The proposed amendment that…

ERO number

019-9266

Comment ID

114052

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

The proposed amendment that will require the removal of bike lanes on Bloor, Yonge and University appears to be completely arbitrary in targeting certain infrastructure before any consideration of expert advice or evidence relating to those specific facilities.

Hence the proposed amendment clumsily contradicts and undermines the Province's original proposal which describes a framework that would be created to assess existing and proposed bike lanes in the City by reviewing information provided to the Province. The Province's original proposal described an approval for existing/new bike lanes "...based on a set of specified criteria, to be set out in guidance and/or regulation." In other words, a clear intention to create "due process" for any potential removal of bike lanes.

But the new amendment prescribes the removal of the Bloor/Yonge/University bike lane infrastructure before any such 'due process' is allowed to even commence. On what basis are these particular lanes being identified as needing removal? I assume on the basis of the intuition of political leaders in the Province and/or based on ad hoc commentary from constituents who have no expertise in urban transport planning or highway safety.

The amendment therefore apparently directs government to expend public funds, management time and effort to manage the destruction of existing costly public infrastructure based on no process or substantiated fact-based evidence to support such action or to understand the socio-economic impacts on the wider community - a fairly good definition of grossly negligent governance.

And therefore why should City taxpayers be exposed to legal actions arising when such negligent government action results in death or injury to cyclists or pedestrians.

If this incompetent amendment cannot be withdrawn entirely on the grounds of it undermining the basic concept of 'due process' then it invites the logical question that if the Province judges a formal review process is of so little value for these particular bike lanes, then why doesn't the Province save us all a lot of time and taxpayer money by just directing all existing bike lanes to be destroyed with no further review process? And it shall be done, like a wise King's command.

If a formal review process has already occurred on these specified bike lanes then please share details with taxpayers so they are able to understand how due process is protecting their tax dollars.

If this illogical amendment is not withdrawn, then will the Province at least consider the following additions to the original proposal and/or the amendment to at least put some responsibility back on the Province for any adverse outcomes arising from its imposed actions and to give local planners the best chance to meet the demands of drivers and the local community:

1. The Province will reimburse the City of Toronto (or other applicable local authority) for all validated direct costs relating to any bike lane assessments processes and/or removals as prescribed by the Act;
2. The Province will indemnify the City of Toronto (or other applicable local authority) for all criminal or civil liability arising from death or injuries deemed by a Court to have been caused by the removal of the bike lane infrastructure; and
2. The Province to add to the stated exemption from the Environmental Assessment Act (for the prescribed removal of the Bloor/Yonge/University bike lanes) by also exempting bike lane reviews (whether existing lanes or new proposed lanes) from any Provincial laws/regulations that require individual lanes for vehicular traffic to be of a defined minimum width. In other words, to allow flexibility for planners to consider in these specific situations an alternative solution - the possibility of less wide traffic lanes to allow in this specific locations the accommodation of both an additional traffic lane as well as maintaining the assessed bike lane (existing or proposed).