June 10, 2025 Ministry of…

June 10, 2025

Ministry of Transportation
Transit Delivery and Partnerships Branch
777 Bay Street, 30th floor
Toronto, Ontario
M5G 2E5

Re: Amendment to the Building Transit Faster Act, 2020 (ERO 025-0450)

To whom it may concern:
Peel Region appreciates the opportunity to comment on Amendment to the Building Transit Faster Act, 2020. Peel Region staff generally support the Ministry’s proposal, and we offer the following comments and questions for consideration.
PEEL REGION STAFF COMMENTS
The comments contained in this correspondence are provided by Peel Region staff and will be considered by Regional Council for endorsement. If additional or differing comments are provided through a Council resolution, they will be forwarded to the Ministry for consideration.
Public Works Considerations

Peel Region staff welcome Metrolinx’s revised definitions within the proposed legislative changes, which now appropriately include transit projects within the region, such as the Hazel McCallion LRT, Queen Street BRT, and others. Peel Region also supports the proposed due diligence amendments, as they help expedite project delivery processes, including access permissions, utility relocations, and permitting. Accordingly, the Region recommends considering amendments to the Public Highways Act to mitigate potential delays to municipal projects.

Regarding backstop authority, Peel Region is concerned about the potential for constructor conflicts and recommends that reasonable deadlines and terms and conditions are put in place and respected. Coordination with existing road occupancy permit holders is essential to avoid such issues. Further, the requirement to obtain a corridor development permit could significantly delay municipal projects if objections arise from Metrolinx. Peel recommends replacing the permit requirement with a coordination and liaison process to ensure timely project delivery.

With respect to any proposed higher-order transit projects within Regional road rights-of-way (ROW), Peel requests that contractors working on behalf of the Ministry of Transportation and/or Metrolinx continue to work with the Peel’s road occupancy permit process to coordinate road works in a safe and efficient manner. Given the complex nature of higher-order transit projects, Peel Region staff recommend submitting complete road occupancy permit applications no less than six weeks prior to the intended start date of a project taking place within Regional ROWs.

Additionally, corridor permits for access to water and wastewater infrastructure to support new housing development has been a key issue of concern. Peel Region feels a defined standard approach to permitting third party access to infrastructure is essential. Notably, on the Hazel McCallion LRT, this issue has caused significant delays to development being able to access infrastructure, as no process is available and no standard for future connection post-construction was completed.

Peel further requests that the Ministry endeavour to work with Peel Region to assess the temporary traffic impacts of parallel corridors during construction of higher-order transit infrastructure, particularly when one of those parallel corridors falls under Peel’s jurisdiction, to assist Peel with signal timing adjustments based on forecasted results. Peel also requests that any deployment and operation of temporary traffic control signals within a higher-order transit project construction zone be integrated with the surrounding traffic control signal network so that the construction zone traffic control signal network is not operating in isolation with the broader traffic control signal network. This can help to reduce spillback queuing because of uncoordinated traffic control signals within proximity of each other.

Overall, it is important to ensure Peel Region is brought into the process during the initial planning stage of a project, so there is adequate time to understand the extent of Peel staff involvement, impact on Peel assets, and to allow the necessary work plans and agreements to be put in place prior to work beginning. Changing development priority areas results in the need for an agile approach to infrastructure planning, and as such the impact on Peel's current and planned infrastructure will need to be considered for all transit projects. Peel staff would also like to request the Ministry clarify whether exempting approvals also applies to maintenance agreements, which could potentially impact road works.

Building Transit Faster Act Part II Section 13 says the Minister may notify a property owner “that the alteration or removal of the thing on their property is required” and “that municipal service and right of way access is required”. Peel Region staff recommend that notification to the owner be mandatory.

Environmental, Energy and Climate Change Considerations

Peel Region is encouraged that the proposed legislation includes strategies for mitigating environmental impacts. However, Peel recommends that to meaningfully address environmental and climate impacts, strategies must be precise, measurable, and enforceable. Peel recommends the Ministry consider a risk-based approach paired with transparent, standardized metrics to define what is considered “significant.” Without this clarity, there is a risk of underestimating cumulative and long-term environmental impacts. Future-oriented assessments and engagement with impacted and vulnerable communities are essential to ensure the assessments reflect their experiences and needs.

Further, replanting strategies should account for ecological equivalence, as mature trees provide far greater ecosystem services than saplings. Efforts should aim to restore lost ecosystem functions, not merely replace tree counts.

Peel Region advises that clear targets, timelines, and defined emission scopes are necessary for effective greenhouse gas reduction. References to “sustained efforts” and “technological innovation” are most effective when they are actionable and aligned with climate-science pathways.

Peel Region appreciates that the Province is mindful of environmental strategies and encourage continued communications in this space to maximize their potential and limit the discretionary perception that accompanies phrases such as “to the extent possible” or “embracing the idea”, as they make green building commitments sound optional.

Beyond minimizing energy consumption, it is important to integrate resilience and human-centered design into green building practices to ensure long-term sustainability and community well-being. Peel Region hopes the Ministry will encourage the adoption of a mandatory framework to ensure new infrastructure both reduces GHG emissions and supports adaptation to climate impacts.

Public Health Considerations

Peel Region recognizes and agrees that public transit infrastructure can support the health and well-being of residents by promoting physical activity, road safety and health equity. In alignment with the Ontario Public Health Standards to support chronic disease prevention and well-being through supportive built environments, Peel requests that the Ministry consider embedding opportunities to assess project-specific health impacts during the early planning and consultation on the design of transit projects to support the development of healthy communities and reduce risks to resident's health where possible.

CONCLUSION

Peel Region asks that the Ministry consider the comments provided herein to inform its decisions on the proposed amendments. Should the proposal advance, Peel Region looks forward to participating in the consultation on the draft regulation.

Your consideration of our comments is greatly appreciated. If you have any questions or require more information, please contact me at lauren.crawford@peelregion.ca.

Kind Regards,

Lauren Crawford
Director, Transportation
Region of Peel, Public Works