Overview of planned highway
(aka The Holland Marsh Highway)
The Bradford Bypass is a proposed 16.2 km, rural 4-lane controlled access 400-series highway that would connect Highway 400 (Town of Bradford West Gwillimbury) and Highway 404 (Town of East Gwillimbury).
1. The Environmental Assessment (EA) for this project is over twenty years old. As such, the EA pre-dates the Greenbelt Plan and Lake Simcoe Protection Plan, and does not provide a climate change impact assessment. The preliminary EA predicted severe water quality impacts to groundwater and surface water in the Lake Simcoe watershed for which there is still no mitigation plan. Additionally, the Bradford Bypass would transect some of the best agricultural land in Ontario, destroy sensitive wildlife habitat in Greenbelt lands, and adversely impact one of Ontario’s largest remaining provincially significant wetlands.
2. The project is anticipated to negatively impact:
• 22.1 hectares of high-quality woodlands;
• 17.2 hectares of Holland Marsh (designated environmentally sensitive area);
• 9.5 hectares of designated provincially significant wetlands; and
• and 32.7 hectares of significant wildlife habitat.
3. There are other alternatives to the Bradford Bypass that have not been given due consideration, such as improved transit service and upgrades to regional roads, which would serve the long-term interests of local communities. It is well known that highways do not solve traffic congestion issues, but rather encourage more vehicular travel. This in turn results in more vehicles on the road, more greenhouse gas emissions, and more pollution. Investing public dollars in this commuter highway is also short-sighted, especially as more individuals transition to remote work in response to the COVID-19 pandemic.
4. Despite the sensitive location of the highway, and the outdated EA, the provincial government recently moved to fast-track 400-series highways through the protected Greenbelt lands. As a result, the Bradford Bypass would be exempted from even the most basic assessment processes and environmental studies Ontarians count on to protect their health, their communities, their food systems, and the environment.
MTO’s consultants have developed a fairly extensive project web page.
This web site has grown a fair bit since it was first initiated. Much of the information provided in intended to elicit a sense of confidence in the reader. The message being: just look at all the work we are doing to ensure:
- the safety of motorists
- the protection of the environment
- the public will be able to participate in the study through meaningful consultation
- Key excerpts from MTO’s web page:
The following environmental discipline studies will be carried out during the current preliminary design study:
- Agricultural Impact Assessment;
- Air Quality Impact Assessment;
- Archaeological Assessment (Stages 2, 3, & 4, as required);
- Cultural Heritage Assessment;
- Drainage and Hydrology;
- Erosion and Sediment Control Risk Assessment;
- Fish and Fish Habitat Existing Conditions and Impact Assessment Report;
- Fluvial Geomorphology;
- Groundwater Impact Assessment;
- Land Use and Property Impact Assessment;
- Noise and Vibration Impact Assessment;
- Preliminary Landscape Composition Plan;
- Snowdrift Assessment;
- Terrestrial Ecosystems Existing Conditions and Impact Assessment Report (including an assessment of vegetation and vegetation communities, wildlife and wildlife habitat, species at risk and designated natural areas); and,
- Waste and Excess Materials Management Plan.
These studies are intended to convey the impression that the subject matter of these studies will be identified and safeguarded in the design and construction of this highway.
A careful reading of the information tells a very different story:
(Key issues are highlighted in red text)
Environmental Protection and Mitigation Measures
Environmental assessments and the development of mitigation measures is an iterative and collaborative process. The Ministry will undertake the environmental assessment in accordance with the Ministry Class Environmental Assessment for Transportation Facilities for a Group ‘A’ project. Protection and mitigation measures will be implemented where practical and in consideration of the evaluation criteria. The intent is to balance the technical and environmental constraints for the proposed design refinements and alternatives. The following outline the proposed protection and mitigation measures to be reviewed and evaluated through the consultation and engagement with regulatory agencies during the study for each environmental consideration.
Elsewhere in the website is the following statement:
A Reasoned Argument (trade-off) method of evaluation will be used to identify the advantages to select the preferred refinements and alternatives.
Once it is determined that the project is to proceed, MTO will only employ mitigation measures they consider reasonable (i.e. cost effective).
The fundamental problem with the Environmental Assessment Process employed by MTO is that the project is deemed paramount. As reasonable alternatives outside of MTO’s jurisdiction are rejected, the only alternative is to not do the project. MTO refuses to consider alternatives beyond their jurisdiction. These alternatives include the Barrie GO Train and upgrades to local and regional roads. MTO projects a compelling reason for this highway because if they don’t build it, the problems they have identified will remain outstanding as they have done for the past 40 years.
Meanwhile York and Simcoe Regions and the Towns of East Gwilimbury and Bradford have no incentive to resolve the long outstanding transportation problems themselves at their expense when MTO will do it for them at no cost. That is why they have all gone on record as being in favour of, or strongly in favour of, the Bradford Bypass.
A proper environmental assessment would start with the basic long outstanding problems:
- Out-of-the-way Travel discontinuances (Barrie and Innisfil to Keswick and Breckin’s gravel pits)
- Traffic congestion in the center of Bradford
It would then consider all possible reasonable solutions and identify one or more of those that would provide the greatest benefit at the least cost and environmental impact. The matter of jurisdiction, who builds the solution(s) and who pays for these would only then come into issue.
Given the Government’s strong desire to employ unprecedented amounts of dollars for post COVID-19 recovery, a strong argument can be made, in this instance, to have the proper solutions funded by the Government of Ontario.