Publish a replacement business case for the ALTO project as currently specified (300 km/h HSR, $60–90 billion). The JPO Business Case Update (December 2021), the government’s only formal financial analysis, found the predecessor project financially unviable at less than half the current capital cost and specification. No replacement has been published. A business case for the project actually being proposed must be released before any route selection is finalized.

ALTO must publish a reference-class forecast of total project cost and ridership, applying Flyvbjerg’s methodology (44.7% average rail overrun; 51.4% average ridership shortfall) to its current estimates. A promoter-class estimate alone does not meet the standard required for public accountability on a project of this scale.

Up to $60 million of public money funded three independent analyses including cost estimates, ridership models, financial structures, and risk registers. These are Crown-owned intellectual property. They are precisely the independent evidence the public needs to evaluate ALTO’s claims. They must be released.

ALTO’s CEO has restated the 24 million passenger projection publicly without ever disclosing the methodology. An independent demand audit must be commissioned by Transport Canada — not by ALTO or Cadence — to avoid promoter bias. The Munk School of Global Affairs GEPL independent model, the only publicly available ridership model with a disclosed methodology, projects approximately 9.44 million passengers by year 20 for the Toronto–Montréal segment alone: less than 40% of ALTO’s 2055 target. The gap between these figures must be publicly reconciled before the project proceeds to financial close.

ALTO has not published an EV counterfactual analysis — the most important single gap in its environmental assessment. A project whose primary environmental justification is carbon reduction must demonstrate that this benefit materializes under realistic scenarios. No scenario achieves carbon payback within any credible operating horizon at 4 million passengers once the electric vehicle fleet transition is accounted for.

Publish a per-municipality net fiscal impact analysis for all municipalities traversed by the southern corridor. An aggregate corridor-level economic return is not an adequate substitute for the per-municipality analysis that communities need to understand whether the project benefits or harms their fiscal position. The international academic literature is unambiguous: rural municipalities traversed by HSR without a station experience net economic losses.

The $3–8 billion cost of grade separation across 1,000+ crossings has never appeared in ALTO’s published estimates. This must be broken out explicitly, with the proposed crossing treatment hierarchy disclosed.

The PBO should be asked to review: the $60–90 billion cost estimate against reference-class benchmarks; the ridership projections against the only disclosed independent model; the 30-year subsidy requirement under realistic ridership scenarios; and the opportunity cost of $3.9 billion in pre-construction operating expenditure.

Formally confirm or deny in writing the verbal commitment made at the Perth public consultation that the ALTO corridor will be enclosed with a domed roof structure along its full length. If this commitment stands, ALTO must document it formally, commission engineering specifications and a cost estimate, and explain why this unprecedented structure has not appeared in any published financial estimate. Formally document all other environmental mitigation commitments including crossing structure specifications, habitat compensation ratios, de-icing protocols in karst zones, and species-at-risk management measures.

Before confirming any corridor in Eastern Ontario, commission and publicly release an independent comparative assessment of passenger and freight rail service improvements along existing transportation corridors, including the Highway 401 corridor, evaluating each alternative against the same criteria applied to the northern and southern ALTO corridors, and with equivalent cost-benefit analysis.