I am writing regarding the…

I am writing regarding the proposed framework requiring provincial approval for municipal bike lanes. 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

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
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
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.
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
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:

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
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
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.

--

https://www.cycleto.ca/an_update_on_bike_share