November 28, 2016…

November 28, 2016

Arielle Mayer
Senior Policy Advisor
Ministry of Transportation
Policy and Planning Division – Transportation Planning Branch
Environmental Policy Office (Toronto)
777 Bay Street, Suite 3000
Toronto, Ontario
M7A 2J8

Re: MTO Discussion Paper on Cycling Initiatives under the Climate Change Action Plan (ERB # 012-8772)

Dear Ms. Mayer,

Thank you for the opportunity to comment on the MTO Discussion Paper on Cycling Initiatives as part of the Climate Change Action Plan (ERB 012-8772).

The City of Brampton’s Strategic Plan, Official Plan, and Transportation Master Plan all support an increased focus on Active Transportation (e.g., cycling, walking) as a way to address current and long-term transportation network capacity challenges, health and environmental concerns, and the development of sustainable and “complete” communities. The City has also initiated an Active Transportation Master Plan to develop an implementation strategy for short and long-term actions that will achieve a comprehensive cycling network, and to see Brampton designated as a “Bicycle Friendly Community”. Provincial support through the Climate Change Action Plan (CCAP) is timely and could provide a significant resource for the City’s implementation strategy.

The City of Brampton has reviewed the MTO’s Discussion Paper on Cycling Initiatives under the Climate Change Action Plan (CCAP), and commends the Province for leveraging $150 to $225 million from the cap and trade proceeds to enhance and accelerate the implementation on #CycleON: Ontario’s Cycling Strategy. We are supportive of the proposed program and provide the following comments and responses to the questions included within the Environmental Registry posting.

Plan to Improve Commuter Cycling Networks

• What infrastructure should be prioritized to make cycling in Ontario safer and more convenient to support commuter cycling between residential communities, major transit stations, employment areas and other destinations travelled to on a frequent basis?

From Brampton’s perspective, in general, the implementation of safe and connected municipal cycling infrastructure is the key priority, and should be supported through provincial funding in order to achieve a range of shared local, regional, and provincial health, transportation, environmental, planning, and equity objectives. The Ontario Municipal Cycling Infrastructure Program (OMCIP) is an excellent example of how the province can support municipalities to improve cycling infrastructure. Based on our recent experience with OMCIP, we encourage MTO to acknowledge the lead time necessary for municipalities to respond to calls for funding applications and the time required for planning, design and construction. We share the Province’s interest in delivering new infrastructure as quickly and efficiently as possible, however if such projects are rushed then the benefit to the end users may be compromised. This should be acknowledged and considered when prescribing the timelines for municipalities to respond to and deliver on any CCAP funding program. For reference, a common “rule of thumb” is to allow three-to-four years for the delivery of new infrastructure projects: one year for planning and consultation, one year for design, and one-to-two years for construction.
Although this Discussion Paper appears to focus on infrastructure spending, we strongly suggest that the Province allocate a portion of funds for planning and policy work to further the goals of the CCAP related to cycling. Like many municipalities in the Province, we are faced with a myriad of challenges related to cycling policy, planning and design. The following list provides a few examples of these challenges:
•The need to develop a solution to allow cyclists to cross at PXOs without being required to dismount and walk;
•The need to update OTM Book 18: Cycling Facilities to reflect advancements in cycling facility design since 2013 (such as “protected intersections” and cycling-friendly roundabouts), and the significant amount of effort and background research that should feed into that update;
•The need for improved planning and design guidelines to safely and effectively accommodate cyclists (and pedestrians) at grade-separated highway interchanges; and
•The need to clarify and refine AODA requirements for infrastructure affected by the implementation of new cycling facilities, such as at signalized intersections and where cycle tracks are flush with the adjacent sidewalk.

These are a few examples of Province-wide challenges facing municipalities that require attention, and that could be addressed with a relatively small investment. Resolving these and other outstanding issues would help maximize the benefits of cycling infrastructure investments by ensuring that they address previously identified challenges.

• What evidence can demonstrate the impact of cycling infrastructure investments on the number of cyclists and on GHG emissions?

The City of Brampton’s Transportation Master Plan Update (2015) identifies the following set of performance indicators used to assess the current and future state of active transportation (AT) in Brampton. These indicators can be used to track demand for AT, utilization of facilities and the quality of infrastructure as the network evolves. Such practices also inform the development of future routes and network links.
•Mode share of pedestrians and cyclists;
•Interaction with transit;
•Percentage of short trips taken by car, bike and on foot;
•Safety of pedestrians and cyclists;
•Bicycle and pedestrian level of service; and
•User satisfaction.

Additional information on the aforementioned items is provided in Technical Report #5 Active Transportation. (http://www.brampton.ca/EN/Business/planning-development/transportation/…).

Local Cycling Infrastructure
• For local cycling networks, what types of cycling infrastructure would best support commuter cycling between residential communities, major transit stations, employment areas and other destinations travelled to on a frequent basis?

Local cycling infrastructure that would best support commuter cycling should be focused on improving cyclist safety and level of comfort rather than a specific facility type (such as a multi-use path or designated bicycle lane). The Bicycle Facility Type Selection guidelines outlined within the Ontario Traffic Manual (OTM) Book 18 provide a solid framework for identifying the type of cycling facility based on the site specific context (considering factors such as vehicle traffic speeds and volumes). Recognizing these context-sensitive approaches to cycling facility type selection and design is a better way to prioritize infrastructure improvements, as opposed to prescribing specific facility types. Many municipalities in the province have either completed or are in the process of completing thorough strategies that include recommended facility types for their networks. In this regard, the best infrastructure to support commuter cycling would be those identified in approved local municipal plans.

Provincial Cycling Infrastructure

• What types of cycling infrastructure on provincial highways would best support commuter cycling between residential communities, major transit stations, employment areas and other destinations travelled to on a frequent basis?

The City’s Transportation Master Plan Update 2015 identifies grade-separated Provincial highways (Highway 410 and Highway 407ETR) as major barriers to travel by bicycle within and between our communities. It is essential that any program or funding intended to improve conditions for cycling address the design of crossings at and over Provincial highways. Navigating bridges and interchanges as they are currently designed is a highly uncomfortable and unsafe undertaking for cyclists, to the extent that most will not even attempt it. The City of Brampton is eager to work with the MTO to improve cycling infrastructure at such crossings, including consideration of alternatives such as dedicated active transportation crossing structures. The proposed funding program for cycling should include crossings of Provincial highways within its scope to support commuter cycling in Ontario communities, including both ‘shared’ road crossings (highway interchanges, roadway overpasses and underpasses) and separated crossings (pedestrian and cycling bridges and tunnels).

The Hwy 407 Transitway presents an ideal opportunity to implement a continuous and generally uninterrupted cycling facility in a protected right of way that can enhance regional connectivity and improve active transportation access to commute destinations (including connections to intersecting north-south cycling infrastructure/routes, and to transit stations). The 407 Transitway Environmental Assessment is currently underway, and it is imperative that a cycling facility be considered in parallel with the transitway alignment. To neglect this would be to miss the best opportunity for building a key piece of infrastructure in an interconnected provincial cycling network.

Bicycle Parking
• What types of bike parking facilities (e.g., bike racks, lockers, fee-based enclosures) are needed to support cycling for commuting and other frequent trips?

Bicycle parking is dependent on duration and type of trip. Long term parking should be secured and shelter, while short term parking should be convenient and easy to use. Short of developing the province’s own guidelines, the types of parking facilities needed to support commuter and other frequent trips should be consistent across the province and align with the Association of Pedestrians and Bicycle Professionals - Bicycle Parking Guidelines.

• What types of government-owned, publicly accessible facilities should have bike parking?
Bicycle parking facilities at elementary and secondary schools would maximize the benefit of any the investment. Typically, a trip to school (that does not meet the criteria for bussing) is ridable and travels along sections of the network that experience “low levels of traffic stress” (within residential neighborhoods). Further, providing infrastructure to support cyclists at a young age will help develop skills and confidence which can translate to positive behavioral changes.

In addition, bike parking should also be provided at public libraries, at recreational and at healthcare facilities, and at post-secondary education institutions.

• What types of transit or transportation stations should have bike parking to support improved cyclist access (e.g., GO Stations, LRT stations, bus terminals)?

It is important that Regional Express Rail and Regional Transit stations have long term secure bicycle parking such as bike lockers, or well attended covered parking. Cycling can provide the first and last mile transit connection for many Brampton residents. Priority investments should be made at stations near connected cycling networks (existing and planned) to ensure maximum usage and easy access. Safe, secure, protected bicycle parking should be provided at all GO rail stations, major transit station areas, and bus terminals.

• What types of private facilities could potentially be eligible to receive provincial funding for bicycle parking facilities?

Private facilities in close proximity to cycling networks (existing and planned) should be prioritized to receive provincial funding for bicycle parking facilities. In communities where such programs exist, businesses with a demonstrated commitment to health & active transportation through programs like Smart Commute, Bicycle Friendly Businesses, etc. should be prioritized.

Thank you for considering our comments and we look forward to working with the province on these and future cycling related initiatives. One final comment regarding the CCAP Action item 3 identified as “Support Cycling and Walking”, we look forward to more details on what CCAP investments will be forthcoming to support walking in Ontario as a complement to the proposed investments to support cycling.

Sincerely,

Henrik Zbogar, MCIP, RPP
Senior Manager, Transportation Planning
Planning & Development Services

[Original Comment ID: 202874]