A series of community led town halls focused on a transparent reconsideration of the route for the Bradford Bypass.
How would the Bradford Bypass affect your life, your community, our health, our environment? Does the current route make the most sense? Have you been consulted? Have your questions been answered?
Free event, open to all to come or drop in.
Community groups are hosting events at which we will share information to answer the above using the maps and data freely available by the government and hidden from the public and discovered through Freedom of Information requests. Please bring your questions!
Walk ins welcome, but if you want to get on a list for email reminders, please add your information to this secure form: https://forms.gle/12RDbBoXchv7aXR49
Hosted by FROGS, Simcoe County Greenbelt Coalition, Rescue Lake Simcoe Coalition & volunteers.
A series of community led town halls focused on a transparent reconsideration of the route for the Bradford Bypass.
How would the Bradford Bypass affect your life, your community, our health, our environment? Does the current route make the most sense? Have you been consulted? Have your questions been answered?
Free event, open to all to come or drop in.
Community groups are hosting events at which we will share information to answer the above using the maps and data freely available by the government and hidden from the public and discovered through Freedom of Information requests. Please bring your questions!
Walk ins welcome, but if you want to get on a list for email reminders, please add your information to this secure form: https://forms.gle/12RDbBoXchv7aXR49
Hosted by FROGS, Simcoe County Greenbelt Coalition, Rescue Lake Simcoe Coalition & volunteers.
Our first YTP Weekend in 2022 was a huge success with events in over 30 cities and towns including a Stop Sprawl Farm Fest with music and local food, a P’Earth Day Parade, eight Stop 413 rallies, watershed restoration in Peterborough and bird watching near Lake Simcoe!
This year, Yours to Protect Weekend will run from April 21st to April 23rd.
Now that we’re also building on the energy of an unprecedented wave of rallies to protect wetlands, stop Bill 23 and save the Greenbelt we expect this year’s Yours to Protect festivities to be even bigger and better than our first event!
All sorts of environmental events are welcome, but here are some key issues we’re rallying for:
Protecting Wetlands, Lakes and Rivers
Repealing Bill 23
Protecting the Greenbelt
Stopping Sprawl
Stopping Highway 413 and the Bradford Bypass
Building Housing in Walkable Communities
Stronger Climate Policies
Click the link below to find out about protests and events in your area!
Lake Simcoe seen from the site of the proposed Bradford Bypass / Holland Marsh Highway, looking north east towards Cooks Bay and Georgina. Photo Credit Jeff Laidlaw.
Summary: The Bradford Bypass is a proposed 16.2 km, 4 – 8 lane highway that would connect Highways 400 and 404 just below Lake Simcoe’s Cooks Bay. The proposed route is just north of Bradford, approximately 100 – 200 m from existing neighbourhoods and parks. It bisects the Holland Marsh Provincially Significant Wetland, proposing to use piers to hold up the bridge across this area. As of September 2022, there is no budget, no technical design drawings, and the studies are incomplete. But the province of Ontario changed its Environmental Assessment regulations and then exempted the Bradford Bypass from the Environmental Assessment process, substituting a streamlined process that identifies the route and allows construction to begin this fall regardless of the outcomes of environmental and traffic studies in progress. Minor changes to the route could occur depending on archaeological studies.
1993
Bradford Bypass highway Draft Environmental Assessment (EA) Proposal was written. Substantially rewritten in 1994 and became legal terms of reference for the current EA Study to this day.
1997
EA finished. Did not consider cumulative effects, climate change, or detail impacts on natural heritage, migratory birds, fisheries, First Nations, or discuss air pollution.
2002
EA approved with conditions including requirements for upgraded studies on archaeological resources, stormwater management, groundwater protection plan, noise, and compliance monitoring.
This EA anticipated severe stormwater and groundwater impacts and adverse effects on fish habitat.
2005
The project didn’t go ahead after the completion of the EA. Reasons include a change in provincial government that enacted major planning and environmental protection legislation: Greenbelt Act & Places to Grow Act. Together they laid the foundation for planning that was aimed at building more compact communities and transit over highways and sprawl.
2008
Lake Simcoe Protection Act passed. Allows for major infrastructure if there is no alternative.
2017
Ontario Liberals decided not to pursue the Bradford Bypass and then did an about-face and included it in the Growth Plan. Still, nothing happened.
2018
Project was revived by the new Progressive Conservative government of Ontario, after nearly 20 years of inactivity on the file, with conditions of the 2002 EA approval not met. Updates to the understanding of the site conditions were supposed to be made every 5 years, and were not.
Proposed map of the Bradford Bypass, from the Ministry of Transportation.
July 8, 2020
The Government of Ontario proposes to exempt the Bradford Bypass from the conditions of the original EA. The Ministry of Transportation (MTO) and the project consultant team, AECOM, present information about the Bypass to municipalities throughout this time, not mentioning the proposed exemptions or changes to the EA Act. They do not produce side-by-side comparisons of the old and the new process for an EA, so municipalities are led to believe that the studies that will be undertaken will mean something. They don’t. Read the exemption here – Environmental Registry of Ontario posting.
February 3, 2021
First attempt at a Federal Impact Assessment. Rescue Lake Simcoe Coalition and Simcoe County Greenbelt Coalition, being represented by Ecojustice, request a Federal Impact Assessment of the project. The request raises the Project’s potential to cause adverse effects on areas of federal jurisdiction and public concerns related to those effects. It also raises concerns that the adequacy of the provincial environmental assessment process to address those issues, particularly in light of Ontario’s proposed exemption to the Environmental Assessment Act. This request is supported by a coalition of 21 environmental groups, including Ontario Nature, Wilderness Committee, Environmental Defence and many local groups.
May 3, 2021
Minister of Environment and Climate Change, Hon. Jonathan Wilkinson decides not to designate the Project for a Federal Impact Assessment. Minister’s response available here.
It also means they exempted this project from completing the conditions in the conditional approval from 2002. They will proceed without evaluating health impacts, climate change, and the impact on Lake Simcoe. Nothing in the studies they are doing will affect the route location, except for some minor adjustments in the route to avoid archaeological sites and a golf course.
October 31, 2021
The Narwhal’s Emma McIntosh and Toronto Star investigative journalist Sheila Wang release a damning story, including details of plans to toll the highway, that the Bypass route today received the worst score for environmental impact compared to other bypass options in the area, in contrast to government claims, and that it would need to be expanded to 6 lanes by 2041. Read the Toronto Star: What the Ford Government Hasn’t Told you Its Next Controversial Highway Project.
November 2021
Public opinion poll regarding the Bradford Bypass highway reveals reversal of earlier apparent public support for the Bypass from a poll conducted by Bradford West Gwillimbury. The 2021 OraclePoll, commissioned by Lake Simcoe Watch, says: Opposition to the highway is 48%; 29% it and 23% are unsure. This after the following truthful statement was presented to those polled: “The government of Ontario is planning to build a 16 km, four lane Holland Marsh Highway to link Highways 400 and 404. The proposed highway would increase phosphorous and road salt pollution to Lake Simcoe, endanger fish spawning habitat, eliminate 23 acres of provincially significant wetland, and eliminate 81 acres of wildlife habitat. Do you support construction of this highway?”
November 9, 2021
East Gwillimbury-based Forbid Roads Over Green Spaces (FROGS) makes a second Impact Assessment designation request to the Federal Minister of Environment, now Hon. Steven Guilbeault, with two other community groups, Concerned Citizens of King Township and Stop the Bradford Bypass. The second request provided information about the way in which the exemption regulation changed the regulatory environment for the Project, and detailed increases in public concerns. It also provided additional information about the Project’s potential adverse effects within federal jurisdiction, including on fish habitat and greenhouse gas emissions.
Nov 13, 2021
Day of Action protest against the Bypass in front of Minister of Transportation and York Simcoe MPP Hon. Caroline Mulroney’s office.
May – December 2021
Seven Lake Simcoe watershed municipalities pass resolutions asking for better oversight of Bradford Bypass highway, an Impact Assessment, or impacts to Lake Simcoe studied. Read details in the December 9, 2021 update letter to Minister Guilbeault.
December 8, 2021
63 environmental groups representing tens of thousands of Ontarians write to the Minister to support the Second Request.
December 2021
AECOM (consultant for MTO on this project) identifies that over 80 square metres of fish habitat would have to be permanently removed as a result of “early works” near Yonge street and Bradford’s 8th Line that would impact an un-named tributary containing direct warmwater fish habitat to the east of Yonge street. They suggest that MTO ask the Department of Fisheries and Oceans Canada (DFO) if authorizations were required for the Bradford Bypass “early works” under the Fisheries Act.
Coalition of environmental groups write to the Minister of Fisheries and Oceans Canada to request that they do their job of protecting fish, and provide or deny, as appropriate, the permits needed for the work. Earlier, DFO staff said they needed to evaluate the impact of the entire project, but in the case of the Bradford Bypass, the provincial exemption regulation allows the project to be carved into smaller pieces, therefore allowing the project to proceed piecemeal, without an evaluation of the entire project. Ontario Federation of Anglers and Hunters also wrote to the MTO / AECOM team to suggest that DFO oversight of this was appropriate.
March 14, 2022
Lawsuit launched against Minister of Environment and Climate Change Hon. Steven Guilbeault, questioning whether he followed the Impact Assessment Act in his decision to not reconsider the request for a Federal Impact Assessment. Appellants are Rescue Lake Simcoe Coalition, Forbid Roads Over Green Spaces (FROGS), Ontario Nature, Wildlands League, Western Canada Wilderness Committee, Environmental Defence, and Earthtroots. “There are errors of fact in the Minister’s decision that cannot be allowed to go unchallenged” says Tim Gray of Environmental Defence. “For the sake of Canada’s environment and the communities dependent on it, we must make sure that destructive projects, such as bulldozing a super-highway through one of Ontario’s largest wetlands, receive a proper and thorough review.” National Observer article: Environmental groups file lawsuit against federal minister over Bradford Bypass.
March 23, 2022
DFO provides a “letter of advice” to the MTO Bypass team allowing for the removal of 80 square metres of fish habitat for the “early works” portion of the Bradford Bypass without a permit. It says effectively, (paraphrasing) ‘Go ahead. Use the following techniques to avoid harming or destroying fish habitat. It’s a self assessment system. Notify the DFO if you are in violation of the rules and if you are destroying fish habitat.’ (The request from the Bypass team clearly indicated that they were removing 80 sq meters of fish habitat.) This is a real head-scratcher.
April 23, 2022
Yours To Protect Earth Day protest against the Bradford Bypass.
May 2022
DFO responds to a formal petition, sent by a member of the Stop the Bradford Bypass team, which asked many specific questions. The response indicated that there were never any instances between 2001 and 2022 where a Fisheries Act authorization or Species At Risk Act (SARA) permit was formally denied, or where a letter of advice was refused. The response also confirms that MTO never applied to DFO for any authorizations for any of the water crossings associated with the 404 extension from Green Lane to Ravenshoe road and had been permitted to self-assess any impacts on fish and fish habitat under a memorandum of understanding.
August 16, 2022
Environmental Conditions Report released and public comments are due one month later. Some studies that one would expect to be in an environmental conditions report are missing. Some still have not been updated in the field. There is no discussion of climate change or induced demand. The report only references greenhouse gas emissions in the context of an upcoming air quality assessment. There is no assessment of chloride (salt) or phosphorus impacts, or impacts to Lake Simcoe. The province requires the project proponents to complete a stormwater management plan, but there appears to be no requirement to follow it.
Traffic impacts: The MTO itself identifies the “Adequacy of facility to accommodate future travel demand” as an issue. The response is: “No commitments are identified by the proponent; however, traffic studies involving traffic modeling and analysis is being undertaken through Preliminary Design.” The modeling is not publicly available. Claims that the highway will improve local traffic are unsubstantiated because the highway will fill up with traffic quickly. This is “induced demand”. The ECR indicates that the project is being planned for 2 lanes each way but anticipates it expanding to 4 lanes each way (p. 315).
Human health impacts: The ECR identifies twenty “sensitive receptors” already in the Air Quality study area: 5 retirement homes, 6 daycares, 9 schools.
There are also nine planned “possible” sensitive receptors in Bradford West Gwillimbury within the Air Quality study area, including a new Simcoe County District School Board school. Henderson municipal park with soccer fields is also in the study area. (P. 195)
November 2, 2022
Hearing regarding the lawsuit / Judicial Review of the Minister of Environment and Climate Change Canada not addressing the second request for a Federal Impact Assessment for this case.
Anticipated next steps:
Final Environmental Conditions Report (ECR) for Bradford Bypass Project will be released on the project website. No date given.
Fall 2022
The Preliminary Design refinements, alternatives, and the evaluation, will be presented at Public Information Centre #2 in the fall of 2022.
Plan to start construction on bridge at Yonge St. (County Road 4) just north of Bradford. There are no detailed engineered drawings, no budget and the route details are not complete. While the timing is meant to coordinate construction with the widening of Yonge St at this location, critics argue that building the ‘early works’ bridge at this stage in the process is premature and establishes the route, regardless of the outcomes of studies underway.
End of 2022, early 2023
Draft Environmental Impact Assessment Report (EIAR)will be available for review.
Selection of Preferred Alternative for the Bradford Bypass Project (minor route changes.)
Early 2023
Final Environmental Impact Assessment Report
Preliminary design complete
The Bradford Bypass’ consultant team’s schedule can be found 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. [14]
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. [15] 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.” [16]
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. [17] 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. [18]
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. [19] [20]
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. [21]
Chart 1. Holland Landing Station – Daily Chloride Concentrations (July 2011-April 2012) [22]
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. [23]
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.” [24]
[15] 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
[16] Quoted in a Just Recovery Simcoe webinar. January 27th, 2022.
[20] Ministry of the Environment, Conservation and Parks, Province of Ontario’s Lake Simcoe Science Event January 28th, 2021. Slide presented by Joelle Young, MOECP.
[24] 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/
