Part 3 of our series Who Will Save Lake Simcoe? Read the full report here.
The most significant development on the ‘highways in the Lake Simcoe watershed’ file is that on top of the Bradford Bypass, the province is planning another 54 km of highways on the southeast shore of Lake Simcoe. 
If building the Bradford Bypass worries you, it’s time to get completely freaked out. The map on the next page shows the locations of all of the province’s planned highways through the Greenbelt.
Map 1. Ontario’s planned highways through the Greenbelt
Exemption from the Environmental Assessment process
It’s been a busy year on the Bradford Bypass file, with disappointing results for Lake Simcoe. In the fall of 2021, the province passed an exemption from the Environmental Assessment Act for the Bradford Bypass, allowing the Ministry of Transportation (MTO) to carve off a piece of the project and start building before all of the Environmental Assessment studies and (very scoped) consultation is complete.  Due to the exemption, the highway has received all environmental approvals, despite studies not being completed. Even the studies that will be done no longer require government approval, so it isn’t clear how they will affect construction decisions.
In the words of the former Environment Commissioner of Ontario, Gord Miller, “This is a violation of international standards. It’s widely recognized that when you’re doing an assessment of an initiative, you don’t start until you’ve at least measured all of the impacts to the best of your ability so you can make a rational decision. They are clearly violating that.” 
Fish habitat destruction and “early works” construction
The MTO’s construction timeline for the “early works” overpass just north of Bradford at Yonge St. was April/May 2022, but has now been pushed until the latter part of 2022. One of the explanations for this could be that they may require Department of Fisheries and Oceans (DFO) permits to alter and potentially destroy fish habitat. Our team of community members at Stop The Bradford Bypass, and our pro-bono lawyer from Ecojustice, alerted the DFO of the risks of fish habitat destruction from the project.
We effectively encouraged the Ontario Federation of Anglers and Hunters to communicate the same to the MTO’s project team. We are happy that this is slowing the process down and are cautiously optimistic that this will improve things for the fish.
Costs and traffic impacts
Although the government has not confirmed the price of the highway, estimates show that Ontarians will be paying anywhere from $800 million to $2.2 billion for this 16 km, 400 series highway.
The commuter time-saving claims have been wildly overstated. The traffic studies that have been released showed that congestion on Highways 400 and 404 will be worse with the Bypass than without, and that those who live in East Gwillimbury or further east won’t see any time savings at all with the Bypass compared to using current roads.  MTO studies also demonstrate that the new highway will be congested by 2041, and therefore more lanes might need to be added.
When traffic alternatives were considered, the GO train did not go to Bradford, nor did it offer all-day, two-way service, which is planned for this line. 
A lot has changed since 1997; we believe that alternatives to this highway must be thoroughly examined using the current transit and population context.
Wildlife habitat and road salt impacts on Lake Simcoe
Environmentally, we have loads of concerns.
Primarily, it is a TERRIBLE place to put a highway while in a climate and biodiversity crisis. It is slated to cross the Holland Marsh Provincially Significant Wetland, farmland, and Greenbelt, in the “protected” Lake Simcoe watershed. It will cross 13 watercourses and affect bird, fish, and spawning habitats.
Lake Simcoe is on a trajectory to exceed the guideline level for chronic salinity in 37 years. This would change the entire ecosystem within the lake, and affect both its freshwater inhabitants and the seven municipalities that take drinking water from the lake. Highways create chloride hotspots in our rivers. It is virtually impossible to remediate chloride pollution.  
The Bradford Bypass is proposed to cross the Holland River’s east and west branches that flow north into Lake Simcoe. The LSRCA measures salt concentrations at the Holland Landing (approximately where the highway would be built), where chloride concentrations exceeded the acute guideline 44 times in the winter of 2011/2012. This project would literally add salt to an open wound. 
Chart 1. Holland Landing Station – Daily Chloride Concentrations (July 2011-April 2012) 
The majority of the summer and autumn chloride concerntrations can be seen to exceed the chronic guidelines, while winter concentrations can be seen to be greatly elevated, exceeding the acute guidelines on 44 occasions at the Holland Landing station (downstream of Aurora and Newmarket.)
Public opinion turns against Bradford Bypass
In the year since we last reported on the Bypass in Lake Simcoe Under Pressure in 2021, eight Lake Simcoe watershed municipalities passed resolutions regarding the Bradford Bypass, expressing concern for Lake Simcoe and a desire for a more thorough Environmental Assessment process.
We got significant media attention due to our team’s tireless reporting on the results of our Freedom of Information requests and our many municipal delegations to Council.
By the end of that year, public opinion had shifted away from supporting the Bypass: 48% of 900 poll respondents in three Lake Simcoe ridings opposed the Bradford Bypass; 29% supported the Bypass, and 23% were unsure. 
Attempts to get a Federal Impact Assessment
Despite all sorts of evidence-based concerns that this would harm fish habitat, pollute Lake Simcoe, perpetuate car dependency, increase GHG emissions, and not address regional traffic congestion, the Federal government has refused to intervene.
Members of Stop the Bradford Bypass requested Federal intervention once in 2020 and were denied. The decision was made even though key ministries (Environment, Health, Fisheries) outlined that they did not have enough time or information to make an assessment on the project. It made us wonder whose professional opinion the government relied upon to deny federal review.
After a year of hard work and a huge shift in public and municipal support, three other local groups tried a second time for a Federal Impact Assessment, only to be turned down again. In February 2022, the Impact Assessment Agency of Canada announced it would not revisit its decision to deny a federal impact assessment designation for the Bradford Bypass. Rescue Lake Simcoe Coalition joined six other ENGOs in litigation against the Federal Minister of Environment and Climate Change, Hon. Steven Guilbeault. The lawsuit challenges the Minister’s failure to designate the Bradford Bypass highway project for a federal impact assessment, alleging that the Minister’s decision was not based on the criteria in the Impact Assessment Act.
In a press release, the groups explain: “The purpose of the litigation is to hold the federal government accountable for the proper review of the impacts of the proposed highway, which is needed to understand the full impact of the proposed project on vital habitats, wildlife, and watersheds in the area. The case for building a highway is thin at best and we must better understand the impacts of the project on natural heritage, migratory birds, fisheries, greenhouse gas emissions, air quality, and First Nations cultural heritage.” 
We wonder, who will take care of Lake Simcoe?
14] Ontario, 2022. Connecting the GGH: A Transportation Plan for the Greater Golden Horseshoe https://www.ontario.ca/page/connecting-ggh-transportation-plan-greater-golden-horseshoe
 ERO posting: Proposal to exempt various Ministry of Transportation projects from the requirements of the Environmental Assessment Act. https://ero.ontario.ca/notice/019-1883
 Quoted in a Just Recovery Simcoe webinar. January 27th, 2022.
 AECOM. BradfordBypass.ca project site. Public Information Centre #1: 5. CONSIDERATIONS FOR THE BRADFORD BYPASS PROJECT: Traffic. https://www.bradfordbypass.ca/2021/04/09/5-considerations-for-the-bradford-bypass-project/
 Metrolinks.com. Barrie GO expansion. https://www.metrolinx.com/en/greaterregion/projects/barrie-go-expansion.aspx
 Learn more about salt in Lake Simcoe at https://www.lsrca.on.ca/Pages/Sodium-Chloride.aspx
 Ministry of the Environment, Conservation and Parks, Province of Ontario’s Lake Simcoe Science Event January 28th, 2021. Slide presented by Joelle Young, MOECP.
 Malcolmson, Claire. Toronto Star, Opinion. February 14, 2022. https://www.thestar.com/opinion/contributors/2022/02/11/salt-contamination-of-lake-simcoe-a-frightening-warning-about-highway-expansion.html
 LSRCA’s Lake Simcoe Science: Sodium Chloride (Winter Salt) page. https://www.lsrca.on.ca/Pages/Sodium-Chloride.aspx
 Oraclepoll, commissioned by Lake Simcoe Watch. Nov. 2021. Pg. 5. https://rescuelakesimcoe.org/wp-content/uploads/2022/04/LSW-survey-Bypass-Report-Nov-2021-2.pdf
 Press release: Groups launch lawsuit against federal environment minister over decision not to do an Impact Assessment on the Bradford Bypass: Dangerous precedent for federal decision-making at core of concerns. March 16, 2022. https://rescuelakesimcoe.org/press-releases/