CRI CONSULTATION SUBMISSION
Technical Performance
Technical Submission — Formal Requests
16 formal requests on geology, geotechnical risk, electricity grid integration, and linear infrastructure alignment.
Technical Performance
The following formal requests address ALTO’s Technical Performance criterion. They are structured by topic and requested for disclosure or action before the April 24, 2026 consultation deadline or, where timing does not permit, as a condition of route selection.
Geology & Geotechnical
1
Release geotechnical analysis underlying corridor cost comparisons
Release the geotechnical analysis underlying any corridor cost-per-kilometre comparisons, including the $50M/km and $80M/km figures cited in Senate committee testimony, for independent review before route selection. As part of this disclosure, ALTO must publish the alignment geometry assumptions for the Frontenac Arch terrain — specifically how the curve radius required through this terrain compares to the minimum curve radii required for 300 km/h operation — and confirm these assumptions have been validated against actual subsurface data. No route should be advanced or dismissed on the basis of cost or geometry claims that have not been subjected to independent geological review.
2
Conduct and release a formal karst risk assessment
Conduct and publicly release a formal karst risk assessment for the Napanee Limestone Plain crossing, including subsurface investigation results and cost modelling consistent with the HS2 Cheshire karst precedent.
3
Publish corridor-by-corridor cutting proportions in frost-susceptible terrain
Publish a corridor-by-corridor comparison of cutting proportions in frost-susceptible terrain, with associated cold-climate cost and maintenance implications modelled against the Harbin–Dalian precedent.
4
Publish EPS/XPS geofoam quantity and cost estimates
Publish the EPS/XPS geofoam quantity and cost estimates for both corridors, including decommissioning liability, and confirm whether these costs are included in the $60–90 billion range.
5
Release the updated aggregate sourcing assessment
Release the updated aggregate sourcing assessment for both corridors, including haulage distance, vehicle movement estimates, CO&sub2; emissions, and net cost differential. Confirm whether aggregate haulage costs, road repair liability, and spoil disposal costs are included in published per-kilometre estimates. Evaluate whether rail-based bulk material haulage on the CP Rail line parallel to the northern corridor is feasible — an approach that saved 19,000 tonnes of CO&sub2; on HS2 Phase 1 and is not available on the southern corridor.
6
Publish compensation framework for municipal road damage
Publish the compensation framework proposed for municipalities whose roads sustain damage from construction traffic on either corridor. ALTO must specify: the mechanism for assessing damage claims, the liability cap per municipality, the dispute resolution process, and how the framework will avoid the documented HS2 shortfall. This framework must be agreed with affected municipalities and the Association of Municipalities of Ontario before construction begins.
7
Release the hydrological drainage assessment for both corridors
Release the hydrological drainage assessment for both corridors, including crossing counts, structure sizing requirements, and settlement risk profiles in clay-till terrain.
8
Conduct and release a chemical de-icing impact assessment
Conduct and publicly release a chemical de-icing impact assessment for the southern corridor, including: proposed de-icing agent types and application rates; a corridor-specific hydrogeological risk assessment for the Napanee Limestone Plain karst system; species-specific risk assessments for listed species at risk in the Frontenac Arch Biosphere and Napanee Plain; drainage management and containment specifications; and a cumulative load estimate for the Bay of Quinte Area of Concern receiving waters. This assessment should be completed before route selection and before the environmental impact assessment process is initiated.
Electricity Grid
9
Release current electricity demand projections
ALTO should publicly release its current electricity demand projections for the HSR configuration, including annual GWh consumption, peak MW demand, and the number, location, and estimated land footprint of planned traction substations, as a precondition to final route selection. A Transport Canada Access to Information request (EA2026_0161358, filed March 5, 2026) for any records of electricity demand or grid integration planning for ALTO returned no records — primary source confirmation that as of March 2026 the federal project lead held no records of traction power prerequisite work or utility coordination.
10
File a System Impact Assessment application with IESO immediately
ALTO should file a System Impact Assessment application with IESO immediately. The current absence of any public record of such a filing is inconsistent with the scale of the load and the proximity of route selection decisions.
11
IESO to confirm ALTO’s load in Eastern Ontario Bulk Planning engagement
IESO should confirm whether ALTO’s load has been incorporated into the Eastern Ontario Bulk Planning engagement and the Supply to Belleville sub-study. If not, those studies should be supplemented before conclusions are drawn.
12
Hydro One IRRP should not be finalised without ALTO’s traction load
Hydro One’s Peterborough-to-Kingston IRRP (due November 2026) should not be finalised without receiving ALTO’s traction load projections. ALTO’s route selection decision is expected to precede the IRRP conclusion date — meaning the most important regional grid study for the southern corridor will be completed after the route decision has been made.
13
PBO to verify electricity cost assumptions in fiscal projections
The Parliamentary Budget Officer should verify whether ALTO’s fiscal self-sustainability projections include realistic electricity cost assumptions for full 300 km/h service, and whether required transmission upgrade costs have been included in the capital programme.
Linear Infrastructure Alignment
14
Inventory existing linear infrastructure usable for alignment anchoring
What specific existing linear infrastructure on the southern corridor has ALTO identified as usable for alignment anchoring, and what is its total usable length relative to the full corridor distance? Alignment anchoring on existing cleared corridors — transmission easements, pipeline routes, or decommissioned railways — substantially reduces greenfield expropriation and construction cost. ALTO’s public consultation materials contain no inventory of such opportunities on either corridor.
15
Formally assess Highway 401 compatibility with HSR alignment requirements
Has the compatibility of existing Highway 401 infrastructure geometry with HSR alignment requirements been formally assessed, given the minimum curve radii (approximately 3.5 km for 300 km/h operation) and maximum grade constraints HSR requires? Highway 401 was designed to highway standards, not HSR standards. Whether and where it can serve as an alignment anchor for a 300 km/h line is a specific engineering question that must be answered before any claim that a southern corridor benefits from existing linear infrastructure is treated as credible.
16
Evaluate co-location along existing transmission line easements
Has the feasibility of corridor alignment along existing transmission line easements in Eastern Ontario been evaluated? Hydro One’s high-voltage transmission network includes existing cleared, legally established easements that in some sections parallel candidate HSR corridors. Co-locating HSR traction infrastructure within or adjacent to existing transmission easements could reduce new land expropriation and simplify grid connection. This option must be formally assessed and publicly reported before route selection.
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April 2026