There are numerous issues…

There are numerous issues with this Bill and Proposal. This comment will first cover the proposal details provided by the ERO and then the contents of the Bill itself.

Proposal Details - October 31 update
"...addendum to the framework that would require the province to remove sections of the Bloor Street, Yonge Street, and University Avenue bike lanes in the City of Toronto and return them to a lane of traffic for motor vehicles" - overstep of the province into municipal responsibilities and expertise. This language also wrongfully implies that motor vehicles should be the default mode of travel on roads.

"...provide the province with the authority to establish a review process on other existing bike lanes (where the removal of a lane of traffic took place)" - again encroaching on municipal affairs, especially when lane installation already goes through review processes. The lane is still a lane of traffic.

"Approval will be based on a set of specified criteria, to be set out in guidance and/or regulation. The criterion for the assessment of existing bike lanes will consider environmental implications and be developed in consultation with targeted stakeholders including large municipalities." - Why are criteria not already established or examples provided? The environmental implications of bike lanes are obvious, in that they facilitate travel that does not produce GHG emissions or noise pollution.

Proposal Details - bullet points
"Recognizes the need to build priority highways faster as our province grows in order to get people and goods out of gridlock and save drivers and businesses time and money" - with the current level of sprawl and congestion in the province, greater focus should be placed on enhancing alternative modes of travel. By shifting more drivers to other modes, they may be able to save even more money by not having to have a motor vehicle. The drivers that remain will consequently see lower congestion due to fewer vehicles on the road in general.

"Recognizes that accidents and lane closures can worsen traffic congestion and impact the quality of life of Ontarians" - another approach would be to reduce the number of cars on the road, thereby reducing chances of accidents. Quality of life is also impacted literally when people are killed in accidents.

"Is building Highway 413, recognizing the importance of this highway to millions of drivers from across Ontario" - this project has already been demonstrated by transportation analyses and models to save minimal time for a small portion of people at the cost of vital ecological and agricultural land

Proposal
"...Ontario is looking to fight gridlock and get drivers where they need to go faster." - the Province should focus on projects that benefit people who use all different travel modes.

"Prescribed municipalities would be required to seek provincial approval to allow for the implementation of new bicycle lanes...that require the removal of an existing lane of traffic." - this proposal also assumes that bike lanes increase congestion when the opposite has clearly been demonstrated worldwide.

"Additional authorities to facilitate the removal of these lanes would also be included in the legislation including an exemption from the Environmental Assessment Act" - this is a completely different subject than reviews of bike lanes, and should not be included in the same Bill.. The EAA is necessary to ensure the safety of our province's vital ecological and agricultural lands, the removal of which directly harms the lives of the plants and animals living there as well as Ontario citizens.

"...and the requirement for the City of Toronto to provide support to facilitate the removal of the bike lanes." - as this is a Provincial proposal to directly manage municipal affairs, the City should bear no responsibility.

Other parts of the Bill
Schedule 2
"Delivery of goods and services to facilitate 24 hour construction" - likely to cause further noise pollution issues with people and animals

Schedule 3
"Activities before process completed" - the activities listed in this section seek to circumvent the EAA by making progress before specific assessment steps are fulfilled properly

Schedule 4
"Ministry approval for bicycle lanes required" - the time and money spent on this endeavor does not seem to be the best approach. It suggests a lack of trust in municipalities and a desire for increased Ministerial oversight.

"Consideration of traffic flow

(4) When considering whether to approve the design for the construction of a bicycle lane, the Ministry may consider whether it would unduly diminish the orderly movement of motor vehicle traffic." - there is no objective measure to what is considered "unduly diminish". This also once again sends a clear message that motor vehicles are more important than the people in them and the people who do not drive.

Ultimately this Bill is very flawed. There are five main schedules proposed that cover a wide range of subjects and should not be combined into one Bill. There is no mention of a plan to replace or install safer cycling infrastructure if lanes are removed. The Bill is written under a false assumption that increased lanes reduce congestion when the opposite has consistently been demonstrated. The environmental impacts of increased driving are not considered and promoting increased driving is counterproductive to current climate action and goals. The cost of removing the bike lanes could be spent on other initiatives such as transit projects or in other sectors.

For municipalities with very little of non-existent cycling infrastructure, those sections have almost no impact and may in fact make it more difficult in the future should the demand arise. For the City of Toronto specifically, the Province is directly targeting specific installations that citizens rely on for safe and convenient travel. Street parking also removes lanes of traffic and are inconvenient because cars take up more space than bikes and make it more difficult for all travelers to navigate streets. Businesses will also be affected as the reduction in bike lanes make it more unsafe and difficult to stop and go into a business while driving along with many other cars.