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This comment is in opposition to the framework that would enable provincial approval for new bike lanes on municipal roads and to provincial involvement in the removal of the bike lanes on Bloor St., Yonge St., and University Ave.

The crux of this opposition is housed in the premise that a higher order of government cannot carry out the depth of analysis needed to establish what is best for traffic control within municipalities. Municipalities are not one size fits all and need flexibility to determine what is best for their residents instead of additional bureaucracy in the form of approvals from further levels of government.

As a resident of Toronto who walks, drives, takes, transit, and cycles I appreciate that wherever a bike lane is installed it is studied extensively and impact to motor vehicle travel times is always part of that consideration, before and after any installation. This data from the City should be reviewed before any removals are considered. The last time I attended to them I would say that on average the increase to motor vehicle travel times increased by 10 minutes on average. An increase of this degree is minimal and could never justify the risk to safety that will be incurred by all road users by their removal. I strongly echo the position of the 120 physicians and researchers signatories in the supporting link that "Legislation proposing to guide road design decisions, such as Bill 212, should explicitly place a higher priority on road safety than motor vehicle travel times." The costs that have already been incurred in the installation of these well-studied lanes and what would be incurred in their proposed removal also represent a wasteful expense.

Gridlock is an important concern but it is extremely questionable that it is caused by bike lanes. Municipalities would be best positioned to assess this but in my own experience (travelling regularly between Hamilton and Pickering) it is rampant across the GTHA whether there are bike lanes present or not. It is most certainly present on roads where bikes are explicitly forbidden.

It is important to flag that the three streets flagged for removal in Toronto (Bloor St., Yonge St., and University Ave) are all on subway lines. A far more impactful way to reduce gridlock on these roads would be to more adequately fund the transit that runs under them. As someone who has used these lines for decades I can note that the rider experience in them is worse than ever. At present there are 15 Reduced Speed Zones due to insufficient track repair and there are continuous delays due to safety alarms. In order to reduce gridlock there must be a focus on viable alternatives.