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 and Schedule 4.

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?

My issue with Schedule 4 is the Ministry of Transportation, a provincial body, is requiring information from municipalities to prove the benefits of bicycle lanes to ensure drivers are not negatively impacted and it will approve what the municipalities can and cannot do. This is overstepping the ministries jurisdiction. The ministry had gone to the Supreme Court of Canada for a similar issue with regards Highway 413 not long ago as well. Highway 413 was designated for a federal impact assessment and the ministry argued that the federal government had overstepped their boundaries. This is the exact same thing that is happening, but not it is the provincial government overstepping boundaries into how municipalities choose to govern themselves.

It is also hypocritical of the Ministry to require data and then decide if it will approve the implementation of bike lanes. Where was all the data and information with regards to Highway 413 that led to the decision that it must be built? The Highway 413 site (https://www.highway413.ca/2021/03/31/timesavings/) states that, "not everyone will enjoy the direct benefit of time savings" and then argues other examples such as building hospitals and how it benefits the local residents in the area. The same argument that they use to argue for Highway 413 applies to the bike lanes they want to limit and even remove along Bloor, University, and Yonge. There is a group of people who benefit from the bike lanes, but that is not enough to expand the bike lane networks anymore, yet it is enough to argue for more highways.

There have been multiple studies on the return on investment when investing in cycling networks in cities. Australia's Queensland government has a website (https://www.tmr.qld.gov.au/travel-and-transport/cycling/cycling-strateg…) speaking about the topic. They invested into their cycling networks and wanted to promote a more active lifestyle for their citizens. They found that for every dollar they invested into the cycling infrastructure, it led to approximately 5 dollars worth of benefits. This came in the form of improved health benefits and reduced traffic congestion to name a few.

Expanding the cycling network also helps deal with the first/last mile issue, where people using multiple forms of transportation require more options for the first and last mile of a trip. Cars and walking are typical forms, but cycling also can be used to solve this issue as the individual can go wherever they need to and are not limited by the predetermined routes used by buses and trains.

Overall, alternative methods, including cycling, should be explored and developed more to reduce traffic congestion, improve the health and quality of life of citizens, and reduce GHG emissions and pollution. Just like how induced demand applies to new highways and roads, it applies to cycling networks as well. The amount of people using Bike Share programs in Toronto has been dramatically increasing over the years. People want to cycle, but they want to be safe when doing so.