Submission on Bill 212:…

Submission on Bill 212: Reducing Gridlock, Saving You Time Act, 2024

I am writing to express my concerns regarding the provisions within Bill 212, Reducing Gridlock, Saving You Time Act, 2024, which would require provincial approval for municipal bike lanes. This proposal introduces significant challenges when evaluated against the foundational rights articulated 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 highlighted in your SEV, affirms that "the people of Ontario have a right to a healthful environment." This right is directly relevant to urban environments, where the majority of Ontarians live and work. Urban environmental health critically influences human well-being through:
* Air quality, especially at street level, where people walk and bike.
* Noise levels, which impact mental and physical health.
* Safe and accessible transportation options for active travel.
* Urban heat island mitigation and enhanced street-level temperatures.
* Quality of life in vibrant, livable urban spaces.

Bike lanes are essential to creating healthful urban environments. They contribute by:
* Improving road safety for all users.
* Reducing air and noise pollution.
* Promoting public health through active transportation.
* Supporting sustainable and equitable mobility options.
* Enhancing livability and fostering human-centered urban design.

By introducing barriers to bike lane implementation, Bill 212 risks undermining this fundamental right to a healthful environment. The Ministry’s commitment to "protect, conserve, and where reasonable, restore the integrity of the environment" must include urban areas where environmental quality directly affects health and well-being.

Concerns with Bill 212
Conflict with Multi-Modal Transportation Goals
The SEV emphasizes "promoting a multi-modal transportation network, including active transportation," recognizing that these improvements help "manage congestion and reduce gridlock." However, Bill 212:
* Contradicts the Ministry’s recognition that active transportation reduces congestion.
* Prioritizes single-occupancy vehicle infrastructure over sustainable alternatives.
* Undermines efforts to integrate transit and cycling networks.
* Places disproportionate administrative burdens on municipalities pursuing active transportation solutions.

Insufficient Environmental Assessments
While Bill 212 references consideration of "implications to the environment," this is insufficient given SEV commitments to:
* Integrate sustainability into decision-making.
* Reduce transportation-related air emissions and water pollution.
* Conserve energy and mitigate climate impacts.

Comprehensive environmental impact assessments should include:
* Air quality impacts from changes in transportation patterns.
* Water pollution risks from increased vehicle traffic, including oil, tire particles, and de-icing * chemicals.
* Comparative benefits of bike infrastructure, which has minimal environmental impact.

Climate Change and Sustainability Goals
The SEV outlines clear commitments to:
* Reduce greenhouse gas (GHG) emissions from transportation.
* Increase sustainable travel options.
* Support innovation in sustainable mobility technologies.

By creating additional obstacles to bike lane development, Bill 212 undermines progress toward these objectives and hinders Ontario's ability to address climate change.

Evidence-Based Decision-Making
Bill 212’s narrow focus on traffic flow data:
* Ignores the SEV mandate to consider "social, economic, and scientific considerations."
* Imposes asymmetric scrutiny, requiring municipalities to justify sustainable infrastructure while exempting vehicle-centric projects from equivalent assessments.
* Overlooks broader benefits of bike lanes, including public health, safety, environmental quality, and economic growth.

Municipal Planning and Integration
The SEV emphasizes the integration of transportation, land use, and environmental planning. However, Bill 212:
* Undermines municipal autonomy to implement locally appropriate solutions.
* Creates regulatory uncertainty that discourages innovative transportation projects.
* Delays critical safety improvements for cyclists and pedestrians.

Recommendations
To align Bill 212 with the Ministry’s SEV and the EBR, I recommend the following:

Revise Evaluation Criteria
Ensure criteria reflect environmental, public health, and safety benefits, including:
* Air quality improvements and climate mitigation.
* Urban livability and safety enhancements.
* Accessibility and equitable transportation outcomes.

Require Comprehensive Assessments
Expand data requirements to consider:
* Seasonal and induced demand for cycling.
* Public health and safety metrics.
* Community well-being and environmental impacts.

Facilitate Municipal Collaboration
* Streamline approval processes to support integrated municipal planning.
* Provide clear guidance to align local projects with provincial goals.

Conclusion
While the stated intent of Bill 212 is to reduce gridlock and save time, the evidence supporting additional car infrastructure as a solution to congestion is mixed at best. Research consistently demonstrates that expanding car lanes often leads to induced demand, where increased road capacity encourages more driving, ultimately exacerbating congestion rather than alleviating it. In contrast, investments in active transportation, such as bike lanes, have been shown to reduce congestion by providing viable alternatives to car travel.

By creating additional barriers to the implementation of bike lanes, Bill 212 risks undermining broader efforts to build healthier, more sustainable, and equitable communities. I urge the Ministry to revise this legislation to align with its commitments under the SEV and EBR, prioritizing evidence-based strategies that foster livable urban environments and truly address the root causes of gridlock.