The proposal is deeply…

The proposal is deeply flawed for the following reasons:

- the proposal represents a significant overreach of provincial responsibility, targeted at a single community in the province. It's notable that both the city of Toronto and the Association of Municipalities of Ontario (AMO) have expressed opposition to this proposal.

- The roadways under consideration (including Bloor Street, Yonge Street and University Avenue) are the responsibility of the City of Toronto. As the custodian of these routes, the city has conducted extensive consultations to assess the magnitude of the addition of bike lanes (and the corresponding reduction of car/truck lanes). The city has also shown its willingness to make adjustments to the traffic flow to facilitate movement for all users (cars, trucks, bicycles, etc.).

- while provincial representatives make reference to having data to make decisions, they ignore the consultation work done above and the data collected following the change. They are also ignoring comments from the local community (e.g., the Bloor-Annex BIA) on the positive aspects of having the bike lanes in their neighbourhood. Data presented in support of this proposal tends to be anecdotal in nature and has been disproved through the collection of data from the streets with implemented bike lanes.

- a key piece of data that does not appear in the provincial proposals is one of public safety. Cyclists will use these streets whether there are reserved lanes for cyclists or not. If the lanes are not present, cyclists will be at increased risk due to vehicular traffic. In addition, a cyclist may legitimately take space in a vehicular lane to improve their own safety situation, which will ultimately increase, rather than decrease congestion.

- the provincial proposal suggests that secondary roads be used as options for bike lanes, yet provides no guidance on the criteria for secondary routes. It is not unreasonable to foresee circumstances where shifting bike lanes to a secondary route (for example, Dupont, rather than Bloor) will generate similar issues. Does the province then mandate that Dupont is a primary route and push the bike lane to a more distant and potentially less direct route?

As an aside, the province has the means under its purview to produce significant improvements in traffic flow if it implements the Crosstown, Finch LRT, Mississauga Huron-Ontario and (future) Ontario Line. There is no need for additional legislation to do this and the impact will be far greater and with minimal disruption and risk to the cycling community.