The controversial highway planned through wetlands and the Greenbelt.

The Bradford By-Pass

1997 – Route Planning and Environmental Assessment Study

2002 – Environmental Assessment 

2008 – Simcoe County includes link in its Master Transportation Plan.

2008 – Highway is not included in the Growth Plan.

2020 – Province announces the Bradford Bypass will proceed.

2021 – EcoJustice requests the federal government conduct an analysis of the project under the Impact Assessment Act.

2021 – York Region Council votes to send letter to the federal government stating its support of construction of the highway.

2021 (March) – Bradford ByPass is mentioned in the provincial budget in section outlining money to be spent on highway construction and maintenance.

2021 (October) – Bypass is exempted from the requirements of the Environmental Assessment Act.  The government says this will help “ensure appropriate environmental protection.”

2021 (October) – The Toronto Star and the National Observer publish an investigation on ties between developers and the provincial government and how developers stand to gain from building the Bypass. The piece also notes that, through information obtained by SCGC via a FOI request, the government was intending on making the highway a toll route.

2022 (January) – Petition of more than 10,000 signatures released opposing construction of the Bypass. 

2022 (February) – The Impact Assessment Agency of Canada decides not to designate the project.

2022 (March) – Lawsuit brought against the federal government by seven ENGOs challenging its refusal to designate the Bypass for a federal impact assessment.

2022 (April) – Contract awarded by provincial government for the Yonge Street bridge. This is part of the ‘early works’, which are to be started prior to all the studies being completed.

What's Happening?

The provincial government is moving forward with building a highway connecting highways 404 and 400. The route passes along the northern edge of Bradford, and through portions of the Holland Marsh.

The highway is controversial due to the route running through portions of the Greenbelt and the Holland Marsh, which is a significant wetland and agricultural area, as well as the fact that it is based, largely, on an environmental assessment that was done more than 20 years ago. (More recently the provincial government decided to exempt most of the project from environmental assessment requirements.) 

Opponents also argue that highways should not be prioritized in a climate crisis.

Finally, the government argues the highway is needed to ease congestion. Highways DO NOT accomplish this, though. This is well known, as outlined by the video we share below, yet they continue to push the project. If congestion is indeed the primary concern, it is clear that the government is mismanaging public money, throwing good after bad, with the project.

Quick Facts

Outdated Environmental Assessment

Increases Car Use in Climate Crisis

Runs through the Greenbelt

Why is it a concern?

There are a number of major concerns with respect to this project:

Early Works

The province would allow so-called “early works”, which include bridges, so proceed before key studies on the impacts they might have on wildlife are completed. This is putting the cart before the horse, to use a well worn analogy, and in effect is saying that the project will proceed regardless of the outcome of studies. This is the opposite of evidence-based planning.

Outdated Environmental Assessment

The Environmental Assessment the project is using was done 23 years ago, before the two major land-use plans in the area, the Lake Simcoe Protection Plan and the Greenbelt Plan, had been created.

These plans exist for a reason. The Lake Simcoe Protection Plan is intended to enhance and protect the health of Lake Simcoe, and the Greenbelt Plan delimits lands to be protected from urban growth, which is most often in the form of sprawl.

Basing a project on an EA that pre-dates these plans, such that the concerns these plans address aren’t taken into account, effectively nullifies them.

Further, the EA was contingent on the completion of further studies, including archaeological assessments, stormwater management, hydrological systems, noise, and compliance monitoring. The province is proposing that the highway be exempted from these additional studies.

Issues of concern that are have received support from necessary levels of government and are currently being implemented.

Issues that have the support of the municipality but are waiting on approval from the province or another entity.

Issues that have been proposed but have not yet received the support of the municipality.

Issues of concern, such as MZOs, that have been denied by the province but that are still progressing at the local level.

Issues that have been successfully resolved.

Subject Lands Outline

Greenbelt

 GO Train Line and Stops

Road/Highway Construction

 500 m High Risk Air Pollution

Evaluated Wetlands

Unevaluated Wetlands

Negative Impacts

The proposed route is anticipated to negatively impact high quality woodlands, the Holland Marsh, Provincially Significant Wetlands, and significant wildlife habitat. These are the direct impacts.

There are additional, and perhaps far more significant, impacts that will result from building infrastructure that enables an increase in single vehicle car use. 

At a time when we are facing a climate emergency, when it is becoming increasingly clear that our inability to address it is leading us towards a worst case scenario, continuing to base our communities around a reliance on cars as the primary mode of transportation is extremely irresponsible.

All major infrastructure projects – all publicly funded projects – should require a full climate change assessment. It could not be more clear that the public interest is directly tied to addressing the impacts of climate change, and accordingly no public money should be spent that exacerbates the crisis. This project profoundly misses that mark.

This is a rendering of what a four-lane highway bridge could look like crossing over the East Holland River looking to the north and Lake Simcoe. 

The bridge crossing of the East Holland River is likely to disturb one of the most significant archeological sites in southern Ontario, where artifacts have been found dating back nearly two-thousand years.

Image: Simcoe County Greenbelt Coalition

There are also costs that communities built around cars have that aren’t evident or easy to see.

Negative health impacts, such as obesity, can be correlated with communities built for cars as people drive to get basic amenities, such as groceries, rather than walk or bike. There are more direct consequences, though perhaps less acknowledged, as well, such as the fact that cars are a leading cause of death in the United States for children.

It is also likely that there will be economic impacts to the town, with development being drawn toward the highway and associated traffic, and away from the downtown. This form of development is most suited to larger commercial operators, and the jobs offered often pay less than what a smaller, locally based business provides.

This development pattern has been repeated just about every time a highway has been built near a town, and it can seriously impact the ability of local businesses to remain viable.

One of the main argument proponents are making in favour of this project is that it will reduce commute times. It is highly unlikely this will be the case in the long term. Evidence shows, repeatedly, that building and increasing car infrastructure does not ease congestion, rather the opposite happens. This is known as “induced demand.”

Basically, induced demand is when the increased capacity of a road leads to increased development along the road and increased use of that road. Think of what happens with Waze and the alternate routes it shows drivers to help them get around heavy traffic – before long those alternate routes become clogged themselves.

For a more detailed explanation watch the video below.

With induced demand what we will end up with is over a billion dollars spent (which could otherwise be spent on enhancing transit options such as the GO line), increased sprawl, and increased congestion. In other words, after all has been said and done it is highly likely that we will find ourselves confronted with the same dilemma, though with a greatly degraded environment.

Finally, the costs associated with car dependant communities1Report – The Unbearable Costs of Sprawl (Congress for New Urbanism)2Report – Suburban Sprawl: Exposing Hidden Costs, Identifying Innovations (Smart Prosperity Institute)3Report – The High Costs of Sprawl (Environmental Defence) – the key characteristic of sprawl – are higher than those associated with complete, walkable communities. This cost is passed on to taxpayers.

Infographic on the high cost of sprawl. Credit: Smart Prosperity Institute.
Infographic on the high cost of sprawl. Credit: Smart Prosperity Institute. (Click image for larger version.)

How Can You Get Involved?

  1. Follow and support those fighting this project on social media. See #stopthebradfordbypass’s linktr.ee for links.
  2. Learn more by watching our webinar, done on March 16th, adding the issue. (Find it above as well.)
  3. Sign up to our newsletter to stay informed on how you can help grow the Greenbelt and stop wasteful sprawl.
  4. Oh, and you can listen to our podcast episode with Laura Bowman of EcoJustice where we talk about exactly this issue! 👇👇

Additional Resources

Related Content

Events

Gather For The Greenbelt

Corporate sponsorship opportunities for the “Gather for the Greenbelt” event in Barrie, Ontario, featuring in-person storytelling from Margaret Atwood, special guests Sarah Harmer, Jeff Monague, and poetry from Barrie’s Poet Laureate, Tyneisha Thomas.

Art installation by Rochelle Rubinstein will be featured, as well.

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This is a comment that was posted by SCGC board member Phil Brennan on Ontario’s Environmental Registry regarding the Forest Sector Strategy


In today’s world, more than ever, good forest management needs to reflect a balance between different uses and needs of the forest.  

You do not double industrial output without making provisions for education and research (we must have ecological reserves to study and compare growth with our silvicultural practices); make effective provisions for biodiversity; build into the planning process strong provisions for mitigating climate change (planting trees has limited potential and it is wiser to take care of what we have); including provisions that are supported by experts for the sustainable management of wildlife and fish; building in protections and future growth potential for tourism; effective protection of natural heritage; including strong provisions for species-at-risk (e.g. caribou habitat); and, incorporating the social needs of affected communities through transparent consultation.

Specifically, I have the following concerns:

  1. The commitment to sustainability must specifically address all the points above throughout the development of the final strategy.  Window dressing is not acceptable. 
  2. Any plan to reduce so-called red tape needs to specifically chart the pros and cons of the existing and proposed changes to legislation – if the Class EA for Forestry is to be replaced in whole or part – how will the new rules insure that the public has the same opportunities to affect change as in the current assessment approach. Transparency here is critical.  If there is an intention to change the ‘area of the undertaking’ this must be clearly articulated in any proposal and needs public scrutiny.
  3. The pros and cons of changing from the current FRI based inventory approach need to be documented in a scientific and professional document for the public,  including the provision of clear information on the new remote sensing technology that is proposed and the manner in which it is verified on the ground. 
  4. It is not at all clear how the proposal will provide for additional wood supply certainty.  That’s what the current forest planning manual and requirements has already been designed to do.  
  5. While I applaud any logical efforts to increase the sustainable harvest, the challenges around this need to be more specifically articulated.  The reality is that for economic reasons we have lost pulp mills, sawmills (quality is a factor here), and board mills.  Ontario has been looking for ways to use its surplus birch and poplar supplies for decades.   Even on the private lands, particularly in Southern Ontario, the challenge is utilizing poor quality trees, not saw logs due to a long history of high grading.
  6. Increasing growth potential in our forests suggests a more intensive forest management and greater utilization of lower value material on harvested sites.  This suggests spending more money on forest management and it is not at all clear where that money would come from.  On private land,  the Ontario government  walked away from more intensive forestry work under the Woodlands Improvement Act and the Forestry Act in the last two decades to save money – hard to imagine us going back to programs like that in the near future under our current budget challenges. 
  7. Forest fires and insect and disease attacks, particularly in older forest tracts can be expected to have a significant impact on all uses of the forest and harvesting  and this needs to be addressed in developing new targets for the harvest in Ontario.  We must learn from the Australian situation. With these things in mind, I support the development of a rigorous and professional ‘Provincial Climate Change Impact Assessment’ and having it factored into moving forward with forest management and wood supply solutions in Ontario. 
  8. The document notes that Ontario has developed its own provincial policy as an alternative to the federal output-based pricing system to reduce carbon emissions in the section on maximizing the use of mill by-products to fight climate change.  Everyone who knows anything about fighting climate change knows that the Ontario approach is very weak and expected to fail.    If Ontario wants to use climate change arguments as part of its strategy to increase industrial output, you now need to have credible experts document the proposal.  
  9. The proposed Forest Sector Advisory Committee must include NGO’s that represent the interests of the non-timber industry for any strategy to be implemented properly. 

Thank you for this opportunity to comment.

Phil Brennan

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