I work as a licensed…

I work as a licensed transportation engineer in Ontario, with over 16 years of experience in the field. I work for, and am a part owner of, one of the largest transportation consulting firms in the country. We specialize in supporting land development across the GTA, Ontario, and the rest of Canada for clients in both the private and public sectors. The proposed policy, to limit and remove bicycle lanes from major streets, will have a detrimental impact on the ability of Ontario to meet its housing targets and will slow the development of high-density housing in the communities that need it most.

Traffic congestion in Ontario cities is, in some cases, at an all-time high. However, eliminating bicycle lanes will impact the ability of both the private sector and public housing developers to deliver additional housing, rather than improving traffic conditions for drivers. As part of the land development process, any medium to large scale development is required to provide a Transportation Impact Study (TIS) which outlines the potential transportation related impacts of the development (such as increased vehicular traffic generation) on the surrounding road network. For decades, the solution to increased traffic congestion was typically to “add more lanes”, or alternatively, add things like turning lanes, in order to mitigate the impacts. That time has passed. Most major Ontario cities are fully “built out”, meaning there are no more new roads, let alone new lanes, coming to major development areas – the roads are as wide as they’re going to get. As a result, when a new development relies upon automobile travel to support the new residents (or employees or customers, depending on the land use), the TIS will show conditions worsening. When they worsen to a tipping point, and there are no mitigation measures available (i.e. no new lanes can be constructed), the project is opposed or reduced in scale.

In most municipalities in Ontario today, medium and large developments reach the threshold where automobile impacts “fail” frequently, and thus a project would be cancelled or reduced. However, cities and residents have widely observed that there are other ways for people to get around. Demonstrating that cycling is a viable mode of transportation, and thus people may elect to ride rather than drive, has proven extremely helpful in supporting development by moving some of the impacts of the automobile to other modes (this is also true of walking and transit).

As it has been demonstrated in Ontario and globally, improving the safety and separation of bicycle facilities from automobile lanes increases their use, and succeeds in providing cycling opportunities to those who are not comfortable travelling in mixed traffic. By eliminating cycle tracks and bicycle lanes (through the prevention of their installation between major destinations or through the removal of existing infrastructure), the Government proposes to take many people off bikes and put them back in cars. This will worsen the existing automobile traffic situation and make it nearly impossible for developments to mitigate their transportation impacts. It will be easier for local municipalities, and indeed the Ministry of Transportation itself (for projects that are within the MTO’s controlled areas near highway infrastructure) to say no to residential, office, retail, commercial, and industrial developments. Simply put, this policy will slow the delivery of housing and economic growth by saying “there are too many cars, and there is no other way to travel, so you cannot build that here”.

As the Government has not sought fit to impose measures that would reduce vehicular travel overall (such as road tolls or congestion charges), it has fallen to transportation professionals to prove that there are alternative modes of travel, allowing us to demonstrate to reviewing agencies that the overall impact of a development can be managed through an increase in the quantity of cycling in a new project (as well as increased walking and transit usage). This policy removes one of the key levers used to support development, and in doing so, will decrease the ability to densify in areas that are most appropriate for densification (as they are also the areas that are most congested with cars).

The secondary result will be a redistribution of development activities to areas that have sufficient road capacity, which means rural and suburban areas, resulting in a loss of farmland and greenspaces and creating congestion in suburban areas. These areas are much more automobile dependent, which in turn results in increased driving to already intensified areas for employment and recreation. Essentially, by pushing development away from congested areas (due to its inability to get approved in those same areas), the amount of people driving in a region increases, resulting in more congestion in those congested areas, further forcing development farther and farther afield. It is a vicious cycle that has played out across North America, as well as locally, as former Toronto suburbs such as Etobicoke and Scarborough became busier without becoming significantly denser, and more distant suburbs, such as Markham, Stouffville, and Uxbridge have also seen rapid increases in congestion. Removing cycling infrastructure from downtown Toronto will not help those commute times, it will only, over time, increase the drive time for those in Uxbridge, as development is forced to occur in those areas rather than near existing infrastructure.

This is not only a recipe for sprawl, and its attendant side effects, but it is, on its face, self-defeating to the stated goal of the bill: to reduce congestion. Only through providing alternative modes of transportation can the Province hope to free up road capacity which can then be used by those that need it.

By no means am I claiming that everyone will cycle, but for each person you put on a bike for a local trip, that’s one less car in the way of someone who does need to drive (for accessibility, comfort, proximity, or any other reason). And the way to get people on to bikes is to provide them an experience that is safe (through separation from vehicular traffic) and convenient (direct routes on major streets, which connect where people live to where they want to go for work, shopping, or entertainment).

This proposal will result in less development and less economic growth in areas that are designated for it, and as such, I strongly recommend that the proposal be removed from consideration. It will undo many of the Government’s efforts to meet housing targets, will not generate a significant improvement in vehicular travel times, and will, over time, only worse the effects of auto-focused development patterns.

Thank you for taking the time to review my comment, and I hope that going forward you will reach out to professionals in the field for their opinions on such a technical subject.