I am writing to express my…

I am writing to express my strong opposition to the proposed Bill 212, Reducing Gridlock, Saving You Time Act, 2024, in particular Schedules 2, 3, and 4 relating to highway construction, provincial approval of bicycle lanes, and removal of bicycle lanes on Bloor Street, Yonge Street, and University Avenue in Toronto.

I strongly agree with the submissions provided by various organizations in opposition to the provincial upload of bicycle lane approvals and the proposed removal of bicycle lanes in Toronto, including the City of Toronto, Ontario Society of Professional Engineers, Ontario Professional Planners Institute, and Ontario Traffic Council. Bill 212 proposes needless and harmful provincial intrusion into municipal planning and engineering authorities. It will create red tape that will delay and increase costs for bikeway and other road construction projects. The fact that so many transportation and planning experts oppose this legislation demonstrates the lack of evidence supporting the proposed legislation.

Roads should be designed and built with consideration of its use over all times of day, not just peak periods. Roads designed to accommodate peak hour demand are overbuilt for much of the rest of the day, encouraging higher speeds which increase the frequency and severity of collisions. Roads that are overbuilt are also more expensive to build and maintain. This legislation will be an obstacle to projects that reallocate road space on roadways for bicycle lanes, driving up costs of future municipal and provincial infrastructure projects due to the need for larger roadways, longer or wider structures, and more relocation of curbs, drainage, and utilities to implement bikeways in the boulevard.

Reallocation of motor vehicle capacity to other modes improves road safety for all road users, not just people cycling. Road diets are a proven countermeasure to reduce collisions, as researched by the US Federal Highway Administration. In addition to pedestrians and people cycling, it's likely that more motor vehicle drivers and passengers will be seriously injured or killed as a result of this bill. Instead of getting home a few minutes quicker, a higher number of motor vehicle users will end up going to the hospital instead, or never make it home at all.

If the Province wants to spend money supporting congestion relief in Toronto, there are many other projects that would be more effective than removing existing bicycle lanes. Any funding should instead be used for more productive projects to relieve congestion, such as targeted modifications to address operational needs on these corridors (including for accessibility), more adaptive "smart" signals on these and other corridors, more frequent GO bus and rail service, and measures to reduce duration of vehicle lane, bicycle lane, and sidewalk closures on Provincial projects.

The proposed creation of an entirely new and dedicated approval process for bicycle lanes is even more red tape. In the past, certain bicycle lane projects - particularly those involving lane removals - were subject to the Municipal Class Environmental Assessment process. This process is a frequently used process with which professionals in government and the private sector are well acquainted. If Bill 212 is passed, the regulation should adopt existing approval processes for which there is an established and familiar process, preferably the Municipal Class EA or its proposed successor.

I am also opposed to the Highway 413 Act, exemption of Highway 413 from the Environmental Assessment Act, the Highway 413 project as a whole, and other proposed measures to accelerate highway construction, such as those related to property acquisition and overriding of municipal by-laws that may limit work.