I am writing to express my…

I am writing to express my strong opposition to Bill 212, specifically the provisions related to the Highway 413 Act, 2024, and the proposed restrictions on municipal authority to implement bike lanes. As a legal professional, I find this legislation deeply troubling on several grounds, including its disregard for environmental protections, public health, and local governance.

**Environmental and Climate Impacts**

The Highway 413 Act exempts the project from the Environmental Assessment Act, allowing construction to proceed without the rigorous scrutiny typically required for developments of this magnitude. This exemption sets a dangerous precedent and directly contravenes Ontario’s obligations under the Environmental Bill of Rights (EBR), which guarantees residents the right to a healthful environment. The Greenbelt lands affected by Highway 413 serve as vital carbon sinks, flood control systems, and habitats for endangered species. Paving over these lands will result in irreversible environmental damage.

Moreover, transportation is Ontario’s largest source of greenhouse gas emissions, and Highway 413 will exacerbate this by increasing car dependency and sprawl. Studies on induced demand demonstrate that new highways do not alleviate congestion but instead lead to greater traffic volumes and emissions.

**Public Health Risks**

The removal of bike lanes under Bill 212 will negatively impact public health. Active transportation infrastructure reduces vehicle traffic, improves air quality, and encourages physical activity, which helps prevent chronic diseases. According to the Ontario Medical Association, air pollution contributes to thousands of premature deaths annually in the province. By prioritising car traffic, Bill 212 undermines these health benefits and exposes more Ontarians to pollution-related illnesses.

**Misallocation of Public Funds**

Highway 413 represents a misuse of public funds, with a projected cost exceeding $8 billion. These resources could be better invested in public transit and active transportation, which provide higher economic returns. For example, the American Public Transportation Association found that every dollar spent on public transit generates over four dollars in economic benefits. Given Ontario’s urgent needs in healthcare, education, and housing, prioritizing Highway 413 is fiscally irresponsible.

**Undermining Local Governance**

Bill 212’s requirement for provincial approval of municipal bike lanes constitutes an overreach of provincial authority under the Municipal Act. Local governments, through extensive public consultation and planning, are best positioned to address their unique transportation needs. By centralizing this decision-making, the province undermines municipal autonomy and disrupts local democratic processes.

**Economic and Social Equity**

Bike lanes are not only essential for reducing congestion but also for promoting economic and social equity. Research shows that businesses along bike corridors see increased foot and cycling traffic, resulting in higher sales. Additionally, cycling provides an affordable transportation option for individuals who cannot afford the high costs of vehicle ownership. Removing this infrastructure disproportionately harms low-income residents, limiting their mobility and economic opportunities.

**Legal and Policy Recommendations**

Bill 212 fails to meet Ontario’s commitments to sustainable development and climate action as outlined in the Ministry of Transportation’s Statement of Environmental Values (SEV). I urge the government to reconsider this bill and focus on evidence-based solutions:

1. Withdraw the Highway 413 Act and reinstate full environmental assessment requirements.
2. Invest in public transit and cycling infrastructure to reduce congestion and emissions.
3. Respect municipal autonomy in transportation planning, aligning with the principles of the Municipal Act.
4. Enhance environmental protections to safeguard Ontario’s natural heritage and uphold the EBR’s guarantees.

In conclusion, Bill 212 is a regressive piece of legislation that will harm Ontario’s environment, economy, and public health. I urge the government to abandon this bill and pursue sustainable, equitable transportation policies that benefit all Ontarians.

Thank you for your attention to this matter.

Sincerely,
Tracy