Bill C-15, ALTO and A Force of Nature: An Irreconcilable Conflict
The Carney government has enacted legislation that exempts ALTO from environmental review — and simultaneously committed to using that same review mechanism proactively before infrastructure decisions. Both cannot apply to the southern corridor.
Two instruments of the Carney government, enacted within sixteen months of each other, point in directly opposite directions on how the ALTO southern corridor must be evaluated before a route selection decision is made.
Bill C-15 — the Fall Economic Statement Implementation Act, 2025 — grants the Minister of Transport authority to exempt ALTO from certain requirements of the Impact Assessment Act, and provides ALTO with enhanced expropriation powers along proposed corridors. Its effect, if applied, is to narrow the scope of mandatory pre-decisional environmental review.
A Force of Nature: Canada’s Strategy to Protect Nature — announced by Prime Minister Carney on March 31, 2026, three weeks before the consultation deadline — commits the government to: using regional assessments under the Impact Assessment Act “to proactively address the effects of development on a region before project reviews”; strengthening SARA protections for species at risk; mapping Key Biodiversity Areas before development decisions; and launching a Natural Capital Accounting Taskforce in spring 2026 to integrate the value of nature into government decision-making.
Bill C-15 — Fast-Tracking Powers
Grants the Minister of Transport authority to exempt ALTO from Impact Assessment Act requirements that would otherwise apply to a project of this scale.
Provides ALTO with enhanced expropriation powers and development holds along proposed corridors before route selection is finalised. Legislative intent: accelerate the project by reducing regulatory burden on ALTO.
A Force of Nature — Nature Strategy
Commits $3.8 billion and binding policy to proactive environmental protection before project reviews, including explicit commitment to use IAA regional assessments before development decisions.
Commits to strengthening SARA species protections, comprehensive KBA mapping, and natural capital accounting — all directly engaged by the southern corridor.
| Force of Nature Commitment | Current ALTO Status | Bill C-15 Effect |
|---|---|---|
| Regional IAA assessments before project reviews | No regional assessment initiated. CEO confirmed Jan 22, 2026: “our budget is not known.” | C-15 gives Minister power to exempt project from this requirement. |
| Strengthen SARA species protections; identify priority habitats | CEO confirmed on CBC March 25, 2026 that species surveys commenced “this week” — one month before consultation closes. | C-15 expropriation powers operate independently of SARA s.58 critical habitat prohibitions. |
| Comprehensive KBA mapping before development decisions | Three designated KBAs in the Frontenac Arch; fourth (Napanee Limestone Plain) pending. No KBA impact assessment published. | No C-15 provision requires KBA mapping as a precondition of corridor selection. |
| Apply mitigation hierarchy: less-harmful alternatives first | No published comparative environmental assessment of northern vs. southern corridors at equivalent data standards. | C-15 does not require mitigation hierarchy compliance before ministerial exemptions are granted. |
| Natural Capital Accounting Taskforce (spring 2026) | ALTO’s financial model contains no natural capital valuation of the Frontenac Arch Biosphere. | C-15 contains no provision requiring natural capital accounting in ALTO’s benefit-cost analysis. |
| 30×30: protect 30% of Canada’s lands and waters by 2030 | Southern corridor crosses thousands of hectares contributing to 30×30, including within the Frontenac Arch UNESCO Biosphere Reserve. | C-15 expropriation powers create pressure toward corridor finalisation before 30×30 accounting is done. |
Bill C-15’s ministerial exemption authority applies to the Impact Assessment Act. It does not, and cannot, override the Species at Risk Act. SARA’s core prohibitions — section 32 (killing or harming listed wildlife), section 33 (damaging residences), and section 58 (destruction of critical habitat) — are standalone criminal prohibitions that the Minister of Transport cannot waive.
The southern corridor intersects confirmed or probable critical habitat for more than a dozen Schedule 1 SARA-listed species: Grey Ratsnake (Frontenac Axis, Threatened), Blanding’s Turtle (Threatened), Wood Turtle (Endangered), Spotted Turtle (Endangered), Brook Floater mussel (Endangered), and Eastern Loggerhead Shrike (Endangered). The section 73 permit test — requiring the proponent to demonstrate the project will not jeopardise survival or recovery — must be met before any corridor is legally confirmed. Bill C-15 does not change this.
Canada’s obligations under the UNESCO Man and the Biosphere Programme are international commitments, not domestic statutory requirements. They cannot be overridden by Bill C-15 or any other domestic legislation. The Frontenac Arch Biosphere Reserve’s periodic review under Article 9 of the MAB Statutory Framework requires demonstration of active conservation of biological diversity and ecologically sustainable development.
A 300 km/h permanently fenced rail corridor bisecting the Biosphere at its most ecologically constrained point — the Frontenac Neck — would represent a categorical failure of this criterion. No UNESCO MAB compatibility assessment for the southern corridor has been published. No formal consultation with the Canadian National Commission for UNESCO or the International MAB Secretariat has been disclosed.
ALTO is presented primarily as a climate project — electrified rail reducing transportation carbon emissions. A Force of Nature notes that Canada’s protected areas store the equivalent of emissions from 57.8 billion cars annually, worth $51.1 trillion in avoided global economic damages (CPAWS, 2026). The Frontenac Arch Biosphere, as an intact boreal-to-Carolinian forest corridor including extensive peatlands and wetlands, is a significant contributor to this carbon storage function.
Routing a 300 km/h rail corridor through the Frontenac Neck would fragment these ecosystems, converting stored carbon to released carbon through construction disturbance, drainage alteration, and long-term edge effects on forest interior. The project’s climate narrative cannot survive the carbon accounting contradiction of destroying one of eastern Canada’s most significant carbon sinks to build “green” infrastructure.
The Ministers of Transport and Environment must jointly confirm, in writing and before April 24, whether Bill C-15’s exemption powers will be used for the ALTO southern corridor — and if so, how that is compatible with the proactive IAA regional assessment commitment in A Force of Nature. A statement that both instruments will be “applied appropriately” is not sufficient.
A regional IAA assessment of the Eastern Ontario corridor must be initiated immediately. The consultation has produced a substantial public record of environmental concerns that provides the factual foundation. There is no credible reason to defer it.
ALTO has not published a full inventory of SARA-listed species and identified critical habitat in the southern corridor study area. Given that the CEO confirmed surveys began in the final weeks of consultation, this information cannot exist in final form. The record cannot be legally defensible under SARA s.79 without it.
A Force of Nature commits the government to proactive conservation of UNESCO-designated landscapes. ALTO and Transport Canada must formally consult with the Canadian National Commission for UNESCO and the International MAB Secretariat regarding the southern corridor’s implications for the Frontenac Arch designation.
The Expert Taskforce on Natural Capital Accounting (spring 2026) is mandated to integrate nature’s value into decision-making. Its methodology would require ALTO’s financial model to account for the economic cost of degrading a protected area generating $3.62 in visitor spending per $1 invested. The corridor selection timeline must not outrun the Taskforce’s work.
A Force of Nature specifically names the mitigation hierarchy — requiring demonstration that all less-harmful alternatives have been exhausted before the most damaging option proceeds. Applied to ALTO, this means publishing a rigorous comparative environmental assessment of the northern corridor before confirming the southern route. No such assessment has been published.
The ALTO HSR Citizen Research Initiative does not oppose investment in improved rail service in the Quebec City–Windsor Corridor. The communities of South Frontenac, Rideau Lakes, Stone Mills, and the Frontenac Arch region understand the national case for better intercity rail.
What they are asking is that the government apply its own stated principles consistently. The same Prime Minister who enacted Bill C-15’s fast-tracking provisions announced, three weeks before this consultation closes, a $3.8 billion commitment to the opposite policy direction: proactive environmental assessment before project decisions, strengthened SARA protections, KBA mapping, natural capital accounting, and the mitigation hierarchy.
These are not CRI arguments. They are government commitments. The communities and ecosystems of the southern Eastern Ontario corridor are entitled to have them honoured — not deferred until after corridor selection, when the landscape’s most acute and irreversible harms have already been locked in.
The consultation closes April 24, 2026. The government has until then to say, clearly, which of its commitments will govern the ALTO southern corridor decision. Both C-15 and A Force of Nature cannot apply. The public is entitled to know which one will.
Submitted as part of the ALTO HSR public consultation process. Research facilitated with AI tools with human review and revision. Consultation closes April 24, 2026.