Below are Peel Region's…

Below are Peel Region's comments on the Bill 212 Reducing Gridlock, Saving You Time Act 2024 – Framework for bike lanes that require the removal of a traffic lane (ERO 019-9266).

We thank the Ministry of Transportation (MTO) for the opportunity to comment on amendments to the Highway Traffic Act regarding bike lanes in Bill 212, Reducing Gridlock, Saving You Time Act 2024. Creating communities for life is a priority for Peel Region, and this includes providing safe, convenient, and equitable options for people to get around within their community.

While Peel Region shares the importance of finding solutions to tackle traffic gridlock, there a number of challenges with the bike lane proposals in Bill 212, including the framework not aligning to or supporting Peel Region’s various transportation plans and strategies and the lack of clarity with a few provisions. In addition to these issues, Peel Region staff want to highlight the social and environmental benefits of bike lanes.

Peel Region staff’s specific comments on the proposed legislation regarding these issues and benefits are outlined below. Please note that the following comments are provided by Peel Region staff and may be considered by Regional Council for endorsement at a later date. If additional or differing comments are provided through a Council resolution, they will be forwarded to the Ministry for consideration.

PEEL REGION STAFF SPECIFIC COMMENTS
Bike Lane Framework Not Aligned with Peel Region’s Transportation Plans & Strategies
Peel's Transportation plans and strategies are being updated to align with the 2024 Provincial Planning Statement, which is supportive of using bike lanes. The Province’s bike lane framework is not aligned and may impact Peel Region’s ability to achieve the goals and vision set out in its various transportation plans and strategies. These impacts are highlighted below:
• Peel's Long Range Transportation Plan supports providing residents and commuters with a variety of travel options, including bike lanes, that support community connections, enhance public health, air quality, and mitigate climate change. The proposed legislation limits Peel's ability to plan for and achieve this vision, including reaching our climate change goals.
• In planning for complete roads that support multiple modes of transportation, removing bike lanes poses serious safety risks. Peel Region's Vision Zero road safety plan prioritizes safety over other factors such as cost, speed, delay, level of service, and convenience, as no loss of life is acceptable due to a motor vehicle collision. Any restriction on bike lanes may interfere with Peel's ability to achieve the outcomes of Vision Zero and put cyclists at unnecessary risk.
• The Region's Sustainable Transportation Strategy aims to achieve a 50% sustainable mode share by 2041. One of the actions for achieving this goal is to encourage and support cycling to and from schools, transit hubs, and other community destinations. Bike lanes are an important part of making trips such as these, as well as connecting trips to and from transit, known as the first and last mile. The bike lane amendments in Bill 212 could impact local municipal and Regional planned cycling networks, that are central to achieving Peel Region’s 50% sustainable mode share goal alongside other modes of active transportation as well as public transit.

Some Bike Lane Framework Provisions Require Greater Clarity
Certain provisions in the Province’s proposed bike lane framework need further clarification as they could affect existing bikes lanes or planned bike lanes as well as apply to multi-use paths. Greater clarity and more information are needed to determine financial, social and property impacts. The provisions and matters in question are outlined below:
• In the provision for the supply of municipal data and Ministry review of existing bike lanes created by converting or removing any traffic lanes, no timeline is given under Schedule 4, Part XII, 195.2 regarding how far back the Ministry would review existing bicycle lanes on municipal roads. If these bike lanes are reverted to traffic lanes, there could be major implications in terms of the function, conversion, and connectivity of Peel’s transportation infrastructure, including financial, social or property impacts.
• The proposed legislation is unclear whether it applies to dedicated bicycle lanes only or any type of cycling infrastructure, such as multi-use paths, which provides accessible and equitable travel options for all users including cyclists, pedestrians, and wheelchair users. If the legislation includes multi-use paths and cycling infrastructure that could be discontinued at highway crossings, this could affect Peel’s Active Transportation Strategy. Additionally, it may pose challenges in terms of time and resources needed for the Ministry’s approval process.
• Schedule 4, Part XII, 195.2 subsection (1) suggests that Regional and municipal roads with existing or planned bicycle lanes impacted by Highways may be considered for removal, which would significantly impact the planned cycling network and cause disconnections and separation between communities.
• As Regional Roads are typically major arterial roadways and support heavy truck traffic, bicycle lanes are often screened out for on-boulevard facilities. In rural areas where roads are not urbanized, Peel provides a wider paved shoulder which functions as an “accessible shoulder” for pedestrians and cyclists. The Region is unclear as to whether these accessible shoulders would be impacted by the proposed legislation. On rural non-urbanized regional roads, wider paved shoulders serve as joint use for pedestrians and cyclists. It is unclear in Bill 212 if these accessible shoulders will be affected by the proposed legislation.

The Benefits of Bike Lanes
The installation of bike lanes on municipal road has several financial, health and environmental benefits, which are detailed below:
• Bicycle lanes can increase safe access to low-cost mobility for lower income populations, provide first- and last-mile connections to support public transit use as previously mentioned, and expand access to employment opportunities. The language in Bill 212 suggests the prioritization of vehicles over other types of travel, including active transportation, which may further marginalize those who rely on active transportation as a primary method of transportation (particularly among transportation-disadvantaged groups such as seniors, youth, and low-income residents, for example). Peel Region advocates for equitable travel options for those who cannot afford to drive, or where transit is not available, which is currently the case in many rural areas within the Region.
• Peel Region continues to advocate for a modal split that promotes the benefits of active transportation, which include financial, health, and environmental benefits including the reduction of greenhouse gas emissions.
• The Financial Accountability Office of Ontario recently reported that as climate change continues to be present in Ontario communities, the cost of maintaining road network infrastructure will escalate. Peel Region advocates for fiscal prudence on behalf of residents and taxpayers, including exploring and allowing for less costly alternative transportation infrastructure such as bicycle lanes.
• Furthermore, shifting travel behaviours away from single-occupancy vehicle travel and towards more active/sustainable travel modes can improve local air quality and reduce greenhouse gas emissions.
• The proposed legislation may have negative impacts on health outcomes among Peel residents by creating barriers to building healthy, complete communities with safe, connected multimodal infrastructure. Evidence demonstrates that bicycle lanes enable active living, advance health equity, address the health-related impacts of climate change, and improve road safety.
• Evidence indicates that providing safe, comfortable, and connected walking and cycling infrastructure encourages active transportation, a proven way for residents to incorporate physical activity into their day that can lower the risk of chronic diseases associated with inactivity and improve mental wellbeing.

Conclusion
Peel Region staff have identified a number of issues for consideration regarding Bill 212 framework for bike lanes. The proposed bike lane framework is not aligned with the Region’s various transportation plans and strategies and may limit its ability to improve road safety, provide residents more travel options and achieve a 50% modal split. There are also certain components of the proposed bike framework that need to be clarified in order for Peel Region to properly determine any financial, social and infrastructure impacts. Finally, we highlighted some of the financial, health and environmental benefits of installing and expanding bike infrastructure networks.