This proposal raises…

This proposal raises significant concerns when evaluated against both the fundamental rights established in the Environmental Bill of Rights (EBR) and the Ministry's Statement of Environmental Values (SEV).

Fundamental Right to a Healthful Environment
The EBR, as referenced in your SEV, establishes that "the people of Ontario have a right to a healthful environment." This fundamental right must be understood to encompass our urban environments, where the majority of Ontarians live, work, and move through daily. Consider that:

- Urban environmental health directly impacts human wellbeing through:
* Air quality at street level where people walk and bike
* Noise levels that affect mental and physical health
* Safe spaces for active transportation and community interaction
* Access to sustainable transportation options
* Street-level temperatures and urban heat island effects
* Overall quality of life in our communities

- Bike lanes contribute substantially to this healthful urban environment by:
* Creating safer streets for all users, including pedestrians
* Reducing local air pollution exposure through decreased vehicle traffic
* Decreasing noise pollution that impacts sleep, cardiovascular health, and cognitive development
* Enabling active transportation that improves public health
* Building more livable, human-scaled urban environments
* Supporting sustainable urban development patterns
* Providing equitable access to transportation options

The proposed framework, by creating barriers to bike lane implementation, risks infringing upon this fundamental right to a healthful environment. The EBR's mandate "to protect, conserve and where reasonable, restore the integrity of the environment" must apply to our urban environment where environmental quality directly impacts human health and wellbeing.

Specific Concerns with the Proposed Framework

1. Contradiction of Multi-Modal Transportation Goals
Your SEV explicitly commits to "promoting a multi-modal transportation network, including active transportation." Most notably, your SEV specifically recognizes that improving "public transit and active transportation networks" helps "manage congestion and reduce gridlock." However, the proposed framework:
- Contradicts your own policy position that active transportation helps reduce congestion
- Creates new barriers to implementing active transportation infrastructure that could help manage gridlock
- Prioritizes single-occupancy vehicle traffic over sustainable transportation options that could reduce overall congestion
- Undermines your priority of "increasing transit ridership" by making it harder for people to bike to transit stations
- Contradicts your commitment to "promote an integrated transportation system that facilitates the use of public transit, active transportation, and other modes"
- Places an undue burden on municipalities trying to develop integrated transportation networks that could help reduce gridlock

2. Environmental Assessment Concerns
While the proposal states that "implications to the environment will be considered," this approach appears insufficient given your SEV commitments to:
- "Integrate sustainability into the ministry's decision making, programs, policies and operations"
- "Reduce transportation-related air emissions"
- "Reduce transportation-related discharges of contaminants to water"
- "Support the Government of Ontario's initiatives to conserve energy"

The framework should require comprehensive environmental impact assessments that consider:
- Air quality impacts
- Stormwater runoff contamination from increased vehicle traffic, including:
* Oil and gasoline leaks
* Tire particles and microplastics
* Brake dust and heavy metals
* Road salt and de-icing chemicals
* Sediment and debris
- The cumulative effect of these contaminants on local watersheds and water quality
- The relative benefits of bike infrastructure, which produces virtually no water pollution

3. Climate Change Obligations
Your SEV specifically commits to:
- "Reduce the impact of Ontario's transportation sector on greenhouse gas (GHG) emissions"
- "Increase the availability of sustainable modes of travel"
- "Support Ontario businesses in developing sustainable new mobility technologies and innovations"
The proposed framework makes it harder to achieve these objectives by creating additional obstacles to sustainable transportation infrastructure.

4. Evidence-Based Decision Making
The proposal's narrow focus on traffic impacts:
- Ignores your SEV commitment to consider integrated "social, economic, and scientific considerations"
- Creates an asymmetric burden of proof that applies only to sustainable transportation infrastructure, where:
* Only bike lanes must be justified with data
* No similar requirements exist for car infrastructure
* Municipalities face extra administrative burdens for sustainable options
* The default assumption favors car infrastructure without equivalent scrutiny
- Overlooks the comprehensive benefits of bike lanes, including:
* Reduced air pollution from decreased vehicle traffic
* Significantly lower noise pollution, which research has linked to:
- Cardiovascular disease
- Sleep disturbance
- Cognitive impairment in children
- Mental health impacts
- Reduced property values
* Improved public health outcomes through active transportation
* Enhanced road safety for all users
* Economic benefits for local businesses and communities, including:
- Increased retail spending from bike and foot traffic
- Higher property values on calmer, more livable streets
- Reduced road maintenance costs
- Greater neighborhood desirability
* More equitable transportation access

5. Municipal Planning Integration
Your SEV emphasizes "promoting the integration of transportation, land use and environmental planning in decision making." However, this framework:
- Undermines municipal authority to implement context-appropriate transportation solutions
- Creates regulatory uncertainty for municipalities planning long-term transportation networks
- May discourage municipalities from pursuing active transportation projects due to additional bureaucratic requirements
- Could delay implementation of urgent safety improvements

Recommendations:
1. Revise the framework to include comprehensive evaluation criteria that align with your SEV and the EBR's fundamental right to a healthful environment, including:
- Environmental benefits (both natural and urban)
- Public health impacts
- Safety improvements
- Economic effects on local businesses and communities
- Accessibility enhancements
- Climate change mitigation potential
- Integration with existing transportation networks

2. Ensure the "specified criteria" mentioned in the proposal:
- Reflect the full range of benefits that bike lanes provide
- Consider both immediate and long-term impacts
- Account for municipal transportation master plans
- Include environmental and health metrics
- Support the achievement of provincial climate targets
- Recognize the value of creating healthful urban environments

3. Modify the data collection requirements to:
- Include metrics beyond just traffic flow
- Consider seasonal variations in cycling usage
- Account for induced demand in both driving and cycling
- Measure safety improvements and public health outcomes
- Evaluate impacts on community wellbeing and urban environmental health

I urge the Ministry to align this framework with both its own environmental values and the fundamental right to a healthful environment established in the EBR. The current proposal risks undermining Ontario's progress toward creating healthier, more sustainable, and more equitable communities for all residents.