I am writing to you as a…

I am writing to you as a resident of Ontario, in the City of Ottawa and a professional transportation planner. I am dismayed as I read the news release from the Province of Ontario dated October 21, 2024 for the Reducing Gridlock, Saving You Time Act. There is little to no information about the act and no resources citing research or informed policy information for many of the changes proposed in the act. The omnibus nature of this act is opaque and undemocratic. Why are all these disparate policies being compiled into a single act? That does not provide sufficient opportunity for discussion and each policy to be examined and judged on their own merit. Each of these new policies and actions need to be discussed on their own. With that said, I applaud your interest and attempt to speed up the process for government action. There are numerous crises in Ontario today being most keenly felt by those experiencing poverty, unstable housing and broader unaffordability, not to mention addictions and mental health, and they need our governments at all levels to take swift, bold actions to work towards sustainable decisions.

There are many issues I take with ranging proposals within the proposed legislation, but I want to focus my attention on this email regarding the proposed new approval process for the installation of new cycling infrastructure. With this issue I speak from a place of expertise and close experience, having worked in the profession for over 8 years, and having worked on transportation projects ranging from master plans, feasibility studies, and projects through the design process that have then been implemented. The idea that municipalities who need to receive approval from MTO before implementing a project is deeply concerning, as it is directly disentitling municipalities to their jurisdiction and creating new layers of red tape that will lead to slowing down an already lengthy, arduous process for a municipality to implement an infrastructure project. At what point in the process would a municipality need to get approval from the province? So often infrastructure projects that include bike lanes are part of initiatives stemming from the municipality's core policy and planning documents including their Official Plan, Transportation Master Plan, a Road Safety Plan, or Climate Action Plan. All these plans are developed through intensive, thoughtful processes that most often include public engagement, and build upon research and best practices. These documents are wide ranging, and broadly setting directions for a community, and responding to the needs of the community, helping it grow and prosper. These documents reflect the community and direct staff towards actions to respond to their needs towards realizing the community's vision and goals. Your proposed policy directly denies for these communities to direct themselves and respond to the desires of their residents and their needs. Would it be here that a municipality would need to seek prospective approval even though a lane removal is just a potential option that could be to help more affordably or rapidly enact infrastructure changes that stem from their policies? If not, then would it be at some point as the municipality takes a project through preliminary design, functional, or detailed design? What moment do they need to pause a project that they have likely engaged a consultant to complete, and put it on pause until it receives approval from MTO? This would add an additional step, and introduce friction into a business engagement and remove predictability, very likely leading towards increased costs for already cash-strapped municipalities due to requiring more project time and an unclear path forward for the consultant.

I could also comment on the vagueness of the proposed legislation that projects will have to "demonstrate that the proposed bike lane will not have a negative impact on vehicle traffic". This is an incredibly single-minded proposal that maintains the status quo in which we are experiencing increasing congestion. It doesn't consider the potential multitudes of benefits of bike lanes which have been rigorously researched in Ontario, Canada, and internationally, and instead decides negative impacts for motor vehicle traffic are the only perspective that matters. This neglects the experience, safety, and needs of the senior getting exercise, the parent cycling with child, the student, the commuter, the person without a drivers license because they can't afford to own or maintain a car or physically not be able to drive. And what is a negative impact? How do we quantify it? Is it any increase in travel time along a corridor? What if there are benefits for people driving motor vehicles from the project like a decrease in the number and severity of collisions? Do those override the negative impacts? What if the project means that a parent driving doesn't need to pick up their young teen after school, because now they have a safe way to bike home, which would provide the parent with real time and money savings. Now that's a benefit!

A single segment of bike lane in isolation may seem unnecessary, that it doesn't provide or get adequate use. I'd like to challenge that notion, and put it in a network perspective. When we travel by car through our cities we are able to travel on numerous routes of our choosing to access any destination, door to door. People who are cycling can use roads, but many - particularly arterial roads have high vehicle speeds and volumes that make cycling very uncomfortable and unsafe, so much so that while the majority of the population wants to cycle, they won't, because they don't feel comfortable and safe to do so. Bike lanes, especially ones with physical separation, create conditions on these arterial roads for people to feel comfortable using them. Very often everyday destinations such as schools, grocery stores and services are along these arterial roads, so people will only choose to access them if they feel comfortable cycling on that arterial road.Other times, that arterial road will be the only direct route through a community to connect between different neighbourhoods. We weigh directness, feasibility of cycling infrastructure, and latent demand when we develop proposed cycling networks for communities. The proposed legislation would set back hard work completed by the municipalities on developing networks. We know that if there's even one weak link in a network, like a stressful road, people will choose not to cycle for that trip.

I hope that you have read and reflected on this email and consider how it aligns not only with provincial policy including past and current Provincial Planning Statements but also your own rhetoric about removing red tape, responding to the needs of Ontarians in this moment, and for a better, healthier, and more affordable future.