This comment concerns PART…

This comment concerns PART XII MUNICIPAL BY-LAWS AND BICYCLE LANES.

I would like to express my disagreement with the province's proposed measures to limit the construction of bike lanes in Ontario. Concerns include:

Necessity
- The government has failed to provide sufficient evidence that bike lanes meaningfully contribute to traffic congestion in Ontario.
- The government has failed to provide sufficient evidence that removing bike lanes on highways will meaningfully alleviate traffic congestion in Ontario.
- The government has failed to provide sufficient evidence that adding to highways will alleviate motor vehicle congestion (i.e., does not consider the phenomenon of induced demand).
- The government has failed to demonstrate that municipal governments do not already conduct sufficient analyses to determine traffic congestion impacts of bikes on highways that they manage.
- The government has not articulated how it is better placed than municipal governments to determine what transit modes to prioritize according to the needs of their constituents.
- The government has not articulated why motor vehicle traffic should be prioritized over othe transit modes.

Proportionality
- The government appears to be using a handful of bikes lanes in the Greater Toronto Area as pretense to justify its incursion into areas of all municpalities' remit. (I live in Ottawa; we have two short protected bike lanes downtown off of main arteries -- why does Ontario need weigh in on their existance?)
- The government has not considered why it is targeting bike lanes, but not other infrastructure that that affect motor vehicle traffic on highways, including, inter alia, on-street motor vehicle parking, public transit, and pedestrian infrastructure.
- The government only requires municipalities to conduct analyses of bicycle lane impacts on traffic congestion, but does not require that the province conduct impact assessments on the removal of bicycle lanes.

Harm
- The government has not conducted risk analyses and assessments to determine the potential impacts of its proposed restrictions on bike lanes.
- Impacts may include, inter alia: environmental harm, increased fatal accidencts, increased injury rates, poorer health outcomes, economic impacts on local businesses, community impacts.

Justification
There are many other concerns Ontarians have with this proposal. Not least, many citizens are frustrated that this Government is turning active transit infrastructure into a political wedge issue. Unfortunately, this Government appears uninterested in addressing the root causes of the traffic congestion, including surban sprawl, lack of safe, effecient multi-modal transit options that force more people into cars, insufficient public transit investment, and an cultural fixation with the automobile. Rather than work to have serious discussions with Ontarians about what the data tells us, the Government has opted to instead offer poor solutions chasing after fictional problems.