation efforts, stimulating economic development, providing recreational opportunities, or improving equity through transportation options. Sincerely,

Jane Mustac, P.Eng. Chair, CWATS Committee cc: Town of Amherstburg –Todd Hewitt Town of Essex – Chris Nepszy Town of Kingsville – Andrew Plancke Town of Lakeshore – Chuck Chevalier Town of Lasalle –Larry Silani Mun. of Leamington – John Pilmer Town of Tecumseh – Brian Hillman ERCA – Kevin Money WECHU – Cathy Copot-Nepszy Mun. of Chatham-Kent – Genevieve Champagne City of Windsor – Jennifer Leitzinger MTO – Paul Santos

[Original Comment ID: 209421]