November 20, 2024

Katerina Downard

Environmental Policy Office

438 University Ave
12th Floor
Toronto, ON
M7A 1N3
Canada

RE: Bill 212 - Reducing Gridlock, Saving You Time Act, 2024 - Framework for bike lanes that require removal of a traffic lane (ERO 019-9266).

The Clean Air Council (CAC) is a network of 40 municipalities from across Southern and Eastern Ontario that work collaboratively on the development and implementation of clean air and climate change mitigation and adaptation actions. The CAC network represents over 10 million Ontarians. Clean Air Partnership (CAP) is a charitable environmental organization that supports the ambition and implementation of municipal climate action. CAP serves as the facilitator for the Clean Air Council network. The information below highlights the consensus-based input from the CAC municipal network.

Most CAC member municipalities have passed climate emergency declarations, committed to science-based GHG reduction targets and are in the process of implementing their Climate Action Plans. The transportation sector is the second largest emitter of GHGs in Ontario. As such, a key aspect of climate action plans has been the adoption of Transportation Master Plans, Complete Streets Policies, and Vision Zero Action Plans that seek to shift transportation mode share away from single occupancy cars towards public transit, walking, and riding bikes. The CAC network is highly concerned that the government of Ontario would undermine years of work in developing well-researched policies, implementation strategies, and equitable community engagement processes that went into creating these critical transportation plans. Bill 212 will not only undermine crucial work on reducing GHG emissions, but it will also have negative impacts on public health and cause preventable deaths of vulnerable road users such as children and youth and older adults.

Below is the consensus-based input from across the CAC municipal network related to ERO posting number 019-9266[1]:

1. Respect for local democracy - Bill 212 provides the Minister of Transportation with an unprecedented level of control over local streets. No provincial or state government in North America has anywhere close to the level of oversight of community roads that Bill 212 would grant the Minister. Local municipal governments work very closely with community associations and business improvement areas to design, build, and maintain road infrastructure that meets the needs of local residents. By granting the Minister of Transportation power to ignore these community-led processes, Bill 212 would undermine one of the very basic principles of our democracy.
   
   
2. Making transportation more expensive - The average cost of owning and maintaining a car in Canada is more than $16,000 annually. In comparison, the average cost of owning and maintaining a bike in Canada is $300 a year. For many economically disadvantaged and working-class Ontarians, riding a bike is an accessible and affordable means of accessing jobs and educational opportunities. Transportation costs make up 15% of an average Ontarian's household budget. Bike lanes provide a safe and economically affordable transportation option that saves Ontarians precious dollars from their family budgets.
   
   
3. Bike lanes and congestion - The base supposition of Bill 212 is that removing bike lanes will improve traffic congestion in Ontario. This is not supported by any evidence or best practices for traffic management. The data on the movement of people and goods is clear. Studies in European, North American, and Ontarian cities have either found that bike lanes have no or negligible effects on car traffic volume and driving times. Congestion is instead caused by an overreliance on car-dominant infrastructure. Studies have shown that the more infrastructure dedicated to the movement of cars, the more people will drive, the worse congestion gets. Removing bike lanes and widening the roads will create induced demand for driving. Initially, the removal of the bike lanes will relieve congestion. However, over time, it will generate extra capacity and attract more drivers who were previously discouraged by traffic. Over time, the increased number of drivers offsets the initial congestion relief, resulting in a return to or even a worsening of the previous traffic levels. By making it more difficult for people to get around without a car, Bill 212 will make congestion worse, not better. Bike lanes are not the cause, nor are they a significant contributor to congestion. They are in fact, in combination with other forms of sustainable transportation infrastructure, the solutions to traffic congestion.
   
   
4. Increased red tape - The scope of Bill 212 applies across the province in urban, suburban, and rural communities. The bill grants the Minister of Transportation final say over all roadways in the province, not just major arterial roads. This entirely unnecessary new process will create mountains of red tape and lead to severe delays in delivering important state-of-good repair projects to Ontario's roads. For smaller municipalities and rural communities, in particular, who often work with limited resources and staff capacity, this additional step in their transportation planning process will create costly financial burdens for already under-resourced communities.
   
   
5. Bike lanes make business sense - Study after study has found that creating more walkable and bikeable neighbourhoods leads to better performances for local businesses. Cycling and pedestrian infrastructure make it easier for a greater volume of people to safely reach and spend time on dense streets compared to car-centric infrastructure. Infrastructure for bike lanes is also less expensive to build and maintain than infrastructure for cars. Bill 212 will make it more difficult for cities to implement cost-effective, pro-business streets for their communities.
   
   The Financial Accountability Office (FAO) of Ontario determined global climate change will directly impact Ontario's public infrastructure. The 2022 report CIPI: Transportation - Assessing the financial impacts of extreme rainfall, extreme heat and freeze-thaw cycles on transportation infrastructure in Ontario highlights how extreme weather events increase the frequency and cost of repairs to transportation infrastructure. Bike lanes are a climate-resilient alternative to car-centric infrastructure and increase transportation options to Ontarians. Generally, they are less prone to damage and therefore require less frequent repairs, and they promote emissions free modes of transportation, contributing to the mitigation of extreme weather impacts.
   
   
6. Bike lanes save lives - Research has found that bike lanes make cities safer for all residents - not just for those on bikes, but also for those who drive, those who walk, and those who take public transit. While it may sound counter-intuitive, adding more bikes to the roadway mix makes streets safer. The presence of bicycles has a calming effect on traffic, and that benefits everyone. Simple and inexpensive investments in basic infrastructure like bike lanes make streets more welcoming to riders and safer for us all. Bill 212 will remove a critical public safety tool from municipalities' toolkit and will create even more dangerous roads for all Ontarians. Furthermore, it will hinder municipalities' progress toward achieving their Vision Zero implementation goals.

The CAC recognizes that congestion is a real issue in this province, one that contributes to economic, environmental, and health disparities for Ontarians. However, Bill 212 is not the correct approach to addressing the province's transportation woes. It will not improve congestion or local air quality. Prioritizing motor vehicles over other means of transportation will impact the economic prosperity of Ontarians by forcing everyone to rely on cars. It will cost lives and impact the safety of Ontarians. The CAC urges the reversal of Bill 212 and recommends that, instead, the Ministry of Transportation collaborate with local municipalities to enhance access to safe, affordable, comfortable, sustainable, and healthy options for walking, cycling, and public transportation for all Ontarians.

The CAC appreciates the opportunity to provide additional input and is happy to answer any questions and provide more information related to this letter. The CAC can be engaged by reaching out to Gabriella Kalapos at gkalapos@cleanairpartnership.org.

Gabriella Kalapos

Executive Director
Clean Air Partnership

[1]

Municipal staff representatives on the Clean Air Council (CAC) were consulted in the preparation of this submission to reflect the feedback of member municipalities, but a direct endorsement of this submission by municipal councils was not sought due to time constraints, and several municipalities are preparing their own independent submissions. CAC representatives are the municipal change agents within leading climate action municipalities and have been working collaboratively across the region for the last 15 years to support and enable progress on clean air and climate change actions. The consultations undertaken were facilitated and endorsed by the Clean Air Partnership, a charitable environmental organization that serves as the secretariat for the Clean Air Council.