ALTO must publish a preliminary road crossing assessment identifying the number and type of crossings on each corridor option, the criteria that will be used to determine whether a crossing receives a grade separation or is closed, and the methodology for assessing detour adequacy in rural settings. Communities cannot meaningfully assess the project’s most direct local impacts without this information. ALTO’s VP of Systems Engineering confirmed on record that the project’s explicit goal is to “limit the number of overpasses.” Transport Canada’s 2023 briefing confirms 1,000+ crossings on the corridor.

ALTO must establish and publish a maximum distance between grade-separated crossings, developed in consultation with local fire services and paramedic services, before route selection is finalised. The current goal of “limiting the number of overpasses” must be reconciled with emergency response obligations.

ALTO must commission and release a fire suppression access analysis for the southern corridor, covering: apparatus response time modelling under current and projected wildfire conditions; tanker shuttle efficiency under various crossing interval scenarios; and wildfire ignition risk from rail operations. This analysis must be conducted in consultation with local fire chiefs and Frontenac and Lennox and Addington counties.

A formal Health Impact Assessment must be a mandatory condition of the federal Impact Assessment process, specifically examining EMS response time modelling, patient travel time impacts from road network changes, displacement effects on patient–provider relationships, and mitigation requirements. The HIA must be conducted in consultation with local paramedic services, Ornge air ambulance, Ontario Health teams, and affected municipalities.

Before construction approvals are granted, ALTO must commit to: rail-based materials delivery with measurable, binding targets; pre-construction baseline road condition surveys with independent documentation; binding compensation mechanisms indexed to actual road damage; and dedicated student transportation and emergency services construction liaisons with minimum 90-day advance notice obligations.

ALTO must commission and publicly release a farm access impact assessment identifying every agricultural operation directly traversed by the corridor; the number and configuration of farm access crossings proposed; the process for determining underpass and overbridge specifications; and the compensation framework for going-concern losses. The assessment must address: has ALTO mapped the tile drainage systems in the southern corridor? And what is the estimated total area of productive agricultural land that would be permanently removed from production, including the 60-metre right-of-way, traction substation sites, maintenance depots, and associated infrastructure?

ALTO must commission and release pre-construction groundwater baseline surveys of the karst aquifer system along the Napanee limestone plain before any corridor is confirmed. Without baseline hydrogeological data, the impact on drinking water for communities served by the Napanee River and Stone Mills wellfields cannot be assessed, mitigated, or costed. Approximately 74% of wells in this terrain are drilled into fractured bedrock.

ALTO must establish a binding programme of continuous well monitoring for all private residential and agricultural wells within a defined setback distance, funded entirely by ALTO and commencing no later than two years before construction. ALTO must publicly commit that any homeowner or farmer whose private water supply is adversely affected will receive: prompt interim water supply at no cost; independent professional assessment; and either full restoration or complete replacement compensation — without requiring the homeowner to establish causation through litigation.

ALTO must confirm how drainage disputes arising from construction and operation will be resolved, given the constitutional limitation on provincial Drainage Act enforcement against federal Crown corporations. A clear, accessible dispute resolution mechanism must be established before construction commences.

ALTO must clarify whether property owners whose land is adjacent to but not directly expropriated by the corridor will receive any compensation for loss of property value. Federal expropriation law addresses land taken; it does not automatically compensate landowners for the diminution in value of retained property. This gap affects potentially thousands of properties along both corridors.

ALTO must publicly disclose what would happen to expropriated properties if the project is cancelled after land acquisition has commenced. ALTO’s Amended Corporate Plan 2024-25 to 2028-29 confirms that “risk-mitigating ‘no regrets’ land acquisitions” were planned to commence in the 2025–26 fiscal year — before the route has been confirmed and before any community was informed. Canada’s directly relevant precedents (Mirabel Airport 1969, Pickering Airport 1972) demonstrate the human consequences of such cancellations.

ALTO must publicly disclose the full scope and location of any land already acquired, optioned, or subject to “no regrets” pre-acquisition activity. Communities and landowners are entitled to know whether land in their area has already been acquired or optioned before the route they were asked to comment on has been confirmed.

ALTO must commission and release a Student Transportation Impact Assessment conducted in partnership with the six affected school boards and three transportation consortia. This assessment must model ride-time impacts, stop location impacts, and boundary revision requirements for the full corridor. School boards must be designated as formal ALTO stakeholders. Road crossing closures will force bus detours that breach Ontario’s 75-minute elementary ride-time standard on affected routes. Student Transportation of Eastern Ontario faces a structural $11.9 million funding deficit with no mechanism to absorb federally imposed route restructuring costs.

ALTO must identify, in consultation with the Ministry of Education, how federally imposed school bus route restructuring costs will be funded. The current structural funding deficit at STEO cannot be resolved through provincial mechanisms when the cost source is federal infrastructure disruption.

ALTO must engage the Ontario Minor Hockey Association and Hockey Eastern Ontario directly before route selection is finalised. The cross-jurisdictional governance problem created by a corridor bisecting the OMHA–HEO boundary has no precedent and no established resolution pathway. Minor hockey in Ontario has already lost 38,400 registered youth players since 2006.

ALTO must commission and release a systematic assessment of impacts on the OFSC trail network for all corridor options. The OFSC has formally confirmed (April 7, 2026) that it “is not in a financial position to cover the costs” of required crossing infrastructure, with 19 clubs, 4 Districts, and 2,196.79 km of trails at risk — supporting a $3–6 billion annual economic activity, $1.48 billion in direct expenditure, 9,307 jobs, and $538 million in taxes, all in communities that would receive no HSR station.

ALTO must commission and publicly release a systematic heritage burial site survey of the full Eastern Ontario study corridor, covering: registered cemeteries on title; known unregistered cemeteries from OGS/OHS databases; historically probable pioneer family plot locations based on Loyalist-era land grant records; Indigenous burial grounds; and field verification. 51 cemeteries have been identified within 15 km of the corridor centreline across South Frontenac, Central Frontenac, and Rideau Lakes townships alone, using only two partial-coverage datasets.

ALTO must obtain and preserve a complete CRHP data export for the full southern corridor before Parks Canada retires the Register in spring 2026. The CRHP will not exist when the federal Impact Assessment commences in 2027. ALTO must confirm which of the six heritage and archaeological datasets identified in the March 11, 2026 submission have been obtained, under what agreements, and how they are being used.

ALTO must publicly disclose whether it relies on any federal paramountcy argument or Bill C-15 provision to override provincial cemetery protections under the Funeral, Burial and Cremation Services Act, 2002. Any such claim must be subject to independent legal review before route selection. Veterans Affairs Canada and the Commonwealth War Graves Commission must be confirmed as consulted on the Eastern Ontario corridor study area.

ALTO must accept GPS coordinate datasets for heritage sites in machine-readable form and incorporate them into the consultation map. The current limitation requiring individual manual pin entry for each coordinate resulted in GPS-coordinated burial site data submitted March 3, 2026 not appearing on the consultation map. This is a process failure requiring correction.