Joint Letter Requesting Federal Impact Assessment of Bradford Bypass

Dear Minister Guilbeault,

Re: Bradford Bypass designation request

We are 63 environmental, farm and community organizations, many of which supported the February 3, 2021 designation request for a federal impact assessment of the Bradford Bypass highway (400-404 extension link) under the Impact Assessment Act. We are writing to indicate our support for the November 9, 2021 designation request made by three local community groups: Forbid Roads Over Green Spaces, Stop the Bradford Bypass and Concerned Citizens of King Township. Like them, we believe the proposed highway will result in adverse social and environmental impacts within federal jurisdiction.

In an era of devastating climate change and accelerating biodiversity loss, we are counting on the Government of Canada to intervene in provincial decisions that would increase greenhouse gas emissions from transportation and negatively impact fish habitat and species at risk. The Bradford Bypass will do exactly that, with serious and irreversible effects on Lake Simcoe and Ontario’s climate. It will also lead to the loss of farmland in the Holland Marsh, an irreplaceable and finite resource and an issue of significant public concern.

As noted by the three community groups in their designation request, the Ontario Cabinet passed a regulation on October 7, 2021 fully approving the Bradford Bypass and exempting it from Ontario’s Environmental Assessment Act. The project is thus set to proceed with minimal consultation, no consideration of alternatives to the highway, and limited studies that will have no impact on whether the project goes forward. The Province’s construction timeline indicates that construction will begin before these studies are even released – despite several municipal requests for a comprehensive assessment of the impacts on Lake Simcoe and associated watersheds.

We agree with the local residents that alternatives to the Bradford Bypass, which have potentially much lower negative impacts on climate and biodiversity, have not been duly considered. The fundamental premise of the Bradford Bypass project is that compact, transit-supportive complete communities are not possible, and that everyone moving to the Lake Simcoe region in the future will be driving in single occupant vehicles. This is not a vision supported by most Canadians. In light of the promises made at COP26, we are counting on the Government of Canada to take meaningful steps to fulfill its obligations and responsibilities. Since transportation emissions are the largest source of greenhouse gas emissions in Ontario, designating the Bradford Bypass for a federal impact assessment would send a strong signal about your government’s intent to put its climate commitments into action, without delay.

Designating the Bradford Bypass for an impact assessment would also show that Canada is committed to protecting fisheries and species at risk, two other important areas of federal jurisdiction. It would demonstrate a precautionary approach to decision-making and a willingness to address public concerns, based on fully understanding the likely or potential impacts of a dramatic increase in impervious surfaces (pavement) as a result of the highway. These include the loss of habitat and farmland as well as the contamination of nearby waterbodies such as the Holland Marsh Provincially Significant Wetland from storm water runoff, wastewater discharge and spills.

An impact assessment would also ensure that species at risk and their habitats are properly considered. One such species is the Red-headed Woodpecker, assessed as Endangered in 2018 by the Committee on the Status of Endangered Wildlife in Canada. There is mapped critical habitat for this at-risk species along the proposed route for the Bradford Bypass, and yet Ontario’s exemption regulation allows habitat destruction to be authorized without public consultation and before environmental studies are completed.

As outlined in the designation request submitted on November 9th, local residents have identified several alternatives to the proposed highway which merit consideration and could open the door to a better, more sustainable future in the region. Given federal obligations and responsibilities with regard to climate change, fisheries and species at risk, we urge you to intervene and compel the Province of Ontario to consider alternatives to the Bradford Bypass through a federal impact assessment.

Thank you for your consideration. We look forward to your response.

Yours sincerely,

Ontario Nature – Caroline Schultz, Executive Director
Rescue Lake Simcoe Coalition – Claire Malcolmson, Executive Director
Simcoe County Greenbelt Coalition – Margaret Prophet, Executive Director
National Farmers Union – Ontario – Don Ciparis, President 
AWARE Simcoe – Don Morgan, Chair
Barrillia Park Ratepayers’ Association – Peter Lavoie, President
Birds Canada – Gregor Beck, Ontario Director
Blue Mountain Watershed Trust – Norman Wingrove, Acting President & Treasurer
Carden Field Naturalists – Tom Wilson, President
Concerned Citizens in Adjala-Tosorontio Inc. – Janet Budgell, Chair
Concerned Citizens of Ramara – Mike Douglas, Chair
Coolearth Architecture Inc. – Sheena Sharp, President
David Suzuki Foundation – Rachel Plotkin, Boreal Program Manager
Durham Region Field Naturalists – Lois Gillette, Co-President
Earthroots – Franz Hartmann, Executive Director
Emerging Leaders for Biodiversity – Jackie Ho, Co-chair
Engage Barrie Organization – Alyssa Wright, Chair
Environmental Defence – Tim Gray, Executive Director
Environment Hamilton – Lynda Lukasik, Executive Director
FLAP Canada – Michael Mesure, Executive Director
Food and Water First – Brian Bell, Chair
Friends of Minesing Wetland – Naomi Saunders
Friends of Second Marsh – Wioletta Walancik, Administrative & Programs Director
Friends of Simcoe Forests Inc. – Mary Wagner, Chair
Friends of Strawberry Island – Pam Fulford, Chair
Friends of the Rouge Watershed – Jim Robb, General Manager
High Park Nature – Karen Yukich & Sharon Lovett, Co-chairs
Kawartha Field Naturalists – Eric Davis, Board Member
Lake Simcoe Watch – Jack Gibbons, Chair
Land Over Landings – Mary Delaney, Chair
Midhurst Ratepayers’ Association – Sandy Buxton, President
Midland-Penetanguishene Field Naturalists Club – Susan Hirst, President
Mycological Society of Toronto – Sheila Mazur, President
Nature Barrie – Bruce Wilson, President
Nature Canada – Gauri Sreenivasan, Director of Policy & Campaigns
Nature League – Rose Feaver, President
New Tecumseth Climate Action – Stephanie Wolfe, Chair
North American Native Plant Society – Harold Smith, Past Director
North Dufferin Agricultural and Community Taskforce (NDACT) – Karren Wallace, Chair
North Durham Nature – Cara Gregory, President
Ontario Farmland Trust – Kathryn Gold, Executive Director
Ontario Headwaters Institute – Andrew McCammon, Executive Director
Ontario Rivers Alliance – Linda Heron, Chair
Orillia Field Naturalists – Denis Paccagnella, President
Our Living Waters – Andrew Stegemann, Director
Parry Sound Nature Club – Tianna Burke, President
Peterborough Field Naturalists – Rene Gareau, President
Pickering Naturalists – Steve Laforest, President
Protect the Wasaga Beach Wetlands – Mario Nobrega, Chair
Ramara Legacy Alliance – Dana Tuju, Communications Coordinator
Simcoe County KAIROS – George Moore, Environmental Justice Representative
South Lake Simcoe Naturalists – Paul Harpley, President
Sustainable Orillia – Stan Mathewson, President
Thickson’s Woods Land Trust – Otto Peter, President
Thompson Architecture, Inc. – Andy Thomson, President
Toronto Field Naturalists – Ellen Schwartzel, President
Wasaga Beach Climate Action – Kathleen Caswell, Chair
Wilderness Committee – Katie Krelove, Ontario Campaigner
Wildlands League – Janet Sumner, Executive Director
Willow Beach Field Naturalists – Frank Godfrey, President
Windfall Ecology Centre – Brent Kopperson, Founder & Executive Director
York Region Environmental Alliance – Gloria Marsh, Executive Director
York Simcoe Nature Club – Sylvia Bowman, Conservation Director