Tag: Access to Information

Procured and then

ALTO HSR Citizen Research Initiative · Brief · September 2026

Procured, and Then?

ALTO commissioned the outside view. Whether it changed anything is the one question the record does not answer.

Independent, non-partisan research · citizenresearch.ca

In Plain Language

The standard fix for over-optimistic infrastructure forecasts is to check them against what comparable projects actually cost and carried, rather than trusting the project’s own bottom-up numbers. That check is called reference-class forecasting, and ALTO commissioned one. It hired the firm founded by the researcher who developed the method.

That is to ALTO’s credit. But commissioning a check and acting on it are different things, and only one document would show which happened: a comparison putting ALTO’s own published figures beside the ones the check produced. The Initiative asked for that record. The response was extended to 18 September 2026, with notice that a third party would be consulted — a step the Act provides for where an institution intends to release records that may contain a supplier’s commercial information.

Meanwhile, in June 2026, ALTO published two studies putting large dollar values on the project’s benefits. Neither sets those benefits against what the line would cost. This brief looks at all three documents and asks what they show about how the project’s numbers are being assembled — and what a single unredacted release would settle.

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Related

HPR Research Report, Chapter 1

The forecasting framework this brief applies, set out in full

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01 · The Instrument

ALTO commissioned the outside view

Chapter 1 of the HPR Research Report sets out the method this brief relies on, so it is only summarised here. Large infrastructure forecasts miss in a consistent direction: costs come in high, benefits come in low. The established corrective is to stop treating a project as unique and instead compare it against the recorded outcomes of projects like it. The technique has a name — reference-class forecasting — and a literature behind it.

In 2024 ALTO issued an advance contract award notice, PAS240625-002-00, for reference-class forecasting, should-cost and should-schedule modelling, and a series of Challenge Boards. An advance contract award notice is the instrument used when a department intends to award without competition, on the basis that only one supplier can do the work. The named supplier was Oxford Global Projects, the consultancy founded by Bent Flyvbjerg and Alexander Budzier.

This is worth stating plainly, because it cuts against the easy criticism. ALTO did not ignore the outside view. It went out and procured it, from the people who developed it.

02 · The Question

Buying the instrument is not the same as letting it bind

Reference-class forecasting corrects a forecast only if the number it produces is permitted to move the decision. A should-cost that is commissioned, delivered and then filed next to an unchanged inside-view estimate has not corrected anything. The method’s own literature is explicit that the failure mode is not the absence of the outside view but its subordination — the number produced, and then declined.

So the decisive record is not the existence of the forecast. It is the comparison: does ALTO’s published capital cost reflect its own reference-class should-cost, or diverge from it? One document would answer that — the inside view and the outside view set side by side.

A test, not an accusation

This yields something better than a claim about anyone’s conduct: a prediction that can be checked. If the commissioned reference-class figures are more conservative than the numbers ALTO has published, the outside view was procured but not applied. If they match, the Initiative’s cost critique weakens accordingly.

We do not know which. Nothing in this brief asserts that ALTO set the analysis aside. The point is that the question is answerable, that a single document answers it, and that the document exists.

03 · The Clock

The record will arrive after the decision has moved on

The Initiative requested the reference-class records under access to information — the workbook, the should-cost and should-schedule outputs, and above all any document setting the inside view beside the outside view. Request A-2026-0004 was met in June 2026 with a ninety-day extension carrying the response to 18 September 2026, together with a notice invoking third-party consultation under section 27.

Section 27 consultation is a routine step, and it is worth being precise about which way it points. The section applies where the head of an institution intends to disclose a record that may contain a third party’s commercial information: the notice tells that third party of the intention to release and gives it twenty days to make representations against disclosure, and invoking the section is what permits the response time to be extended. The notice on A-2026-0004 therefore records that Alto has turned its mind to releasing the reference-class records and has given Oxford Global Projects the opportunity to object. It is not a signal that the material will be withheld.

What remains is a question of timing rather than intent. The third party may object and the institution may then withhold some of the figures; equally it may not. What can be said is the sequence: the record capable of testing the decision will arrive after further commitment has been made. What it contains, the disclosure itself will settle.

Why timing decides this

An outside-view check disciplines a decision only while the decision is still open. Once enough money is committed, the arithmetic changes: the cost of stopping is subtracted from the cost of continuing, and a project can show better value for money the more has already been spent on it. Britain’s High Speed Two reached exactly that point — the National Audit Office found in June 2026 that the ratio for completing the programme had risen even as the programme grew more expensive, because the estimated cost of cancelling had more than quadrupled.

The cheapest moment to apply the test is before that crossover, not after it.

04 · The Benefit Case

Two studies, no cost side

In June 2026, two months after the consultation closed, ALTO released two commissioned studies. A computable general equilibrium assessment by Aviseo Consulting reports a national real GDP gain of about $24.4 billion a year. A corridor tourism study by CPCS with HDR adds up to $3.9 billion in GDP and 43,000 jobs.

Neither nets a cost. The macroeconomic study excludes construction and operating expenditure by design; the tourism study has no cost side to exclude. Both are benefit totals unaccompanied by the outlay required to obtain them. Both, to their credit, describe their outputs as illustrative and order-of-magnitude rather than forecasts, and make the largest figures conditional on tourism policy the railway itself does not deliver.

The scenario range has a floor and no ceiling on the downside

Each study is built as a fan of scenarios, from pessimistic to optimistic. In both, the entire fan sits above zero. The macro study reports welfare increasing in every scenario; the tourism study’s weakest case is still $177 million and two thousand jobs. The modelled question is how large the gain is, never whether there is a loss.

Adverse mechanisms are identified but do not reach the total

The tourism study acknowledges that faster trains shorten stays and convert overnight visits into day trips, and shows length of stay falling in several cities. The aggregate rises regardless.

The two studies disagree, and each resolves the disagreement upward

The macro study omits domestic tourism on the ground that it is largely substitution from other household spending, with little net effect on national output. The tourism study builds most of its $33.7-billion base, and most of its headline uplift, from precisely that in-corridor domestic travel — counted through gross multipliers that assume no such displacement. The two treatments diverge, and in each case the treatment adopted is the one that yields the larger figure for that study.

The studies import the literature’s upside but not its realisation record

Both studies draw their benefit magnitudes from the international high-speed rail literature — the same comparison set the Initiative uses. What they import is the size of the upside. What they do not import is that literature’s record on realisation: rail benefits arriving at about two-thirds of forecast, and passenger numbers overstated by roughly a hundred per cent.

Each of the four observations above is a description of what the documents contain. Taken together they describe a benefit case in which every point of divergence has resolved in the same direction — which is the pattern the forecasting literature says to look for, and the reason an independent outside-view comparison matters more, not less, once numbers of this size are in circulation. The same two studies are examined in detail in the Initiative’s briefs Two Point Two Trillion and At Face Value.

05 · The Ask

Publish the comparison

The Initiative’s recommendation is narrow and does not require anyone to accept a word of its own analysis.

01
Release the comparison in full. ALTO should publish its reference-class should-cost and should-schedule outputs alongside its published capital cost and benefit-cost figures, unredacted. The outside view was commissioned to be seen, not filed.

02
Publish the benefit studies against a cost. A $24.4-billion annual benefit figure is not interpretable without the outlay required to obtain it. The two June 2026 studies should be accompanied by an appraisal that nets one against the other.

03
Apply the test before further commitment. The window in which an outside-view check can still change a decision is open now. It narrows with every disbursement.

It requires one document to be made public. The framework behind the request is set out in full in Chapter 1 of the HPR Research Report; what ought to be built instead is the subject of the chapters that follow it.

How to read this brief

Every figure attributed to Alto, Aviseo, CPCS, the National Audit Office or a published paper is quoted from the source listed below and can be checked there. Nothing else here is a calculation of ours: the argument rests on what the documents contain and on the sequence of dates, not on a competing estimate.

Where a record has not been released, this brief says so rather than inferring its contents, and makes no claim about why any extension was taken or any figure was or was not published. The prediction in section 02 is stated in both directions and will be settled by the disclosure, not by us.

Sources

Documents relied on

1
Alto (VIA HFR – VIA TGF Inc.). Advance Contract Award Notice PAS240625-002-00 — project management and control expertise; pre-identified supplier Oxford Global Projects UK Limited. 2024.

2
Alto (VIA HFR – VIA TGF Inc.). Notice of extension, Access to Information request A-2026-0004. June 2026. On file with the Initiative.

3
Aviseo Consulting. An Overview of the Structural Economic Impacts of Alto: Computable General Equilibrium Modelling Approach to Assessing High-Speed Rail in the Toronto–Québec City Corridor. Prepared for Alto. June 2026.

4
CPCS, in association with HDR. Tourism in the Alto Corridor: Current Conditions and Potential Impacts. Prepared for Alto. June 2026.

5
National Audit Office. High Speed Two reset. Report by the Comptroller and Auditor General, Session 2026-27, HC 52. London: National Audit Office, June 2026.

6
Flyvbjerg, Bent. “Quality Control and Due Diligence in Project Management: Getting Decisions Right by Taking the Outside View.” International Journal of Project Management 31, no. 5 (2013): 760–774.

7
Flyvbjerg, Bent. “Top-Ten Behavioral Biases in Project Management: An Overview.” Project Management Journal 52, no. 6 (2021): 531–546.

Coalition for Better Rail · ALTO HSR Citizen Research Initiative · citizenresearch.ca · Brief · September 2026
Independent, non-partisan research on Canada’s proposed Toronto–Québec City high-speed rail corridor.

September 2, 2026

Hours are not dollars

Hours Are Not Dollars

Almost none of ALTO’s $49.5 billion is money. It is time — and a saved hour cannot service a loan. Here is what that figure actually is, how it was built, and why it says nothing about who pays for the railway.

ALTO HSR Citizen Research Initiative · Economics Explainer · August 2026 · Companion to the audit It Left the Rules Behind

⚠ Where the Number Sits

In August 2026 ALTO published Canada’s Moment: The Economic Opportunity of High-Speed Rail, reporting $49.5 billion in benefits against a construction cost of $60 to $90 billion. Those benefits are not money in a bank account. They are mostly hours — time that travellers would have spent on the road or at an airport — stretched over sixty years and converted into today’s dollars.1

The tool that does the converting is called a discount rate. ALTO uses 3.5 per cent a year. Change that one number and the headline changes by tens of billions, without a single train or passenger changing.

In One Paragraph

The $49.5 billion is a measure of worth, not of funds. The tool that produces it, a discount rate, answers the question is this worth doing? It does not answer the question who pays, and how? Those are separate ledgers, and ALTO’s report is detailed on the first and thin on the second. This explainer sets out what the rate does, shows the arithmetic openly, and then follows the money to the place the appraisal never goes: the difference between what it costs the government to borrow and what a private partner needs to earn.

One finding runs against the grain and is stated here first. Two of the adjustments ALTO leaves out would have made its benefit figure larger, not smaller. The problem is not that the number is tilted. The problem is that a reader is given one number, no range, and no way to know that any of these choices were made.

Start Here

What a discount rate is, in ordinary words

Ask yourself a simple question. Would you rather have $100 today, or $100 in forty years? Almost everyone takes it today. The money is useful now, the future is uncertain, and by 2066 we will probably all be somewhat better off anyway, so $100 will matter a little less to us then than it does now.

Economists turn that instinct into a percentage. A discount rate shrinks future amounts back to what they are worth to us today, by a fixed amount each year. At 3.5 per cent, a benefit arriving sixty years from now counts for about 13 cents on the dollar. At 8 per cent, the same benefit counts for about one cent.

That is the whole mechanism. It sounds technical and it is arithmetically simple. But it matters enormously for a railway, because of when the money and the benefits arrive.

13¢

what a dollar of benefit in year 60 is worth today at ALTO’s 3.5 per cent

23¢

the same dollar at 2.5 per cent, the rate ALTO’s own cited manual requires be tested

1¢

the same dollar at 8 per cent, the rate identified in 2007 Treasury Board guidance

The timing is what makes this decisive. Construction money is spent early — from 2029 through the early 2040s — so it is barely shrunk at all. The benefits arrive later and keep arriving for sixty years, so they are shrunk heavily. Anything that changes the rate therefore hits the benefit side hard and the cost side hardly at all. A project’s whole case can move from comfortable to marginal without anything physical changing.

The Arithmetic, Shown Openly

How much the answer moves

The table below is the Initiative’s own arithmetic, not a re-run of ALTO’s model. It takes a steady stream of benefits running for sixty years, beginning fifteen years from now, and asks what that stream is worth in today’s dollars at different rates. The last column simply scales ALTO’s published $49.5 billion by the same proportion, to show the size of the swing.

Discount rate used	Value of the stream	Relative to 3.5%	$49.5B scaled
2.5 per cent	21.34	1.43×	$71.0B
3.0 per cent	17.76	1.19×	$59.1B
3.5 per cent — ALTO’s rate	14.89	1.00×	$49.5B
UK declining schedule	15.61	1.05×	$51.9B
5 per cent	9.11	0.61×	$30.3B
7 per cent	5.09	0.34×	$16.9B
8 per cent	3.90	0.26×	$13.0B

Assumptions, stated so the arithmetic can be checked: a level benefit stream of one dollar per year, sixty years of operation beginning in year 16, discounted back to a year-zero base. ALTO’s real benefit stream ramps up rather than running level, so the exact figures would differ; the proportions are what matter here. The scaled column is illustrative and is not ALTO’s number at those rates.

Read the middle rows first. At 8 per cent, the same railway carrying the same passengers saving the same hours produces a benefit figure roughly a quarter the size. At 2.5 per cent it produces one roughly forty per cent larger. Nothing about the trains changed. Only the parameter changed.

This is why appraisal manuals require the calculation to be repeated at more than one rate and the results published as a range. It is not a bureaucratic formality. It is the only way a reader can tell whether a case is robust or whether it depends on a parameter choice.

Where 3.5 Per Cent Comes From

A number with a family tree

ALTO’s report attributes its rate to one source: the Business Case Manual Volume 2: Guidance, published by Metrolinx, the Government of Ontario’s transit agency for the Toronto and Hamilton region.2 That manual sets a social discount rate of 3.5 per cent, alongside an evaluation period of five to sixty years.

The 3.5 per cent figure is not original to Metrolinx. It is the rate used by HM Treasury in the United Kingdom, and the Treasury publishes exactly how it was assembled. Three judgements are added together:

0.5 per cent for simple impatience. People prefer good things sooner. Half a percentage point is the allowance for that.

1.0 per cent for the risk that the future does not arrive as expected. Wars, pandemics, collapses. A benefit promised in 2080 might never materialise, so it is discounted a little further.

2.0 per cent because people in the future will be richer. If incomes rise about 2 per cent a year, our grandchildren will be considerably better off than we are, and an extra dollar will matter less to them than it does to us. This is the largest of the three, and the most contestable.

Those three add to 3.5.3

Notice what the rate is not. It is not a market price, an interest rate, or anything anyone can look up. It is a set of judgements about how much weight to give people who are not yet born — and every one of the three is disputed by serious people. That is not a criticism of the figure. It is the reason a serious appraisal shows what happens when the figure moves.

The detail that cuts in ALTO’s favour

HM Treasury does not apply 3.5 per cent forever. The rate steps down to 3.0 per cent for years 31 to 75, and 2.5 per cent thereafter,3 and the Treasury’s supplementary guidance instructs practitioners in the same terms: the standard 3.5 per cent for years 1 to 30, and 3.0 per cent for years 31 to 75.4 The reason is uncertainty: the further out you look, the less confident anyone can be in the parameters, and the lower the rate should be.

ALTO discounts a sixty-year stream at a flat 3.5 per cent throughout. Applying the stepped-down schedule instead would have made ALTO’s benefit total about five per cent larger, as the fourth row of the table above shows. This is a conservatism in ALTO’s favour, and it should be credited as one. It is recorded here because a reader assessing where a federal appraisal input came from deserves the whole picture, including the parts that do not fit a critical narrative.

The Canadian Comparison

What the federal government uses, and the gap where a manual should be

Canada has approached the same question from the opposite end, and it is worth understanding the difference, because it produces a far higher number.

The British method asks a question about values: how much should we care about the future? The Canadian method asks a question about alternatives: what else could this money have done? If public money invested elsewhere in the economy would have earned, say, 8 per cent, then a project has to clear that bar to be worth funding — otherwise the country was better off doing the other thing. That is what economists mean by the opportunity cost of capital.

Neither question is wrong. They are simply different questions, and the second one produces a much tougher test than the first.

The Treasury Board’s 2007 guidance identified 8 per cent as the appropriate rate, with sensitivity tests at 3 and 10 per cent, on that opportunity-cost basis.5 The current federal Policy on Cost-Benefit Analysis still directs departments to use the opportunity cost of capital as the discount rate, permitting a social rate only in defined cases — including where impacts run fifty years or more — and requiring that even when a social rate is used, results using the opportunity cost of capital must also be reported.6

Two honest qualifications belong here, and neither is small. First, that federal policy governs regulations, not capital projects, so it does not bind ALTO. Second, the current edition of the Treasury Board guide is no longer published on canada.ca and is available only through an internal government wiki page,7 so the Initiative has not been able to verify the figure it now specifies.

And the federal manual for transport projects specifically? Transport Canada’s guide to benefit-cost analysis dates from 1994.8 Thirty-two years later, there is no current, public federal appraisal manual for a project of this kind. That absence is very likely why a national railway is being appraised using a provincial transit agency’s parameters — and it is a finding about the machinery of government rather than about ALTO.

Even the academic case for 3.5 per cent has conditions

The most cited Canadian argument for a 3.5 per cent rate comes from the economists Boardman, Moore and Vining, who reject the 8 per cent approach. So there is a respectable Canadian case for ALTO’s rate. But it is a conditional case, and the conditions are specific.

Condition one: the project runs under fifty years. Beyond that, they recommend a rate that steps down over time, for the same reason the UK Treasury does — nobody can see that far ahead with confidence.

Condition two: the project must not pull money away from private investment. The money for a public project comes from taxes or borrowing, and it would otherwise have been used by someone else. Some of it would have been spent, and some would have been invested — a business expansion, new equipment, a factory. Those two are not equivalent. A dollar diverted from someone’s spending costs the economy that one dollar. A dollar diverted from investment costs more, because that investment would have gone on producing returns for years afterwards.

And if the project does pull money from investment, there is a fix. Rather than argue about the rate all over again, you take the portion of the cost that displaced private investment and mark it up by 26 per cent before putting it in the calculation — because that is roughly what the lost investment was worth to the economy over time. Economists call the 1.26 multiplier a shadow price of capital. It is simply a way of using a generous discount rate honestly, instead of using it to pretend the money was free.5

ALTO’s appraisal period is sixty years, which fails the first condition outright. Whether a $60 to $90 billion draw on Canadian capital displaces private investment is a real question, not a technicality — and the mark-up would apply only to the share that does, not to the whole sum. Neither condition is mentioned in the report.

The pattern is the one the companion audit It Left the Rules Behind describes: a number travels, and the conditions attached to it stay behind.

The Precedent

The last time anyone published these numbers for this corridor

ALTO’s stated reason for publishing no benefit-cost ratio is that the cost estimate is not yet mature enough to support one. It is worth knowing that a predecessor project on the same corridor did publish one, at a comparable stage, and published the funding ledger alongside it.

In December 2021 the Joint Project Office — a body formed by VIA Rail and the Canada Infrastructure Bank — completed a Business Case Update for High Frequency Rail, the slower, cheaper predecessor to ALTO between Toronto and Québec City. It was released through access to information by the Canada Infrastructure Bank in November 2025.16

What the 2021 business case published	Figure
Capital cost, with electrification (2020 prices)	$27.71B
Projected revenue over 30 years (2019 prices)	$33.7B
Operations, maintenance and rehabilitation, 30 years	$32.5B
Net present value over 30 years	−$21.1B
Benefit-cost ratio	~0.13
Expanded benefit-cost ratio	~0.4
Public subsidy over 30 years, by delivery model	$37.1B to $42.2B

Source: Joint Project Office, High Frequency Rail Business Case Update V.002, 10 December 2021. Ratios at Table 14, page 43; capital, revenue, lifecycle and net present value figures in the executive summary, pages 7 and 8; subsidy comparison at Table 4, page 8.

A benefit-cost ratio of 0.13 means about thirteen cents of measured benefit for every dollar of cost. The wider figure of 0.4 is what the same table calls an expanded ratio, and the difference between the two is worth understanding, because it is the larger of the two numbers.

The expansion adds two items. One is agglomeration — the economic gain from businesses being better connected — worth $0.3 to $0.9 billion. The other, worth $5.6 to $7.6 billion, is a resource correction: the fares new passengers would pay, counted as a benefit because they arrive as revenue for the operator. That single item is larger than the journey time savings and all the external benefits put together. The business case itself notes that both are relatively new to Canadian economic appraisal, which is why it reports the ratio with and without them.

The same two sources, five years apart

The 2021 economic case states where its parameters came from: the social discount rate, the value of time and the value of external impacts were taken from a combination of Metrolinx and Ministère des Transports du Québec guidance. Those are the same two sources ALTO cites in 2026.

So the identical parameter lineage, applied to a $27.71 billion version of this corridor, produced a published ratio of 0.13. Five years later, on a project costing two to three times as much, the same two sources are cited and no ratio is published at all.

And it kept the two ledgers apart

The 2021 document also shows how the distinction this page has been drawing is meant to work in practice. Its net present value calculation used a discount rate of 2.5 per cent, sourced explicitly to the ten-year average of the 30-year Government of Canada benchmark bond — a financing rate, taken from what the government actually pays to borrow. Its economic case used the social parameters from Metrolinx and MTQ. Two questions, two rates, both disclosed, in a single document.

Three cautions, stated plainly. High Frequency Rail is not ALTO: different technology, different speed, a $27.71 billion cost rather than $60 to $90 billion, and a thirty-year evaluation rather than sixty. The JPO described its own results as preliminary. And none of these figures transfer to ALTO by arithmetic. What the document establishes is narrower and harder to set aside: a benefit-cost ratio can be produced for a project on this corridor at this stage of development, because one was.

One further point belongs on the record. The identical document was also released under a separate access request, and in that version the whole net present value section, the capital cost figure, the revenue figure and both ratios were blacked out — along with the subsection titles of the Economic Case within the table of contents, and the construction employment figure in the executive summary. No exemption provision is marked against any of it.17 Same document, same date, two releases, opposite outcomes.

Following the Money

Three different rates, and only one of them is in the report

Here is the heart of it. People use the phrase “the discount rate” for three quite different things, and conflating them is how an appraisal result gets mistaken for a financing plan.

1. The appraisal rate — 3.5 per cent

Used to decide whether a project is worth doing. No money moves because of it. It turns hours saved and collisions avoided into a single present-day figure so they can be compared with the cost. Nobody charges it, nobody pays it, and no bank uses it.

2. What it costs the government to borrow

Real money, actually paid. When the federal government borrows for thirty years it has been paying in the region of 3.7 to 3.9 per cent during 2026. Take off inflation, which the Bank of Canada aims to hold at 2 per cent, and the true cost of the money is roughly two per cent a year.9 If the state simply builds the railway and holds it, this is what the borrowing actually costs, and it is lower than the appraisal rate.

3. What a private partner needs to earn

Considerably more. If a pension fund or infrastructure investor builds the railway, it is putting its own money at risk — the risk that construction costs more than planned, or that too few people ride. It requires a return for carrying that risk, and that return is paid out every year for decades. This is the rate that decides what the public actually hands over, and it appears nowhere in ALTO’s economic report.

The gap between the second and the third is the entire public-private question. If the government borrows at 2 per cent and builds the railway itself, that is what the money costs. If a private partner builds it instead and needs 8 per cent, someone has to make up the difference — every year, for as long as the arrangement lasts. That someone is the public.

So a project can pass the 3.5 per cent test comfortably and still require very large annual public payments to get built. The appraisal will go on saying “worth doing.” It will never say who writes the cheque, for how long, or at what return.

Why the $49.5 billion cannot pay for anything

This is the point most easily missed, and it is not a technicality. Nearly all of ALTO’s benefit figure is not cash. It is hours of travel time, collisions that did not happen, tonnes of emissions avoided. These are real and they matter. But a saved hour cannot service a loan, meet a payroll, or renew a worn rail.

The money that actually funds a railway comes from two places only: fares, and government payments. ALTO’s report handles that second ledger in a few pages, supported chiefly by the operating margins of three foreign railways, and it publishes no fare, no revenue figure and no farebox recovery ratio. So the document is expansive about whether the project is worth doing and close to silent about how it would be paid for.

A Canadian Example, Fully Documented

How the Montréal REM is actually funded

The Réseau express métropolitain is a 67-kilometre automated light metro in Greater Montréal, built, owned and operated by CDPQ Infra, a subsidiary of the Québec pension fund manager. It is the clearest Canadian illustration of what the third rate looks like once it becomes money, and its terms are public.10

Who put up the capital

CDPQ Infra $2.95B; the Government of Québec $1.283B; the Government of Canada $1.283B; Hydro-Québec $295M; the regional transit authority $512M. The construction estimate rose from $6.3 billion in 2018 to $7.95 billion by 2023, an increase CDPQ Infra absorbed under its agreement.11

How the money returns

Not through fares. The regional transit authority pays CDPQ Infra 72 cents for every kilometre every passenger travels, indexed annually to the Consumer Price Index. That single rate covers construction, operation and long-term maintenance.12

If ridership beats forecast

The rate steps down. CDPQ Infra has described trips beyond 15 per cent above forecast being paid at roughly 57 cents, and trips beyond 40 per cent above forecast at the user fare itself.13

The two return targets

8 to 9 per cent for CDPQ Infra. 3.7 per cent for the governments. Both were set at the outset and publicly reaffirmed during construction.14

That pair of numbers is the whole point of this section, made concrete. The same railway, the same track, the same passengers — and two participants requiring returns that differ by more than double. The difference is not a rounding error in an appraisal. It is paid out, in cash, on every passenger-kilometre, for as long as the agreement runs.

Why this case and not another. The REM is not an analogy picked at random. CDPQ Infra leads Cadence, the consortium selected in February 2025 as ALTO’s private development partner. AtkinsRéalis — formerly SNC-Lavalin, a member of the group that built the REM and, with Alstom, of the group that supplies and operates its trains — is also a Cadence member. The other Cadence members are SYSTRA Canada, Keolis Canada, SNCF Voyageurs and Air Canada.18 The REM is the lead sponsor’s own model, which CDPQ Infra presents publicly as an innovative approach to delivering public infrastructure. That is what makes it the most informative available guide to how a private partner’s return might be priced here.

An important caution. ALTO is nonetheless not the REM, and this is not a prediction. Canada is to retain permanent ownership of the ALTO network, which was never the REM arrangement; the project is in a co-development phase running to 2029; and no payment mechanism has been disclosed. Cadence is a different group with different members and a different contract. The REM is offered as the one Canadian case where the arithmetic of a private partner’s return has been made public — which is exactly what has not yet happened for a project several times its size.

Notice what a payment mechanism does with risk. Because CDPQ Infra is paid per passenger-kilometre, a shortfall in riders is a shortfall in its own revenue — the investor carries the demand risk. Under a different structure, where the public pays for the railway simply being available, a shortfall in riders changes nothing the partner receives and everything the public pays.

Same railway, same disappointing ridership, opposite consequences. Which of those applies to ALTO has not been published.

Limits of This Explainer

What this does not claim

On the rate

3.5 per cent is not wrongIt is a mainstream, well-supported choice for long-lived public investment. This explainer does not argue that ALTO’s rate is too low.

Two omissions favour ALTOBoth the stepped-down schedule and the sensitivity test its cited manual requires would have produced a larger benefit figure. The omissions do not all run one way.

The arithmetic is illustrativeThe table uses a level benefit stream and a stated start year. It shows the shape of the sensitivity, not a recalculation of ALTO’s result.

The 2021 ratios are not ALTO’sHigh Frequency Rail was a different and cheaper project assessed over thirty years, and its authors called the results preliminary. Those figures are cited as evidence that a ratio can be produced at this stage, not as an estimate of ALTO’s.

On the comparisons

Nothing here binds ALTOMetrolinx guidance, UK Treasury practice and federal regulatory policy carry no legal force over this project. They are offered as points of comparison, one of which ALTO chose to cite itself.

The federal figure is unverifiedThe 8 per cent rate is documented from 2007 guidance through peer-reviewed sources. The current edition of that guide is not publicly posted, and the Initiative does not assert what it now specifies.

We do not say whyWhere the report does not state something — a fare, a payment mechanism, a sensitivity test, a range — this page says so rather than inferring it, and makes no claim about why any figure was or was not published, or about the intentions of anyone who prepared it.

This is a public report, not a business caseA submission to Cabinet in 2029 may contain material this document does not. What is examined here is what has been placed in public.

What Would Settle It

Two questions, answerable without releasing a model

1. Who absorbs it if the passengers do not come?

Not a forecasting question but a contract question. If a partner is paid per passenger, a shortfall reduces its return. If it is paid for availability, a shortfall costs the partner nothing and the public a great deal. Identical ridership, opposite outcomes — and ALTO has published neither the mechanism nor the cost of capital behind it.

2. What fare, and what revenue?

No fare level, average yield or farebox recovery ratio appears in eighty-three pages. Without one, the funding question cannot be examined by anyone outside the project.

Neither requires access to ALTO’s models, cooperation from its staff, or agreement about what the correct discount rate for a national railway ought to be. Both are answerable from work already done.

A third question — whether the calculation was ever run at any rate other than 3.5 per cent — belongs to the companion audit It Left the Rules Behind, which sets out the full list of tests the cited manual requires at this project’s scale and which of them appear in the report.

Sources

Primary documents

ALTO, Canada’s Moment: The Economic Opportunity of High-Speed Rail, August 2026, 83 pp. Discount rate, sixty-year appraisal period and price base in the Appendix A methodology box, sourced at footnote 65 to the Metrolinx manual; capital cost and AACE Class 5 estimate at pp. 5 and 65; direct-benefit tables headed “upper estimate”. Analysed in full in the Initiative’s companion brief Two Parameters, None of the Conditions, summarised at It Left the Rules Behind.

Metrolinx, Business Case Manual Volume 2: Guidance, August 2021, 222 pp. Economic parameters at Table 5.8: social discount rate 3.5 per cent, evaluation period five to sixty years, single blended value of time. Verified as the current edition, 21 August 2026. metrolinx.com

HM Treasury, Review of discounting in the Green Book: Terms of Reference, 16 December 2025. Sets out the derivation of the 3.5 per cent Social Time Preference Rate. The Treasury specifies four parameters — pure time preference, catastrophe risk, the elasticity of marginal utility and the growth rate — the last two of which multiply to the 2.0 per cent component described above as a single judgement. and the declining schedule of 3.0 per cent for years 31 to 75 and 2.5 per cent thereafter. gov.uk

HM Treasury, Green Book supplementary guidance: discounting, updated 5 February 2026. Instructs practitioners to use 3.5 per cent for years 1 to 30 and 3.0 per cent for years 31 to 75. gov.uk (PDF)

A. E. Boardman and M. A. Moore, “The Social Discount Rate for Canada Based on Future Growth in Consumption,” Canadian Public Policy, vol. 36 no. 3 (2010), pp. 325 onward. Records the Treasury Board Secretariat’s 2007 interim recommendation of an 8 per cent social discount rate with sensitivity rates of 3 and 10 per cent on a weighted social opportunity cost of capital basis; argues instead for 3.5 per cent, conditional on a horizon under fifty years and no crowding out of private investment, with a shadow price of capital of 1.26 applied to investment flows, and a declining schedule beyond fifty years. Canadian Public Policy

Treasury Board of Canada Secretariat, Policy on Cost-Benefit Analysis, in force since 1 September 2018. Requires departments to use the opportunity cost of capital specified in the TBS guide, with a social discount rate permitted in defined cases including impacts of fifty years or more, and requires opportunity-cost results to be reported in any event. canada.ca

Treasury Board of Canada Secretariat, “Requirements for developing, managing and reviewing regulations,” canada.ca, page updated 26 November 2025, accessed 21 August 2026. States that the most current version of Canada’s Cost-Benefit Analysis Guide for Regulatory Proposals is available exclusively on the Cabinet Directive on Regulation GCwiki page. The 2022 edition remains catalogued in Government of Canada Publications as an archived document. canada.ca

Transport Canada, Economic Evaluation Branch, Guide to Benefit-Cost Analysis in Transport Canada, Ottawa, 1994. Catalogued in the Transport Research International Documentation database. TRID

Bank of Canada, selected benchmark bond yields, accessed August 2026; Bank of Canada policy interest rate held at 2.25 per cent through mid-2026 against a 2 per cent inflation target. Long-bond yields move daily and should be checked against the source rather than quoted from this page. bankofcanada.ca

10.

Réseau express métropolitain, “Information about the agreement with the ARTM and its rate mechanisms.” Sets out the 72-cent per passenger-kilometre invoice to the regional transit authority, the reduction once ridership projections are exceeded, and the turnkey scope covering construction, operation and long-term maintenance. rem.info

11.

Capital structure as reported on award of the construction contracts: CDPQ Infra $2.95B, Government of Québec $1.283B, Government of Canada $1.283B, Hydro-Québec $295M, ARTM $512M, against a construction cost of $6.3B. The estimate was revised to $7.95B in September 2023, with CDPQ Infra absorbing the increase under its agreement with the Québec government. International Railway Journal

12.

Gouvernement du Québec, ARTM and CDPQ Infra, “Release of the management and implementation agreement and of the integration agreement for the Réseau express métropolitain,” 23 April 2018. Confirms the $0.72 per passenger-km base cost and annual indexation to Canada’s Consumer Price Index, and the cap limiting additional municipal costs to roughly $45 to $60 million a year in then-current dollars. quebec.ca

13.

CDPQ Infra, “7 myths about the REM de l’Est,” February 2022. Describes the ridership relief mechanism: the rate falls by about 20 per cent, to roughly $0.57, for trips above 15 per cent over forecast, and equals the user fare for trips above 40 per cent over forecast. Published in the context of a later project; the mechanism described is the REM’s. cdpqinfra.com

14.

Réseau express métropolitain, semi-annual project update, 3 June 2021. Reaffirms the 72-cent rate set in the 2018 agreement and states the performance targets: 8 to 9 per cent for CDPQ Infra and 3.7 per cent for the government partners. rem.info

15.

Discounting arithmetic in this explainer computed by the Initiative on the stated assumptions: a level annual benefit stream, sixty years of operation beginning in year 16, discounted to a year-zero base; the declining-schedule row applies 3.5 per cent to years 1 to 30, 3.0 per cent to years 31 to 75, per source 3.

16.

Joint Project Office (VIA Rail Canada and the Canada Infrastructure Bank), High Frequency Rail Project: Business Case Update, V.002, 10 December 2021, 150 pp., released by the Canada Infrastructure Bank under the Access to Information Act, November 2025. Capital cost breakdown and 30-year revenue at p. 7; benefit-cost ratio, net present value and the Table 4 subsidy comparison at p. 8; economic appraisal parameters sourced to Metrolinx and MTQ guidance at p. 40; incremental capex and opex at Table 9; other impacts at Table 12; impact results and both ratios at Table 14, p. 43; net present value assumptions, including the 2.5 per cent discount rate sourced to the ten-year average 30-year Government of Canada benchmark bond, at Figure 38, p. 85.

17.

The same document released as Annexe A to access request 22-2207 (148 pp., stamped Demande d’accès à l’information #22-2207 AI(D)). In that version, section 9.7 Net Present Value Analysis survives as a heading at p. 84 with pp. 84–86 otherwise blank; section 9.8 Financial Structuring at p. 87 is withheld in full; the capital cost and 30-year revenue sentences are truncated mid-clause at p. 21, leaving the grammar intact around the removed figures; and the subsection headings of section 7 Economic Case are withheld within the table of contents, together with the title of section 8 and all of its subsections, which appear as bare dot leaders against pp. 40–43 and 44–63. The construction employment sentence at p. 21 is severed in the same way: “an estimated ___ annual equivalent jobs could be created.” That figure — 71,000 to 96,000 annual equivalent — is disclosed in full in the Canada Infrastructure Bank release at note 16. No exemption provisions are marked against any of the severed passages. Both versions held by the Initiative.

18.

Cadence consortium membership and CDPQ Infra’s leadership role: Cadence, “About us,” and CDPQ Infra, “Alto high-speed rail,” both accessed August 2026; consortium announced as preferred private development partner 19 February 2025, co-development agreement signed March 2025. AtkinsRéalis (formerly SNC-Lavalin) was a member of NouvLR, which held the REM engineering, procurement and construction contract, and of the group now operating as Pulsar with Alstom under the rolling stock, systems, operations and maintenance contract. cadence.info

August 21, 2026

It left the rules behind

ALTO Used the Rulebook’s Numbers. It Left the Rules Behind.

ALTO’s new economic report takes two key figures from an Ontario appraisal manual and names that manual as its source. The manual attaches conditions to those figures. The report uses the figures and leaves the conditions out.

ALTO HSR Citizen Research Initiative · Economics Brief · Published August 2026 · Plain-language version of the research brief Two Parameters, None of the Conditions · Companion explainer: Hours Are Not Dollars

⚠ The Document Under Examination

In August 2026 ALTO published Canada’s Moment: The Economic Opportunity of High-Speed Rail, an 83-page report setting out the economic case for the Toronto–Québec City high-speed rail corridor. Its central figure is $49.5 billion in benefits to travellers and society, set against a construction cost of $60 to $90 billion.

To turn sixty years of future benefits into one number in today’s dollars, the report needs two things: a rate at which to shrink future benefits back to present value, and a price for an hour of a traveller’s time. For both, it names one source — a public appraisal manual published by Metrolinx, the Government of Ontario’s transit agency for the Toronto and Hamilton region.

Critical Finding

The Metrolinx manual does not simply publish those two numbers. It publishes them as part of a package. For any project over $500 million, the same manual requires that the numbers be re-tested at different values, that results be reported as a range rather than a single figure, that early-stage construction costs be topped up to correct for known optimism, and that the project’s benefit-to-cost ratio be published. ALTO’s project is roughly a hundred times larger than that threshold.

None of those requirements appears in ALTO’s report. There is no test of the discount rate, no range around the $49.5 billion, no optimism adjustment to the cost, and no benefit-cost ratio. The two numbers were carried across. The conditions attached to them were not.

This brief does not argue that ALTO used the wrong discount rate. The rate it used is a mainstream, defensible choice. The finding is narrower and, we think, harder to answer: the report presents a set of choices as though they were simply facts, and a reader has no way of knowing that anything was chosen at all.

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Why this matters

Imagine a builder quotes you a price for an extension. Asked where the figures come from, they name the standard industry pricing guide. That guide does set those rates. It also says that on a job this size the quote must show a high and a low figure rather than a single number, must add a fixed percentage on top because early quotes are almost always too low, and must set the total against the value of what you are getting.

The builder uses the guide’s rates and does none of the rest. The quote may well be sound. You have no way of telling — and nothing on the page tells you that anything was left out.

That is the situation this brief describes. ALTO’s economic report takes two figures from a public appraisal manual and names that manual as its source. The same manual attaches a set of mandatory checks to those figures for projects of this size. The figures were used. The checks are absent, and their absence is not disclosed.

It matters because of what rests on the result. The $49.5 billion benefit figure is the number now appearing in news coverage and public statements as the reason to build a railway costing $60 to $90 billion of public money, ahead of a federal decision in 2029. Presented as a single figure with no range, it reads as something measured. The report’s own tables call it an upper estimate.

What the report gives you

One benefit figure, $49.5 billion, built on a rate and an hourly value of time presented without explanation of where they came from or what else was possible. No range. No benefit-to-cost ratio.

What its own cited source requires

The same figures re-tested at different values, results published as a range with a confidence level, a 64 per cent top-up on early-stage construction costs, and the benefit-to-cost ratio reported.

What that leaves a reader with

No way to judge how firm the headline number is — and no indication in the document that this is a question worth asking.

One thing this brief does not do: argue that the numbers ALTO chose are wrong, or that high-speed rail is a bad idea. The rate it used is a mainstream choice, and the one test the manual requires would, if anything, make the benefits look larger. The ask is simply that the tests be run and published, as the cited manual says they must be.

The Two Numbers

What the report borrowed, and from where

3.5%

the discount rate ALTO uses, taken from the Metrolinx manual

Appendix A, footnote 65

$22.32

the value of one hour of a traveller’s time, the same figure for every trip

justified as following Metrolinx method

64%

the top-up the same manual requires on construction costs at this stage of design

not applied in the report

The discount rate. A benefit that arrives in 2085 is not worth as much to us today as the same benefit next year. Economists handle this by shrinking future amounts back to a present-day value at a fixed annual percentage — the discount rate. ALTO uses 3.5 per cent a year, applied over a sixty-year period. The rate matters enormously: over sixty years, small changes to it move the headline benefit figure by billions.

The value of time. Most of the $49.5 billion is not cash. It is hours — time that travellers would otherwise have spent on the road or waiting at an airport. To put a dollar figure on those hours, you have to decide what an hour is worth. ALTO uses $22.32, and applies the same figure to every trip: business or holiday, commuter or tourist. The report tells us its own ridership model did separate business from non-business travel, and that this distinction was set aside in favour of one blended figure.

Where both come from. The footnote attached to the discount rate cites one document and one only: the Business Case Manual Volume 2: Guidance, published by Metrolinx in August 2021. The single blended value of time is defended on the grounds that it follows Metrolinx method. So a manual written for regional transit projects in the Toronto and Hamilton area is the published authority for how a national intercity railway has been appraised.

Metrolinx guidance is not binding on a federal Crown corporation, and nothing here suggests otherwise. But a citation carries the terms of the thing cited. If you name a manual as your authority, it is fair to look at what else that manual says on the same page.

The Manual’s Own Terms

The numbers come as a set, not a menu

The 3.5 per cent rate appears in a table of standard parameters. The text introducing that table is direct about their status: any departure from them has to be explicitly agreed during the work, with a clear justification recorded. It is a list of defaults you may leave, provided you say so. Below is how each of those defaults is treated in ALTO’s report.

What the Metrolinx manual specifies	What ALTO’s report does
Discount rate: 3.5 per cent. The rate at which future benefits are shrunk to present value.	3.5 per cent. Adopted exactly as specified, and correctly footnoted to the manual.
Status:Carried across
Value of time: one blended figure. A single hourly value across all modes and all trip purposes, rather than separate values for business and leisure travel.	One blended figure, $22.32. Adopted, and expressly justified by reference to the manual — in preference to the business and non-business split that ALTO’s own ridership model had already produced.
Status:Carried across
Growth cap: stop escalating benefits 30 years out. The manual caps growth in the inputs thirty years after the base year, expressly to reflect the fact that nobody can see that far ahead. User benefits are named as covered by the cap.	Applied to two small lines, not the big one. Accident rates are capped after twenty years, and vehicle emission factors run to 2050. No cap is stated on travel-time benefits — which are 78 per cent of the total.
Status:Applied selectively
One price year throughout. All values discounted and escalated to a single common year, fixed at the start of the study, so that every figure in the document is in the same money.	Two price years in one report. The appraisal and the capital cost are in 2024 dollars; the economy-wide GDP result is in 2019 dollars.
Status:Not consistent
Test the value of time at 0.75 per cent real growth. The manual’s base case assumes the value of an hour does not rise in real terms — but pairs that assumption with a required test of what happens if it does.	Zero growth assumed; no test run. The assumption was carried across. The test that the manual attaches to the assumption was not.
Status:Left behind

One footnote on the money. Adjusting the manual’s 2021 value of time for inflation to 2024 gives roughly $21.40 — within a few per cent of ALTO’s $22.32. We are not claiming ALTO derived its figure that way, and ALTO does not say how it did. The point is simply that the figure sits where you would expect a Metrolinx-derived figure to sit, which makes the omission of the accompanying test harder to explain as an oversight.

The Missing Tests

What a project this size is supposed to publish

The Metrolinx manual scales its requirements to the size of the project. Anything above $500 million is treated as large scale, and a specific list of tests and disclosures becomes mandatory. ALTO’s cost estimate is $60 to $90 billion — roughly a hundred times that threshold. Here is that list, and where each item stands in ALTO’s report.

Re-run the numbers at a different discount rate

The manual requires the calculation be repeated at 2.5 per cent so the reader can see how sensitive the answer is to the rate. Not done, and not mentioned. Note the direction here: the required test is at a lower rate, which would make the benefits look larger. Nothing in the manual supports an argument that ALTO’s rate is too generous. What it supports is the narrower point that the manual’s author expects the rate to be tested and the test to be shown.

Re-run the numbers with a rising value of time

Required at 0.75 per cent real growth per year. Not done.

Run the costs and assumptions through a range analysis

The manual requires costs and modelling assumptions be run thousands of times with the inputs varied, and the result reported as a range with a stated confidence level. Not done.

Report the odds that the project is worth doing

The manual asks specifically for the probability that benefits exceed costs. Not reported — the report publishes no benefit-cost ratio at all.

Publish the standard indicators

Net present value, benefit-cost ratio, capital utilisation, return on investment, internal rate of return. None published.

Model low, medium and high growth scenarios

Required, with the ridership growth rate stated for each. A ridership range is shown; the underlying growth scenarios are not stated.

This is not a theoretical requirement

The manual works the method through on a real example: an extension of the Yonge subway line in Toronto, at an early stage of design. A single cost estimate of $5.65 billion becomes a range of $6.16 to $6.84 billion, with the confidence level attached. The reader is shown a central figure, a spread, and how sure anyone is about it.

That project is roughly one per cent the size of ALTO. On uncertainty, the manual ALTO cites tells its reader more about a subway extension than ALTO’s report tells its reader about a national railway.

The Missing Lower Number

The report concedes a range it never publishes

The two tables carrying the entire $49.5 billion case are both headed with the words upper estimate. Every figure in the narrative is prefixed the same way: up to 24 million riders, up to 9.3 billion hours saved, up to 400 fatalities avoided, up to 39.1 million tonnes of emissions.

An upper estimate is one end of a range. The other end does not appear anywhere in the document.

The claim built on top of those figures goes further still. The report states that the benefits hold across a wide range of scenarios, and repeats the point in its conclusion. But demonstrating that a result holds across a range of scenarios is exactly what the missing sensitivity analysis does, and exactly what the cited manual requires be reported at this scale. The scenarios may well have been run. Their results are not shown.

And the report clearly knows how to show them. Elsewhere in the same document, the ridership forecast comes with multiple scenarios and a published band around it. The economy-wide GDP figure rests on nearly a hundred separate model runs with the assumptions varied. Between a tested input and a tested output sits the largest single number in the report, presented as a single column of point estimates.

The Optimism Adjustment

A top-up the manual requires, and the report does not mention

Early cost estimates for big infrastructure projects are, as a matter of record, too low. Not occasionally — routinely. The Metrolinx manual is explicit about the evidence behind this: in an international sample of 258 rail projects, ninety per cent were undercosted, by an average of forty-five per cent.

The manual’s response is a mandatory top-up applied to the construction cost when it is compared with benefits, over and above whatever contingency is already in the estimate. The size of the top-up depends on how far the design has progressed. At the earliest stage — nought to ten per cent designed — it is 64 per cent.

ALTO’s cost estimate is described in its own report as an AACE Class 5 estimate, which is the earliest and least developed class there is. Applied as the manual directs, a cost of $60 to $90 billion would enter the comparison at roughly $98 to $148 billion, before any comparison with benefits is attempted. That range is our own arithmetic on ALTO’s published estimate at the manual’s stated uplift; ALTO publishes no uplifted figure.

The report applies no such adjustment and does not mention the concept. It is worth noting where this reasoning comes from: the manual grounds the adjustment in the research on transport megaproject cost overruns that this Initiative has drawn on since its first publication. That reasoning is already embedded in the appraisal manual ALTO chose to cite.

The Central Inversion

Too early to divide, but not too early to multiply

The report declines to publish a benefit-cost ratio — benefits divided by costs, the single number a reader would most want. Its stated reason is that the cost estimate is too immature to support one.

Under the framework ALTO cites, that reasoning runs backwards. The manual sets out what is required at each stage of a project’s life. At the earliest stage, the very stage ALTO is at, the requirement is a single line: conduct sensitivity testing to understand the key drivers and the level of uncertainty in each option.

Early-stage uncertainty is not an exemption from testing. It is the reason testing is required. The report treats it the other way round: immaturity on the cost side is given as grounds for publishing nothing, while single-point figures are published on the benefit side of the same ledger. The same uncertainty is treated as decisive for one number and immaterial for the other.

And a business case for this corridor has already done it. In December 2021 the Joint Project Office — VIA Rail and the Canada Infrastructure Bank — published a benefit-cost ratio for High Frequency Rail, the cheaper predecessor to ALTO, at a comparable stage of development: about 0.13, or roughly 0.4 on an expanded basis counting fare revenue and agglomeration as benefits. It published a net present value of minus $21.1 billion and a thirty-year public subsidy of $37.1 to $42.2 billion alongside it. Its economic parameters were drawn from Metrolinx and Ministère des Transports du Québec guidance — the same two sources ALTO cites. Immaturity did not prevent a ratio then. The companion explainer Hours Are Not Dollars sets out those figures in full, including why 0.13 rather than 0.4 is the anchor.

A related point arises elsewhere in the report. In explaining why one set of results is excluded from the welfare account, it refers to those results as therefore not being included in the benefit-cost ratio — speaking of it as a thing with a settled boundary about what enters it. One page says a meaningful ratio cannot yet be produced. Another treats the ratio as already drawn up. The two are difficult to read together, and the report does not reconcile them.

Limits of This Analysis

What this brief does not say

Stated here rather than left for others to find.

On the analysis

The rate is not wrong3.5 per cent is a defensible choice, used by the United Kingdom Treasury and by Metrolinx, and well supported for long-horizon public investment. This brief does not argue that ALTO’s rate is too low or too high.

Metrolinx does not bind ALTOA provincial agency’s manual has no legal force over a federal Crown corporation. The argument is about the coherence of a citation, not about jurisdiction.

One choice runs in ALTO’s favourThe 3.5 per cent rate is applied flat across sixty years. The UK Treasury, whose Social Time Preference Rate this figure matches, steps its rate down to 3.0 per cent after year 30. Applying that schedule would have made ALTO’s benefit total larger, not smaller.

One cited source was not reviewedGuidance from the Ministère des Transports du Québec is cited separately for the value of time. The Initiative has not reviewed it and takes no position on what it requires.

On the report and its source

The report does apply conservatism in placesAccident reductions are capped after twenty years, and car emission factors are assumed to improve to 2050, which the report notes limits the emissions benefit. These are the two smallest monetised lines. No equivalent constraint is disclosed for travel time, which is 78 per cent of the total.

The manual itself is datedMetrolinx said in 2021 that a revised version with updated values would follow in 2022. Five years on, it has not. That is a limitation of the source document, not a fault of ALTO’s — but a reader assessing where a federal appraisal input came from is entitled to know it.

Which figures are whoseEvery figure attributed to ALTO, Metrolinx, the Joint Project Office, HM Treasury or Statistics Canada is quoted from the sources listed below and can be checked there. Three figures are our own arithmetic and are marked as such where they appear: the $98 to $148 billion uplifted capital range, the $21.40 inflation-escalated value of time, and the five per cent effect of the declining Green Book schedule. Where the report does not state something, we say so rather than inferring it, and we make no claim about why any requirement was or was not carried across.

This is a public report, not a formal submissionA business case submitted to Cabinet in 2029 may well contain material this document does not. The claims examined here are the claims ALTO has chosen to put in public.

What Would Settle It

Two questions ALTO can answer without releasing a model

Both are answerable from work ALTO has already done. Neither requires disclosure of a model, cooperation from staff, or agreement about what the correct discount rate for a national railway ought to be.

1. Was the calculation ever run at a rate other than 3.5 per cent?

And if so, what were the results? A negative answer is itself informative — it would mean the required test was never performed. An affirmative answer is the sensitivity table the report does not contain.

2. Which parts of the cited guidance were applied, and which were departed from?

The Metrolinx document requires that any variation from its parameters be agreed and clearly justified. The report records no variations at all — while, on the evidence above, departing from several.

Where Things Stand · August 2026

Summary ledger

Measured against the requirements of the manual ALTO names as its authority:

Carried across

The 3.5 per cent discount rate, correctly cited to the manual.

Carried across

The single blended value of time, expressly justified by reference to the manual.

Partial

The thirty-year cap on benefit growth: applied to accident and emissions lines, not stated for travel time, which is 78 per cent of the benefits.

Partial

A single price year throughout: the appraisal is in 2024 dollars, the GDP result in 2019 dollars.

Left behind

Discount rate sensitivity test at 2.5 per cent.

Left behind

Value of time sensitivity test at 0.75 per cent real growth.

Left behind

Range analysis of costs and assumptions, reported with a confidence level.

Left behind

The probability that benefits exceed costs, and the benefit-cost ratio itself.

Left behind

The standard set of performance indicators: net present value, benefit-cost ratio, capital utilisation, return on investment, internal rate of return.

Left behind

The optimism-bias top-up on construction costs, 64 per cent at this level of design — not applied and not mentioned.

Left behind

The lower end of the range, on figures the report itself labels an upper estimate.

ALTO names an appraisal manual twice — once for its discount rate, once to justify a single blended value of time — and leaves behind the testing, the ranges, the optimism adjustment and the benefit-cost reporting that the same manual attaches to those figures at this project’s scale. What remains is a column of numbers labelled an upper estimate whose lower estimate is never shown, resting on parameters presented as facts rather than as selections, in a report that declines to divide that column by the cost while describing the benefits as holding across a wide range of scenarios.

Every document relied on here is public. Nothing in this analysis requires access to ALTO’s models, cooperation from its staff, or a view on what the correct discount rate for a national railway ought to be.

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If the terms in this brief are unfamiliar — what a discount rate actually does, why a benefit figure is not money, and who ends up paying — the companion explainer Hours Are Not Dollars covers the same ground in plain language, and sets out the 2021 business case figures in full.

Sources

Primary documents

ALTO, Canada’s Moment: The Economic Opportunity of High-Speed Rail, August 2026, 83 pp. Discount rate, appraisal period and price base in the Appendix A methodology box, sourced at footnote 65 to the Metrolinx Business Case Manual Volume 2; value of time and the single-parameter justification in the same appendix, with Ministère des Transports du Québec guidance at footnote 66. Direct-effects tables headed “upper estimate, $2024 CAD”; benefit-cost ratio discussion at p. 62 and reference to the benefit-cost ratio at p. 80; capital cost and AACE Class 5 at pp. 5 and 65; scenario-robustness claims at pp. 3 and 69.

Metrolinx, Business Case Manual Volume 2: Guidance, August 2021, 222 pp. Economic parameters at Table 5.8; sensitivity requirements at Tables 5.1 to 5.3; optimism bias at Tables 5.4 to 5.6; worked range example at Table 5.7; Economic Case lifecycle requirements and key performance indicators; business case principles at pp. 11 and 13; guidance revision cycle at p. 4. metrolinx.com

Metrolinx, “Business Cases — Resources,” accessed 21 August 2026. The Business Case Guidance link resolves to the Volume 2 file under an asset version token corresponding to 15 September 2022; no Volume 2 revision has been issued.

B. Flyvbjerg, Procedures for Dealing with Optimism Bias in Transport Planning (UK Department for Transport, 2004), cited in the Metrolinx Guidance as the basis for the optimism-bias uplift.

Statistics Canada, Table 18-10-0004-01, consumer price index, used for the 2021 to 2024 escalation of the Metrolinx value of time. The comparison is arithmetic and is not an attribution of method.

August 21, 2026

Bound before briefed

City of Kingston: Bound Before Briefed

Britain spent a decade learning what happens when councils sign confidentiality agreements with a high-speed rail promoter. The lessons were on the record. Kingston signed on 10 July, three days before this brief reached councillors.

ALTO HSR Citizen Research Initiative · Governance and Transparency Brief · Published July 2026 · Updated following the July 10 signing

⚠ Update · The agreement has been signed

This brief sets out the questions Kingston City Council should have asked before entering a non-disclosure agreement with ALTO. By the time it reached councillors, on Monday, July 13, the agreement had already been signed — the Whig-Standard reported that the City signed on Friday, July 10, and the signing became public on July 14. Whig-Standard

The document’s title turns out to be literal. Councillors were bound on the Friday and briefed on the Monday — bound by an agreement the City says applies to them personally, three days before the questions below were put in front of them. The brief did not arrive too early to matter. It arrived after the decision it was meant to inform.

Two facts from that reporting change the picture materially. First, a City spokesperson confirmed that the agreement binds city staff and councillors alike — every person who receives technical information from ALTO. Second, asked whether the City had a choice, the same spokesperson said: “This is not optional.”

The analysis below is the brief as sent to councillors, unchanged. The questions it raises were answerable before Friday. That they are printed here after the signing, rather than asked before it, is the point.

Critical Finding

Of the five questions this brief puts to Council, one has already been answered, and answered badly. The agreement binds elected members, not merely officers. A councillor who receives technical information about the corridor cannot discuss it with the constituents whose land that corridor may cross. The remaining four — whether the agreement expires, what precisely it covers, whether MFIPPA and open-meeting obligations are expressly preserved, and what ALTO would actually have withheld without it — remain unanswered on the public record.

A second finding sits underneath the first. ALTO describes these agreements as instruments that enable two-way data sharing and productive collaboration. HS2 Ltd, facing the same criticism in Britain, said its agreements were mutual and entered into by consent. The City of Kingston says the agreement was not optional. A contract that one party had no choice but to sign is not a collaboration. Both characterisations cannot be true, and it is the City — not the critics — that has contradicted the promoter.

Kingston’s neighbours faced the identical request and treated it as a decision. Two eastern Ontario counties have now refused ALTO’s confidentiality agreement outright, both unanimously, both on the public record — the United Counties of Prescott and Russell in May, and the United Counties of Stormont, Dundas and Glengarry on June 15. Frontenac County voted formally on April 15 to oppose the proposed corridors through the county. Whether Kingston’s agreement was ever put to its own elected representatives — by motion, in open or closed session — has not been established on the public record.

The most important fact in this brief is the one that follows from that. SDG refused the agreement and then published ALTO’s presentation to the public. The choice Kingston was offered — sign and be informed, or refuse and be ignorant — is not a real choice. A council next door declined to sign and released the material anyway.

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City of Kingston: Bound Before Briefed — Full Brief (PDF)

The briefing note circulated to Kingston City Council, reproduced as issued, with a dated note recording that the agreement was signed before it arrived. Ten-minute read.

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What was signed

“This is not optional”

The agreement was executed on Friday, July 10, between the City of Kingston and ALTO, the Crown corporation developing the corridor. ALTO’s account of why is straightforward and, in its own terms, reasonable: planning work is not final; early concepts, technical analysis and emerging ideas are still being refined; and sharing preliminary material without its full context could give the impression that decisions have already been made. Confidentiality agreements, the corporation says, are used widely in the infrastructure industry and structure these discussions so that evolving information can be shared. Whig-Standard

The Mayor’s defence follows the same line. Such agreements are common in major infrastructure planning; they allow technical information to be shared so that municipalities can provide informed input; the agreement is not an endorsement of any particular route or station location; and the City remains committed to transparency and will share information publicly when it is able to.

Set against that framing, the City spokesperson’s own words do a great deal of work. The agreement applies to all city staff and councillors who receive technical information from ALTO. It was required in order for the City to receive any technical information at all. And it was not optional.

A confidentiality agreement that one party had no choice but to sign is not a collaboration. It is a condition of entry.

This is the distinction the British record turns on, and it is worth being precise about it. The objection is not that confidential material was shared confidentially. It is that information was withheld until silence was promised — that access to the facts was made conditional on a commitment not to use them. That is not a description of HS2. It is now, on the City’s own account, a description of Kingston.

Part One · The mechanism

Access conditioned on silence

In Britain, councils were not handed material and then asked to protect the commercially sensitive parts of it. They were told they could see nothing at all unless they signed first. Many were required to sign before they could engage with HS2 Ltd on the questions that mattered most locally — where stations might go, how they would be designed, and which route the promoter preferred. Warwickshire County Council could not receive early design updates until it had signed. New Civil Engineer Warwickshire World

A council’s capacity to scrutinise the promoter is made conditional on a promise not to tell the people it represents what that scrutiny has revealed.

The council does not become better informed in any way it can act upon. It becomes better informed and simultaneously disabled from using the information in the one forum where a council is supposed to act: in public, on the record, in front of the residents whose homes and farms lie in the corridor.

That is the general case. In Kingston it now has a specific and uncomfortable form. Because the agreement binds councillors rather than officers alone, a member of Council who is briefed on the alignment cannot discuss what they have learned with the constituent whose property it crosses. The representative becomes an insider. Whatever else the agreement achieves, it removes from thirteen elected people the ability to do the thing they were elected to do.

Part Two · The scale, and the creep

Four agreements became three hundred and thirty-nine

Freedom of Information disclosures eventually forced HS2 Ltd to reveal how far the practice had spread. The progression was four agreements in 2012–13, ten in 2014, twenty-seven in 2015, thirty-four in 2016, seventy-one in 2017, and one hundred and twelve in 2018. New Civil Engineer

confidentiality agreements signed in 2012–13, at the outset

HS2 Ltd, via FOI

112

signed in 2018 alone, as the practice took hold

HS2 Ltd, via FOI

339

bodies bound, by the figure cited in the House of Lords

Hansard

HS2 Ltd then resisted disclosing who had signed for eighteen months, releasing the list of 253 organisations only after the Information Commissioner intervened. A further thirty-eight agreements with individuals were never named. By the end, the signatories included dozens of councils, the Health and Safety Executive, the National Trust, Historic England, and five universities.

The circle of people who could speak freely about a public project — funded by the public, running through the public’s communities — had been drawn so tightly that supporters of the scheme in the House of Lords questioned why so many organisations needed to be bound at all.

The creep has already begun here

Reporting on the Prescott and Russell decision confirms that ALTO requires every landholder who permits field survey access to sign a non-disclosure agreement, not only municipalities. The first agreement is never the last. It establishes the template, the precedent, and the expectation — for this municipality, for the next one down the corridor, for landowners, consultants and agencies, and for every subsequent phase of the project. Tribune-Express

Part Three · The terms

Twenty-six of twenty-eight had no end date

Of the twenty-eight English local authorities identified, the Town and Country Planning Association found that twenty-six had agreements with no end date. New Civil Engineer

No sunset clause. No automatic release on publication of the environmental assessment. No expiry when the route was confirmed and the commercial sensitivity had evaporated. Silence in perpetuity, over material that in most cases became public anyway — simply later, and on the promoter’s timetable rather than the community’s.

This is the single most consequential drafting failure in the entire British record, and it is also the easiest to prevent. An officer negotiating in good faith, focused on getting the data flowing, will not necessarily notice that the agreement never expires. Whether Kingston’s agreement contains an expiry date is not, at the time of writing, on the public record. It is a one-word answer, and the City can give it today.

Part Four · Both sides, fairly stated

The promoter’s case, and what the record shows

Nothing in this brief argues that no confidentiality is ever warranted. The argument is narrower: the terms matter enormously, the English terms were bad, and they were bad in ways that were entirely avoidable if identified in advance.

What the promoter says	What the British record shows
The agreements are mutual and entered into by consent. ALTO describes instruments that enable two-way data sharing and support productive collaboration on planning.	The City of Kingston’s own spokesperson says the agreement was not optional and was required to receive any technical information at all. HS2 Ltd made the identical “mutual and consensual” claim about agreements that councils could not decline without being cut off.
Confidentiality protects residents from unnecessary blight and confusion. Sharing early information without full context could suggest decisions have been made.	Note the shape of the argument: the secrecy is offered as a protection for the affected. It is worth asking whether residents in the corridor, given the choice, would prefer to be protected from knowing. In Britain, the discovery of the agreements produced anger, not relief.
These agreements are common in major infrastructure. They allow municipalities to give informed input.	They are common. That is the finding, not the defence. The Raynsford Review examined precisely this common practice and concluded that it corroded public trust in the project it was meant to protect.
The agreement is not an endorsement of any route or station. The City will share information publicly when it is able to.	“When we are able to” is the operative phrase, and its meaning is set by a document the public has not seen. If the agreement has no expiry, the answer is: at the promoter’s discretion, indefinitely.

The most honest defence of signing came, in Britain, from Doncaster. The council signed because it relied on HS2’s data to scrutinise and challenge the design; without signing, exposing the route’s damaging effects would have been harder still and might have produced more blight rather than less. Doncaster Free Press That is not a foolish argument, and it should not be caricatured. It is the argument of a body that has accepted the promoter’s framing of the available choices — sign and be informed, or refuse and be ignorant. Whether that framing was tested is not something the public record shows.

Prescott and Russell tested it. So did Stormont, Dundas and Glengarry. Both refused — and neither is, on the available evidence, less informed about ALTO than Kingston is. One of them has published the promoter’s presentation. Kingston cannot.

Part Five · The independent verdicts

What Britain concluded, in public, before Kingston signed

The Raynsford Review (Town and Country Planning Association, 2018)

Led by a former construction minister, this review of the English planning system found that the agreements undermine public trust in major infrastructure. It criticised the widespread use of confidentiality agreements by the HS2 company and identified a corrosive public sense that planning no longer protects people’s interests. It found that the agreements created real anger among local politicians and deeper resentment in affected communities once their existence came to light.

Raynsford’s line — the most useful distinction in the literature

Raynsford did not oppose confidentiality as such. He accepted the case for it where competing route options are under assessment and public knowledge could inflate land prices — and opposed it where it undermines public trust or may shield inappropriate relationships between developers and those making decisions. The test is not whether confidentiality is ever justified. It is whether this confidentiality, on these terms, for this long, is.

The House of Lords — criticism from the project’s own supporters

Baroness Kramer, a consistent advocate of HS2, argued that the presumption must always be transparency, with confidentiality as the exception, and that the slow release of information on cost, land and compensation had harmed the project and generated suspicion. Lord Berkeley proposed an independent assessor to review every HS2 confidentiality agreement against a presumption of public accountability. The people who most wanted HS2 built were among the loudest voices warning that the secrecy was destroying its public licence.

The culture did not stay in its lane

HS2 Ltd paid roughly £1.67 million in settlement agreements to forty-eight former employees from April 2016, with confidentiality clauses written in; a number of whistleblowers were among them. The company also redacted the names of attendees from its board minutes, against the Information Commissioner’s stated presumption in favour of naming those acting in a professional capacity. In the English record, confidentiality practice did not stay confined to route data. New Civil Engineer

Part Six · The neighbours

The same request, refused twice next door

ALTO has made materially the same approach to municipalities across the corridor: access to technical material, in exchange for a confidentiality agreement, plus permission to enter municipal land for field survey. What distinguishes Kingston is not the request. It is the response, and the process by which the response was reached.

United Counties of Prescott and Russell — refused, May 2026

All eight mayors on the UCPR council voted against a resolution that would have granted ALTO access to counties’ land for survey work and committed the Counties to a non-disclosure agreement. Each mayor declared their position on a registered vote. Warden Mario Zanth, mayor of Clarence-Rockland, directed the CAO to inform ALTO that the council did not want the corporation on its territory, having refused both the confidentiality agreement and land access. Zanth’s stated objection was that the corporation demanded secrecy before it would disclose the technical details municipalities were asking about — the chemistry of de-icing fluids and the risk to wells, the electricity supply, and other questions of direct local consequence. Tribune-Express ONFR

United Counties of Stormont, Dundas and Glengarry — refused, June 15, 2026

SDG Counties Council unanimously rejected both ALTO’s request to access counties-owned land for environmental and technical study and its request that SDG sign a non-disclosure agreement — an agreement that would have prohibited councillors and staff from discussing with the public any details of their meetings and communications with the corporation. Council was given three options: full access, partial access, or none. It chose none, without further debate. North Glengarry Mayor Jamie MacDonald grounded his objection in accountability, saying of the agreement: “Here they’re telling us we can’t share any information in them.” The Review

Frontenac County — a formal, public vote on the corridor, April 15, 2026

Frontenac County Council formally voted to oppose the proposed high-speed rail corridors through the county, favouring routes along existing rail lines or the Highway 401 corridor. The resolution cited disruption to residential areas, agricultural lands and environmentally sensitive features; impacts on municipal infrastructure including road closures; risks to emergency response times; and uncertainty about the long-term financial implications for municipalities. Council supported a Kingston stop and called for no expropriation west of Ottawa until the Ottawa–Montreal segment nears completion. County of Frontenac

City of Kingston — signed July 10; the authorising process is not on the public record

Whether the agreement was authorised by a motion of Council — in open session, or in closed session with a reporting-out resolution — or executed by staff under delegated signing authority without coming to Council at all, has not been established. The distinction is not academic. An agreement authorised by a recorded vote is a decision residents can argue with. One signed under delegated authority means the City bound itself, and its councillors, on a matter of plain public interest without the body accountable for that interest ever recording a view.

The choice Kingston was offered is not a real choice

The case for signing rests entirely on a premise: that a council which refuses the agreement is left in the dark. The City spokesperson put it plainly — the agreement was required in order to receive any technical information at all, and it was not optional.

That premise has been tested next door, and it failed. SDG refused the agreement, refused land access, and then shared ALTO’s presentation with the public. From that published material, residents of SDG can now learn what ALTO intends: that field sampling across the corridor is scheduled for the fourth quarter of 2026 and will feed the impact assessment; that the surveys cover wetlands, forests, avian wildlife, and fish and wildlife habitat; that archaeology, cultural heritage, and “sensitive receptors” such as parks, schools and hospitals are treated as socio-economic components; and that noise, vibration, hydrogeology, soil quality and surface water are the physical components under examination. The Review

A council that refused to sign has told its residents more about ALTO’s plans than a council that signed is now permitted to.

This is not a rhetorical point. It is the whole argument, and it can be verified by anyone with a browser. The bargain Kingston accepted — silence in exchange for information — was offered on the premise that there was no alternative. Two neighbouring counties declined it, and one of them proceeded to put the promoter’s own material on the public record. The alternative existed. Kingston did not take it, and has not explained why.

One further detail of timing deserves an answer. The Eastern Ontario Wardens’ Caucus — the body through which these counties have been coordinating their response — was scheduled to discuss ALTO at a meeting in Kingston, in July. Kingston signed on July 10.

The Initiative has written to Kingston city councillors asking a single question, answerable in one sentence: was the agreement authorised by resolution of Council, and if so, what is the resolution number and date — or was it executed under delegated authority, and under which by-law? We will publish the answer when we receive it, whatever it is.

Part Seven · Where things stand

Five questions, one answered

These are the five questions the brief puts to Council. None is hostile. Each was answerable by staff in a sentence — before Friday. This is their status as of publication.

Answered

Who is bound — officers, or members? Both. The City confirms the agreement applies to all staff and councillors who receive technical information. This is the outcome the brief identifies as the most serious: an agreement that binds elected members converts representatives into insiders.

Unanswered

Does it expire? No sunset date has been disclosed. Twenty-six of the twenty-eight English councils signed agreements with no end date at all.

Unanswered

What, exactly, is covered? Whether the agreement is confined to genuinely commercial and personal information, or reaches route alignment, station siting, cost and community impact, has not been disclosed.

Unanswered

Are the statutory carve-outs express? Whether the agreement expressly preserves the City’s obligations under MFIPPA and the open-meeting provisions of the Municipal Act has not been disclosed. A municipality cannot lawfully contract out of those duties — but a poorly drafted agreement can create a chilling effect that operates as though it had.

Unanswered

What was actually being withheld without it? ALTO is a federal entity subject to the Access to Information Act. If the material behind the agreement is disclosable in due course regardless, the agreement is not buying confidentiality. It is buying delay.

Outstanding

How many of these has ALTO already signed? With municipalities, agencies, consultants and landowners — and on what terms? In Britain, that number was the story. It went from four to more than three hundred while nobody was counting.

Every question above can be answered without disclosing a single confidential fact. The terms of an agreement are not the contents of an agreement.

This is the point on which the whole matter turns, and it is worth stating without heat. Publishing the agreement — its duration, its scope, whom it binds, what it carves out — discloses nothing ALTO has a legitimate interest in protecting. It reveals no alignment, no cost, no property. A city genuinely committed to transparency, and unable to say more about the substance, can nonetheless say everything about the instrument. That it has not yet done so is a choice, and it is a choice the City can reverse this week.

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City of Kingston: Bound Before Briefed (PDF)

The briefing note as circulated to Kingston City Council — the full British record, the Ontario statutory overlay and the five questions in their original form, prefaced by a dated note on the 10 July signing

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The English record

The confidentiality did not protect HS2

Refusal was never the only alternative to signature, and this brief did not urge it. An agreement that would survive scrutiny is time-limited — expiring on a defined public milestone; scope-limited — confined to genuinely commercial and personal information, with alignment, cost and impact data expressly excluded; statute-preserving — with explicit carve-outs for MFIPPA and open-meeting duties; officer-bound, not member-bound; and publicly disclosed — the agreement itself, if not its contents, placed on the public record.

Every one of those five terms exists because HS2 lacked it. None of them costs the promoter anything to which it is entitled. Four of the five can still be secured by amendment, and the fifth — publication of the instrument — requires nothing from ALTO at all.

The English record offers one final observation, and it is not a partisan one. The confidentiality did not protect the project. It corroded HS2’s public licence, hardened the opposition, and left even the scheme’s allies defending a company against the impression that it had something to conceal. Kingston has signed. It has not yet explained. Those are different things, and only one of them is now beyond recall.

How to read this brief

Every figure and finding about HS2 is quoted from the sources listed below and can be checked there: the yearly counts of confidentiality agreements, the 253 organisations named after the Information Commissioner intervened, the 26 of 28 English councils with no end date, the settlement figures, and the Raynsford Review and House of Lords findings. The Kingston facts — the 10 July signing, that the agreement binds councillors as well as staff, and the City’s statement that it was not optional — are as reported by the Whig-Standard.

The statutory points about MFIPPA, the Municipal Act and the Access to Information Act are research, not legal advice, and are offered as questions for the City Solicitor rather than as conclusions. Where something has not been published or answered, this brief says so rather than inferring it, and makes no claim about anyone’s motives in signing.

Sources

Primary documents and reporting

Elliot Ferguson, “Kingston signs non-disclosure agreement for high-speed rail talks,” The Kingston Whig-Standard, July 14, 2026. thewhig.com

“UCPR denies ALTO access to lands, rejects request for NDA,” Tribune-Express, reporting the United Counties of Prescott and Russell council session of May 27, 2026. tribune-express.ca

“TGV : Prescott-Russell bloque Alto et refuse de signer une entente de confidentialité,” ONFR / TFO, May 2026 — carries Warden Mario Zanth’s directive to the CAO and his stated reasons. onfr.tfo.org

James Morgan, “SDG Council rejects Alto request for land access and NDA,” The Review, June 23, 2026 — reporting the unanimous SDG Counties Council decision of June 15, the terms of the proposed agreement, and the public release of ALTO’s presentation. thereview.ca

County of Frontenac, “Council votes to oppose Alto routes through Frontenac County,” April 15, 2026. frontenaccounty.ca

“Exclusive: HS2 ramps up use of gagging orders,” New Civil Engineer, July 1, 2019 — the year-by-year progression of agreements and the TCPA finding that 26 of 28 local authority agreements had no end date. newcivilengineer.com

“Revealed: the 253 companies and public bodies to sign HS2 gagging orders,” New Civil Engineer, November 16, 2020 — the signatory list released after the Information Commissioner’s intervention. newcivilengineer.com

“Exclusive: HS2 paid £1.67m to silence ex-employees,” New Civil Engineer, October 14, 2019. newcivilengineer.com

Nick Raynsford, Planning 2020: Final Report of the Raynsford Review of Planning in England, Town and Country Planning Association, November 2018. Reported context on the HS2 confidentiality agreements: Warwickshire World

10.

Christian Wolmar, “HS2 likes to keep things secret,” December 2020 — carries the Raynsford distinction between legitimate and illegitimate confidentiality, and the board-minute redactions. christianwolmar.co.uk

11.

House of Lords debate on HS2 confidentiality agreements — contributions of Baroness Kramer and Lord Berkeley, Hansard. Hansard record

12.

“Doncaster Council signed non-disclosure agreement with HS2 bosses,” Doncaster Free Press — the fullest published statement of a council’s reasons for signing. doncasterfreepress.co.uk

13.

Municipal Freedom of Information and Protection of Privacy Act, R.S.O. 1990, c. M.56; Municipal Act, 2001, S.O. 2001, c. 25, s. 239 (open meetings); Access to Information Act, R.S.C. 1985, c. A-1. Statutory points in this brief are offered as questions for the City Solicitor, not as legal conclusions.

July 14, 2026

Winter, Ice and the Weather Envelope

ALTO HSR Citizen Research · Technical Brief

Wind, Ice & the Weather Envelope

Winter snow is not the only weather that shapes a high-speed railway. The faster a line is built to run, the more it must spend to stay reliable when the weather turns — and the government’s own record shows this question was raised, and left unanswered.

ALTO HSR Citizen Research Initiative · Technical Brief · Updated July 2026

⚠ On the record: the speed-in-winter question was answered in 2020

An October 2020 Ministerial Briefing, released under the Access to Information Act, found that the government’s advisers could not identify any high-speed rail system that operates at 300 km/h in −30 °C conditions. The only cold-climate comparator they identified — China’s Harbin–Dalian line — reduces speed from 350 km/h to 250 km/h in winter. The finding was briefed to ministers more than four years before the project was announced. ATIA A-2024-004

In June 2026, the tabled government answer to a Parliamentary question on winter-weather readiness confirmed that, “at this point in the design process,” Alto has not commissioned a comparative freezing-rain, snow, or ice assessment, nor a full winter-weather cost analysis, and that its freezing-rain reliability targets are “currently in development.” Sessional Paper 8555-451-1191

Why this brief

High-speed rail runs successfully in some of the world’s harshest weather — but never for free, and never without operating rules that slow or stop trains when conditions demand it. Every mature operator lives inside a “weather envelope”: the range of conditions in which full-speed service is safe. Crosswinds, tornadoes, freezing rain, and heat all sit at its edges.

Because wind forces grow with the square of speed, and because cold, ice, and heat mitigation all cost more the faster and longer the line, the decisive question is not whether high-speed rail can run here. It is how fast the line should be designed to run, and whether the weather-hardening that speed requires has been counted. This brief draws on published engineering research, the operating experience of networks in Japan, China, and Europe, and the project’s own record released under the Access to Information Act. It is not an argument against high-speed rail.

300 km/h

the speed Alto advertises — “even in winter”

Alto promotion, Feb 2026

250 km/h

winter speed of the only cold-climate HSR comparator identified (Harbin–Dalian)

Ministerial Briefing, Oct 2020

2020

the year the government’s advisers flagged the 300 km/h cold-weather limit — over four years before the project was announced

Ministerial Briefing, Oct 2020

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Weather & the Speed Decision (PDF)

Crosswind, tornado, and freezing-rain reliability analysis, with the documented record

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On the Record

The question was examined internally — and never reconciled in public

This is not only an inference from international experience. Documents released under the Access to Information Act show the federal government examined exactly this question years before the project was announced — and in June 2026 the government confirmed to Parliament that Alto has not yet commissioned either a comparative winter-weather assessment or a full winter-weather cost analysis.

What is advertised	What the record shows
“300 km/h or more. Even in winter.” Alto’s public promotion assumes consistent 300 km/h running, and the advertised journey times depend on it.	The October 2020 Ministerial Briefing found no HSR system was identified that operates at 300 km/h in −30 °C. The only cold-climate comparator, Harbin–Dalian, reduces 350 → 250 km/h in winter.
Reliability is “designed into every kilometre,” with “heated switches to de-icing systems.”	The June 2026 answer confirms that, “at this point in the design process,” Alto has not commissioned a comparative freezing-rain / snow / ice assessment or a full winter-weather cost analysis; reliability targets for freezing-rain conditions are “currently in development.”
A 300 km/h specification is presented as the project’s baseline.	The May 2025 Corporate Plan contains no cold-climate operating standard, and the 2020 finding has never been publicly addressed.

Two further items on the record bear directly on the speed choice. First, the procurement was structured as a speed comparison: each of the three bidders was required to submit both an enhanced-conventional option (up to 200 km/h) and a high-speed option (300+ km/h). A slower, cheaper design was therefore a live, formally-evaluated alternative — not a hypothetical. Second, the 2011 EcoTrain feasibility study of a Windsor–Quebec City high-speed service concluded that the full Québec City–Windsor corridor would not be financially viable on a standalone commercial basis and would require substantial public funding — though it found the Montréal–Ottawa–Toronto segment could generate net economic benefit. When a corridor’s commercial case is that fragile, avoidable cost — including over-specifying speed and the weather-hardening it demands — matters more, not less.

Why this matters for speed and cost

The gap is now a matter of record. The government’s own briefing established that 300 km/h has not been demonstrated in extreme cold, and that the nearest cold-climate line runs slower in winter — yet the advertised journey times assume full speed year-round, and Alto has confirmed it has not commissioned the comparative assessment or full winter-weather cost analysis that would test the assumption. A lower-speed option was on the table and formally costed. That is precisely the speed-and-cost question this brief is about, and it remains open.

Wind & Crosswind

The everyday wind risk is overturning — and it scales with speed

For a high-speed train, the routine wind hazard is not a dramatic storm but a strong steady crosswind catching the train side-on. Aerodynamic side and lift forces rise with the square of the combined train-and-wind speed, so a lighter modern trainset at line speed becomes sensitive to winds that would barely trouble a slower, heavier train. The failure mode that governs design is overturning, not wheel-climb derailment.

The threshold is closer than it looks

In one published dynamic simulation, a high-speed vehicle running at 300 km/h overturned when the crosswind reached roughly 24 m/s (about 86 km/h) — a strong gale, but far short of tornado strength. Chinese railway practice treats an overturning coefficient above 0.8 as the danger threshold, and the overturning coefficient in these conditions typically runs about twice the derailment coefficient. Crosswind-induced overturning has been blamed for derailments in China, Japan, Belgium, and Switzerland.

The speed lever

Because the force grows with the square of speed, a line designed for 300 km/h is markedly more wind-sensitive than one designed for, say, 250. A higher design speed means the safe crosswind threshold is crossed more often — so a faster line needs more wind fencing, more sensor coverage, and lives with more frequent speed restrictions. Exposure is also geometry: viaducts and high embankments are the danger zones, cuttings and tunnels are sheltered, and running fast across open, elevated country is the most demanding combination of all.

The mitigation is well proven — anemometer networks feeding automatic speed control, backed by physical wind barriers on exposed stretches. After a December 2005 derailment on the Uetsu Line, Japan’s JR East revised wind-based speed limits system-wide and installed windbreak fences and a strong-wind warning system; porous barriers can cut a train’s crosswind response by around a quarter. China’s Lanzhou–Xinjiang line runs long wind-fenced sections through the Gobi’s windy zones. None of it is free, and the bill rises with the speed being protected.

Tornadoes

Rare, extreme, and hard to see coming

Tornadoes break the crosswind playbook, and it is worth being precise about why: they are managed by avoidance, not by building a train that can survive one. An EF2 tornado carries winds well above 180 km/h and EF3 higher still — far beyond the ~85–100 km/h band where overturning becomes likely. No practical trainset or wind fence keeps a train upright through a direct strike at speed.

Detection is the hard part

Fixed anemometer grids are calibrated for the prevailing winds that blow along the line. A tornado is a narrow, fast-moving, erratic feature that a line-side sensor network may never register before a train is in it — the opposite of the seismic case, where Japan’s earthquake system gets seconds of warning and automatically cuts power and brakes. Even a near miss throws trees and debris onto the alignment.

The corridor sits in Canada’s tornado belt

Most Ontario tornadoes are concentrated in a narrow corridor from Windsor to Ottawa and into parts of southern Quebec — the geography the proposed line traverses. Tornadoes up to F4 have been documented in the region; the 2018 National Capital outbreak produced a high-end EF3, and Canada records an estimated 230 tornadoes a year. The mainstream response is warning-triggered service suspension — hold the trains — not survivability engineering.

In proportion, the tornado question is a genuine but low-frequency tail risk managed through hold procedures — the more dramatic hazard, but the smaller line item. Routine crosswind exposure, which shows up as everyday speed restrictions, is the larger and more quantifiable one.

Freezing Rain

Freezing rain is an electrical problem as much as a track problem

Snow can be ploughed and blown clear. Freezing rain cannot — and its most serious target on an electrified line is not the rail but the overhead wire, the single power path for the whole train. Ice on the contact wire degrades the pantograph’s ability to collect current; it can flash over insulators, set the wire into large-amplitude “galloping” oscillations, and cause arcing — in severe cases, disconnection. Freezing rain is a recognised cause of equipment malfunction and delay wherever winters hover near 0 °C — precisely the St. Lawrence Valley profile documented in our Winter Weather analysis.

The mitigation is real, proven, and continuous — which is another way of saying it is a permanent cost line. France’s SNCF illustrates the toolkit: electric switch heaters, resistive heating circuits that keep catenary above freezing, a fleet of de-icing “scraper” locomotives, and a hydrophobic anti-icing lubricant on the contact wire. China’s purpose-built cold line pairs catenary de-icing with turnout snow-melting and a dedicated snow-and-ice monitoring system. Freezing rain is beaten by equipment plus surveillance plus standing procedures — all carrying capital and maintenance cost that scales with the length of exposed line.

And a second question: which de-icing method?

Mitigating ice raises a choice with its own consequences. Alto’s own winter-operations material lists chemical de-icing using “glycol- or saline-based solutions,” while its June 2026 Parliamentary answer instead illustrates winter mitigation with electric methods — ice-breaking equipment and running high current through the catenary to melt ice. Glycol and chloride de-icers carry serious environmental constraints over the Frontenac Arch and Napanee karst, where contaminants can reach the aquifer before any collection point exists.

As our De-Icing analysis sets out, that pushes the corridor toward electric heating as the primary de-icing technology on sensitive sections — effective, but a permanent energy and cost load. The freezing-rain problem and the environmental problem point at the same answer, and the same bill.

Heat & Water

The other ends of the envelope

Summer heat and rail buckling

Continuously welded rail expands in extreme heat and can buckle (“sun kink”). Operators manage this with real-time rail-temperature monitoring, heat-related speed-limit orders, and — in some networks — spraying track with water. A corridor with a >70 °C annual temperature swing, like the cold-climate reference lines, must design for both extremes at once.

Heavy rain and flooding

Intense rainfall drives washouts, embankment and slope failure, and landslides — which is why high-speed operators monitor rainfall and river levels alongside wind, and impose speed controls or shutdowns when thresholds are crossed.

What It Costs

Weather-proof is achievable — the reference projects show the price tag

The strongest evidence that severe-weather high-speed rail works is also the strongest evidence that it is expensive and route-specific. Two reference cases are instructive.

China · Harbin–Dalian	Japan · Shinkansen
The world’s first alpine high-speed line runs through a −40 °C to +40 °C range. To beat frost heave, 70% of the line was built on viaduct and about 20% of the at-grade track was rebuilt before opening. Final cost ran roughly 25% over budget. It historically dropped to 250 km/h in winter and, even after resolving frost heave, runs a unified 300 km/h year-round — still below its 350 km/h design speed.	Snow-related cancellations were cut from a 1976 peak of 635 to essentially zero since 1994 — but only through sprinkler systems, slab track, snow-removal teams, and undercarriage sensors, and delays of 10–20 minutes still occur in snow. A high-speed train has derailed in blizzard conditions (Akita, 2013, no injuries). Reliability is engineered; it is not free.

China · Harbin–Dalian

Japan · Shinkansen

The world’s first alpine high-speed line runs through a −40 °C to +40 °C range. To beat frost heave, 70% of the line was built on viaduct and about 20% of the at-grade track was rebuilt before opening. Final cost ran roughly 25% over budget. It historically dropped to 250 km/h in winter and, even after resolving frost heave, runs a unified 300 km/h year-round — still below its 350 km/h design speed.

Snow-related cancellations were cut from a 1976 peak of 635 to essentially zero since 1994 — but only through sprinkler systems, slab track, snow-removal teams, and undercarriage sensors, and delays of 10–20 minutes still occur in snow. A high-speed train has derailed in blizzard conditions (Akita, 2013, no injuries). Reliability is engineered; it is not free.

The lesson is not that weather makes high-speed rail impossible — it plainly does not. It is that weather resilience is a design choice priced in both dollars and speed: a purpose-built cold line still ran over budget, and still ran slower in winter until the problems were solved. The faster the promised service, the steeper both penalties climb. That is why weather belongs inside the speed-and-cost decision, and why those figures should be visible in a public business case.

And the cost-risk itself is unquantified

The un-commissioned winter-weather cost analysis sits inside a capital estimate the government describes as preliminary. Asked in June 2026 for its estimate of the risk of Alto exceeding $90 billion, the government replied that it has no quantitative estimate of that likelihood, or of any overrun amount, because the cited $60–90 billion is “a preliminary, high-level planning range and not a final project budget.” Un-costed weather-hardening therefore sits within a capital range whose own overrun risk has not been quantified.

Where things stand · July 2026

The winter-weather accountability ledger

Measured against what a defensible 300 km/h “even in winter” claim would require:

Not shown

A precedent for 300 km/h operation in extreme cold. The government’s own advisers could not identify one in October 2020; the nearest comparator reduces to 250 km/h in winter.

Not commissioned

A comparative freezing-rain / snow / ice assessment. Alto states it has not commissioned one “at this point in the design process.”

Not commissioned

A full winter-weather cost analysis. Alto states it has not commissioned one; winter costs are to be folded into operating-cost estimates instead.

Absent

A cold-climate operating standard. The May 2025 Corporate Plan contains none.

In development

Freezing-rain reliability targets. Stated to be still in development.

On record

A lower-speed alternative. The procurement required an enhanced-conventional (up to 200 km/h) option alongside the high-speed one — a slower, cheaper design was formally evaluated.

Questions for the process

What design speed is being committed to, and how much of the capital cost is weather-hardening for that speed — wind fencing, catenary de-icing, switch and pantograph heating?

What weather-related speed-restriction and service-suspension frequency sits behind the advertised journey times — would passengers actually see 300 km/h as often as promised?

Given that a lower-speed option was formally evaluated, has the speed-versus-weather-cost trade-off been quantified and published — and why was the higher speed chosen?

Since the comparative winter-weather assessment and full cost analysis have not yet been commissioned, when will they be undertaken and published — and will that happen before design speed and cost decisions are locked in?

Have the severe-weather cost overruns seen on comparable projects (Harbin–Dalian, ~25% over budget) been reflected in contingency and risk provisions?

Sources

Primary documents and research

1.Ministerial Briefing to the responsible Ministers, October 2020 — cold-climate high-speed rail operating limits (“unable to identify an HSR system that operates at 300 km/h in −30 °C”; Harbin–Dalian 350 → 250 km/h in winter). Released under the Access to Information Act, file ATIA A-2024-004 (Canada Infrastructure Bank release, November 2025).

2.Written reply to a Parliamentary question on the HFR-to-HSR shift and winter-weather readiness, House of Commons Sessional Paper 8555-451-1191 (asked by Scott Reid, Lanark–Frontenac; tabled June 17, 2026). Alto has not commissioned a comparative freezing-rain / snow / ice assessment (n) or a full winter-weather cost analysis (p) “at this point in the design process”; freezing-rain reliability targets “currently in development” (o); enhanced-conventional (up to 200 km/h) vs high-speed (300+ km/h) bid structure (a); 2011 EcoTrain finding (h); $60–90B vs $45–75B Class 5 cost ranges (i, j); no quantitative estimate of the risk of exceeding $90B (k). ourcommons.ca

3.EcoTrain consortium, Updated Feasibility Study of a High Speed Rail Service in the Quebec City–Windsor Corridor — Final Report (2011) — full corridor not financially viable on a standalone commercial basis, requiring substantial public funding; Montréal–Ottawa–Toronto segment could generate net economic benefit. citizenresearch.ca (PDF)

4.Zhu, L. et al. “Study on the safety of operating high-speed railway vehicles subjected to crosswinds.” Journal of Zhejiang University-SCIENCE A. jzus.zju.edu.cn

5.“Effect of the wind speed on aerodynamic behaviours during the acceleration of a high-speed train under crosswinds.” J. Wind Engineering & Industrial Aerodynamics (2023). sciencedirect.com

6.“Crosswind Stability of High-Speed Train in Unsteady Wind Conditions.” IntechOpen (2025). intechopen.com

7.“Mitigating crosswind response of a high-speed train passing the end of windbreak walls.” ScienceDirect (2024). sciencedirect.com

8.JR East. “Measures to Reduce Service Disruptions when Restrictions are in Force due to Strong Winds” (2006), re: 25 Dec 2005 Uetsu Line derailment. jreast.co.jp

9.Wikipedia. “Tornado Alley” (Windsor–Ottawa corridor; 2018 National Capital outbreak). en.wikipedia.org

10.Global News. “Ontario is now Canada’s tornado hot spot” (2024). globalnews.ca

11.Wikipedia. “List of tornadoes by province (Canada)” (~230/year estimated). en.wikipedia.org

12.“Electrical-thermal conduction and distribution characteristics of the catenary system … electrothermal ice-melting.” Applied Thermal Engineering (2025). sciencedirect.com

13.“Numerical Simulation … Ice Formation on Electrified Railway Contact Lines.” Infrastructures (MDPI, 2025). mdpi.com

14.Nilsson, F. et al. “Modelling anti-icing of railway overhead catenary wires by resistive heating.” Int. J. Heat and Mass Transfer (2019) — icing types; SNCF thermal ice-prevention. sciencedirect.com

15.SNCF Group. “Protecting the network and trains from extreme cold” (switch heaters, catenary heating, de-icing scrapers, anti-icing lubricant). groupe-sncf.com

16.Wikipedia. “Harbin–Dalian high-speed railway” (frost heave; 70% viaduct; alpine EMUs; 25% over budget). en.wikipedia.org

17.Global Times. “China’s first high-speed railway built for extreme cold … 1 billion passenger trips” (2025) — turnout heating, unified year-round timetable. globaltimes.cn

18.Wikipedia. “Shinkansen” (snow sprinklers; Jōetsu slab track; Akita 2013 blizzard derailment; UrEDAS). en.wikipedia.org

19.Toyo Keizai. “Why Heavy Snow is no Match for the Tokaido Shinkansen” (2016) — cancellations 635 (1976) to ~0 since 1994. toyokeizai.net

20.“A Rail-Temperature-Prediction Model Based on Machine Learning.” Sensors (2021) — buckling, speed limits, water spraying. ncbi.nlm.nih.gov

21.Alto, “Winter Operations Require Winter Readiness,” altotrain.ca blog (2026) — lists chemical de-icing using “glycol- or saline-based solutions.” altotrain.ca

July 3, 2026

Sign first, see later

Sign First, See Later

A confidentiality precondition runs through ALTO’s field studies and corridor maps — for municipalities and for Indigenous rightsholders alike.

ALTO HSR Citizen Research Initiative · Research Brief · Published June 2026

The finding in brief

Two of ALTO’s own June 2026 reports, read together, reveal a pattern. To let ALTO’s crews onto its land for field studies, the United Counties of Stormont, Dundas and Glengarry would first have had to sign a non-disclosure agreement; they declined. And to see the early corridor maps for their own territories, Indigenous communities were asked to sign a collaboration or confidentiality agreement first.

In both cases the information came with the same condition attached: silence. This is a question of public trust, not of whether the trains are a good idea.

“The most basic question — where might the line go? — was answered only after a confidentiality agreement was signed.”
— the pattern across ALTO’s own June 2026 reports

The Evidence

What the documents show

The pattern is set out not in commentary but in ALTO’s own records and a municipal council package — the same condition appearing in two separate processes, applied to two different kinds of party.

The municipal case	The rightsholder case
Set out in the United Counties of SDG’s June 15, 2026 council package. ALTO sought a Permission to Enter agreement for environmental field study and geotechnical work — boreholes, test pits, and tree clearing — on county-owned parcels, with the Counties required to sign a non-disclosure agreement as a condition of access. Council declined the request.	Set out in ALTO’s Indigenous Consultation What We Heard Report. Initial corridor maps, prepared in November 2025, were shared only with communities that had signed a collaboration agreement or a non-disclosure agreement. For the others, ALTO worked to secure non-disclosure agreements to share maps as early as possible (p. 14). A community could not see the corridor maps for its own territory until it accepted a confidentiality undertaking. View ALTO’s report

The municipal case

The rightsholder case

Set out in the United Counties of SDG’s June 15, 2026 council package. ALTO sought a Permission to Enter agreement for environmental field study and geotechnical work — boreholes, test pits, and tree clearing — on county-owned parcels, with the Counties required to sign a non-disclosure agreement as a condition of access. Council declined the request.

Set out in ALTO’s Indigenous Consultation What We Heard Report. Initial corridor maps, prepared in November 2025, were shared only with communities that had signed a collaboration agreement or a non-disclosure agreement. For the others, ALTO worked to secure non-disclosure agreements to share maps as early as possible (p. 14). A community could not see the corridor maps for its own territory until it accepted a confidentiality undertaking. View ALTO’s report

A confidentiality clause is ordinary between two private companies. It is a different matter when the other party is a public body, or an Indigenous community being consulted about its rights.

The Municipal Case

What was actually requested

ALTO sought a “Permission to Enter” (PTE) agreement covering two kinds of work. The first is environmental field study — wetland and habitat assessment, wildlife and bird surveys, and the collection of noise, vibration, hydrology, soil and archaeological data, described as largely non-invasive. The second is geotechnical investigation: boreholes, test pits and other ground disturbance to characterise what lies beneath the surface. The County’s own report notes that this second category would require clearing trees to bring in heavy equipment, with the land to be “restored” afterward.

The agreement also runs in favour of the private developer consortium, Cadence, not only the Crown corporation — so a landowner’s signature binds them to both. And it requires the landowner to keep the arrangement confidential.

The request and its supporting materials are on the public record in the United Counties’ June 15, 2026 council package: the CAO Key Information Report, the ALTO presentation of May 5, 2026, and the Map of Impacted SDG Properties.

“It tells you nothing about the route”

ALTO’s presentation states, more than once, that a Permission to Enter does not indicate the final alignment and is not proof that a property sits on the route. Yet the same council package includes a map that identifies specific “Subject Lands,” and the geotechnical work is targeted at named parcels. You do not drill boreholes everywhere; you drill where you expect to build.

On the public record

In March 2026 the Mayor of North Glengarry said the alignment had shifted from the existing rail line through town to the township’s “far northeast corner” — the area, next to Highway 417, where the identified study parcels sit. The claim that the studies reveal nothing about the route, and the targeted footprint of the work, do not sit easily together.

“A municipality holds and shares information on behalf of its residents. A non-disclosure agreement is the one condition it cannot quietly accept.”
— the transparency question the request puts to a public body

The Analysis

A pattern, not an exception

A municipality holds and shares information on behalf of its residents; an Indigenous community is being consulted toward its free, prior and informed consent. In both settings, the value of the process depends on people being able to know — and to discuss — what is proposed for their land. A precondition of silence cuts against that.

What makes this a pattern rather than a one-off is that the same condition appears in two separate processes, applied to two different kinds of party, documented in the same set of reports. It is part of how the project is being run.

Why confidentiality changes the calculus

A public body that signs a non-disclosure agreement narrows what it can tell residents about studies on public land, and narrows what is reachable under freedom-of-information law. A rightsholder asked to sign before seeing a map is asked to accept a constraint before it has the information needed to weigh the project. Informed consent and an informed public both depend on having the information first.

Consent and Transparency

The tension the precondition creates

ALTO states that it consults Indigenous communities with the aim of securing their free, prior and informed consent. Consent is harder to call fully informed when the information is released only after a confidentiality agreement, and harder to call fully free when seeing the map requires signing first. None of this is to say that any community objected to the agreements — the report does not say so, and this brief does not speak for any community. The observation is narrower, and is about ALTO’s process: the condition it attaches to its own information.

For municipalities, the duty runs the other way — toward openness. Ontario’s freedom-of-information regime exists precisely so residents can learn what public bodies know. An access agreement that forecloses disclosure sits in tension with that duty, which is part of why the United Counties declined.

The Decision

What the municipalities decided

The refusals were not isolated. The body that owns the land said no; the host township and a regional caucus were already on record against the project; and a neighbouring county refused the very same non-disclosure agreement.

United Counties of SDG — the landowner

The Counties, which own the land, voted down the access request (By-Law No. 5538). Councillors pointed to the impact on agriculture and were wary that granting access would itself be read as support for the project.

North Glengarry — the host township

The township where the parcels sit had already endorsed the regional resolution opposing the project in its current form, and its mayor and council have continued to speak against it.

Prescott-Russell — the neighbour

On May 27, 2026 the neighbouring United Counties of Prescott and Russell unanimously refused to sign a non-disclosure agreement and declined access for surveys, with the warden framing it as a stand for transparency and local autonomy. Council minutes

Eastern Ontario Wardens’ Caucus

The regional caucus opposes the project in its current form — the resolution North Glengarry endorsed in April 2026.

What To Watch

What happens next

The field studies are active and, by ALTO’s own account, will continue through 2026 and beyond. The southern route now under study — through Kingston and the Frontenac Arch — will not reach public consultation until 2027. Access to the ground, and the agreements that come with it, can arrive well before the public conversation does.

The next test is a willing host. Kingston has asked for a station and wants its staff to work directly with ALTO. A municipality that wants the outcome may accept terms a reluctant one refused. Whether the confidentiality precondition travels south, and whether it has already been signed anywhere, can be tested directly: through freedom-of-information requests to the municipalities along the route.

Anticipated Objection

“Isn’t this just opposition to high-speed rail dressed up as a complaint about process?”

No. The concern is the terms on offer, not the existence of a railway. The refusing councils have not asked for no rail; they have asked that the project coordinate with existing passenger service and existing corridors, and that decisions be made in the open. The question is not whether ALTO may protect commercially sensitive information — firms do that routinely.

It is whether the public’s information about a public project, on public land and on the territories of rightsholders, should be available only to those who first agree not to share it. Better passenger rail and an open process are not in conflict.

The bottom line

The question is not whether ALTO may protect commercially sensitive information — firms do that routinely. It is whether the public’s information about a public project, on public land and on the territories of rightsholders, should be available only to those who first agree not to share it.

A reasonable standard would be simple: the corridor maps, field-study scopes, and access terms that affect a community should be available to that community without a confidentiality precondition. Better passenger rail and an open process are not in conflict.

Read the full brief offline or share it.

Download the brief (PDF)

Sources

Primary documents and statements

ALTO, Indigenous Consultation What We Heard Report (June 2026), incl. p. 14 — initial corridor maps shared only with communities that had signed a collaboration or non-disclosure agreement; ALTO describes the agreements as a means of sharing maps as early as possible. altotrain.ca

ALTO, Public Consultation What We Heard Report (June 2026).

United Counties of SDG council package, June 15, 2026 — CAO Key Information Report; ALTO presentation, May 5, 2026; Map of Impacted SDG Properties; and By-Law No. 5538.

The SDG access vote and councillor statements as reported by the Morrisburg Leader, June 18, 2026.

North Glengarry’s April 13, 2026 endorsement of the regional (EOWC) resolution, and its mayor’s continued public opposition — The Review, April 16, 2026, and Cornwall Seaway News.

United Counties of Prescott and Russell, Regular Council Meeting, May 27, 2026 — council declined to sign a non-disclosure agreement and refused access for surveys. Meeting agendas and minutes

Transport Canada announcement, Kingston, June 22, 2026.

June 28, 2026

A straighter line

A Straighter Line

Three ways to connect the same cities — and what the government’s own yardstick says about each.

ALTO HSR Citizen Research Initiative · Research Brief · June 2026

⚠ Companion to “Sixth in North America”

The 2020 ministerial briefing released under A-2022-005 contains two yardsticks the federal government chose for itself: slide 2.5, a checklist of where high-speed rail works best, and slide 2.6, a benchmark table of selected HSR systems. This brief runs ALTO’s eight proposed stations through both — then tests two other ways of connecting the same anchor cities. Read the companion brief →

The finding in brief

On the government’s own benchmark, ALTO as planned is the longest corridor and the least demand-dense of any system in the briefing — about 14,600 people per kilometre of new track, below every benchmarked line that reports a population.

Straightening the Toronto–Montreal spine helps only a little. The real lever is dropping the two stations that sit on no existing line, and reaching Ottawa and Quebec City on upgraded track rather than new build. Do that and the new build falls to a 540 km High Performance Passenger Rail (HPPR) spine — about 40 per cent less new track than ALTO — while demand density on new build climbs by roughly two-thirds, to mid-pack above Spain, without losing a single anchor city.

The Yardsticks

Two tests, chosen by the government

Slide 2.5 lists what makes high-speed rail work: large metropolitan populations, strong local transit, an optimal corridor length between economic centres, and dense city pairs.

Ministerial briefing slide 2.5, Success Factors: Where HSR Works Best, listing strong transit connections, optimal corridor length, and city-pair criteria including metropolitan population, GDP, density and collaborating economic sectors

Slide 2.5, “Success Factors: Where HSR Works Best.” Page 154 of the Canada Infrastructure Bank release, A-2022-005 (disclosed in part; marked DRAFT) — the federal checklist of where high-speed rail succeeds.

Slide 2.6 then benchmarks selected systems on capital cost, length, and the combined population they serve. Together the two let us score any route on the government’s own criteria — not ours.

Ministerial briefing slide 2.6, Selected HSR Systems: Key Metrics, a table of capital cost, cost per track-kilometre, population served, GDP and total length for seven HSR systems including France, Spain, the UK, Japan, Taiwan, California and Texas

Slide 2.6, “Selected HSR Systems: Key Metrics,” from the same release (A-2022-005, disclosed in part; marked DRAFT) — the benchmark systems against which the corridor is measured below.

Run ALTO’s eight stations through slide 2.5 and they sort cleanly into three tiers:

Anchors — pass outright

Toronto, Montreal, Ottawa, Quebec City: large metros with real or near-real rapid transit, at HSR-friendly distances. These are the cities the corridor exists to connect.

Good intermediate — earns its place

Kingston: small, but it sits on the direct Toronto–Montreal path, so it adds riders without adding distance. The methodology rewards exactly this.

Weak — cost without a base

Peterborough and Trois-Rivières are small and sit on no existing passenger line; reaching either means building all-new track. Laval is redundant — it is inside the Montréal CMA.

The Ladder

Three ways to connect the same anchors

Hold the four anchor cities constant and change only how they are linked. Option ① is ALTO as planned. Options ② and ③ are the High Performance Rail (HPR) alternative: a new-build HPPR spine — the High Performance Passenger Rail line — on the direct Toronto–Montreal lakeshore, plus upgraded existing track for the secondary connections. ② keeps all eight stations, reaching Ottawa on the existing line and the small cities by new spur; ③ keeps Kingston on the spine, reaches Ottawa and Quebec City on upgraded existing lines, and drops the two off-corridor cities.

Metric	① ALTO as planned	② Direct HPPR spine + spurs (keep all 8)	③ Direct HPPR spine + Ottawa link (drop 2)
Stations	8	8	6
Toronto–Montreal routing	~650 km (detour via Peterborough/Ottawa)	~540 km direct lakeshore (HPPR spine)	~540 km direct lakeshore (HPPR spine)
Ottawa connection	on the new mainline	upgraded existing (Smiths Falls–Brockville)	upgraded existing (Smiths Falls–Brockville)
Montreal–Quebec City leg	new build (north shore, via Trois-Rivières)	new build (north shore, via Trois-Rivières)	upgraded existing (south-shore VIA line)
New-build track	~910 km	~850 km	~540 km
Upgraded existing track	—	~80 km	~350 km
People served	~13.3 M	~13.3 M	~13.0 M
Demand density, new-build track	~14,600 / km	~15,600 / km	~24,100 / km
Position on the slide 2.6 benchmark	last	below Spain	mid-pack (above Spain)
Off-corridor cities needing new track	Peterborough, Trois-Rivières	Peterborough, Trois-Rivières	none

The Montreal–Quebec City leg is the pivot between ② and ③: ② builds it as new north-shore track to keep Trois-Rivières on the line, while ③ drops Trois-Rivières and serves Quebec City on the existing south-shore line, upgraded — about 260 km of the gap in new build between the two. In both ② and ③ the Ottawa connection is upgraded existing track (VIA’s Smiths Falls–Brockville line), not new build. Distances are approximate planning-level estimates; full workings with live formulas are in the reference-class workbook.

What the Numbers Say

Reading the ladder

① ALTO is the longest, least-dense option

At roughly 14,600 people per kilometre of new track, ALTO sits below every system on slide 2.6 that reports a population — the most track for the least demand per kilometre.

② Straightening the spine helps only a little

Keep all eight cities but run Toronto–Montreal direct on the HPPR spine and reach Ottawa on the existing line: new build falls to ~850 km (from ALTO’s ~910) and density edges up to ~15,600 per kilometre. Better — but still near the bottom of the benchmark, because it keeps building new track for Peterborough and the north-shore line to Trois-Rivières. The off-corridor cities, not the spine, are what hold it down.

③ Dropping the two off-corridor cities is the lever

Removing Peterborough and Trois-Rivières — and reaching Ottawa and Quebec City on upgraded existing track — cuts new build to just the 540 km HPPR spine, about 40 per cent less than ALTO, while losing fewer than 0.3 million people. Most of the saving is the Quebec leg: with Trois-Rivières gone, Montreal–Quebec reverts from ~260 km of new north-shore track to the existing south-shore line, upgraded. Demand density on new build climbs from ~14,600 to ~24,100 per kilometre — from worst on the benchmark to mid-pack, above Spain. The route gets stronger by building less, because the dropped legs were costing more length than they were adding demand.

The Kingston Test

Same city, opposite effect

Kingston is the cleanest illustration, because every option serves it. On the direct line it sits on the shortest Toronto–Montreal path, so it adds riders at almost no added distance — density goes up. On ALTO, reaching the same city means a southern dogleg off the northern route — the same population bought with extra kilometres, so density goes down. One stop, two outcomes, set entirely by the alignment rather than the city. Keeping Kingston while dropping Peterborough is precisely the discrimination the federal criteria imply: reward the intermediate that sits on the path, decline the one that pulls the line off it.

In plain language

The problem was never which cities to serve. It is the line drawn to reach them. Run the strong Toronto–Montreal market on the direct lakeshore route, branch to Ottawa, serve Quebec City on the line that already exists, and keep Kingston where it naturally sits — and the corridor moves from worst on the government’s own benchmark to the middle of the pack, on far less new track.

The two stations that drag it down, Peterborough and Trois-Rivières, are the two that sit on no existing line and would each need new track built to reach them. Serving them may be a worthy regional goal — but it should be argued and costed as that, openly, not folded into a national corridor whose headline case rests on Toronto–Montreal.

Method

How this was scored

“People served” is the combined metropolitan population of the named cities — a scale proxy, not modelled ridership, and the same crude basis slide 2.6 uses. Demand density is people per kilometre of new-build track. The alternative configurations are High Performance Rail (HPR): a new-build HPPR spine on the direct Toronto–Montreal lakeshore, plus upgraded existing lines for the Ottawa connection (VIA’s Smiths Falls–Brockville route) and, in ③, the Montreal–Quebec leg. ALTO and both alternatives are high-performance (≤200 km/h), not the 300 km/h HSR of the slide 2.6 benchmark systems, so the density comparison is conservative. Distances are approximate planning-level estimates and should be checked against ALTO’s published alignment before any figure is cited. Populations are 2021 StatCan census-metropolitan-area figures; slide 2.6 is on a 2016 basis. Trois-Rivières has had no passenger rail since 1990 and is not on VIA’s south-shore Montréal–Québec line, so serving it requires all-new track. Full workings, with live formulas, are in the reference-class workbook.

June 26, 2026

Sixth in NA

Sixth in North America

What the ranking actually measures — and the route it does not describe.

ALTO HSR Citizen Research Initiative · Research Brief · Published June 2026

⚠ Source: Disclosed under the Access to Information Act

The slide below is page 206 of a 294-page record released by the Canada Infrastructure Bank under access request A-2022-005 — a request for all studies, analyses, and reports related to the federal government’s high-frequency and high-speed rail file, disclosed in part. The briefing deck it belongs to is stamped “Privileged and Confidential — Do Not Share and/or Copy,” and its own footer marks it “DRAFT.” Adjacent pages were withheld under the Act’s economic-interest and advice exemptions (s. 18 and s. 21). The deck, as disclosed, is posted in full here: Ministerial Briefing — HFR and HSR (PDF).

The marking is part of the point: this is a draft analysis the department preferred not be seen, and it is the evidence being used to vouch for the corridor.

Briefing slide: Success Factors, Where HSR Works Best, ranking North American city pairs by high-speed rail demand

Section 4.2, “Success Factors: Where HSR Works Best.” Page 206 of the Canada Infrastructure Bank release, A-2022-005 (disclosed in part; marked DRAFT). The three highlighted bars are Toronto–Montreal, Toronto–Ottawa, and Montreal–Quebec City.

The finding in brief

The slide ranks Toronto–Montreal sixth among North American city pairs for high-speed rail demand. The ranking is real. What it measures is the market between two endpoint metros — not the route now being built.

The number describes the direct Toronto–Montreal corridor. The alignment taking shape runs Toronto–Peterborough–Kingston–Ottawa–Montreal — a longer, meandering route. On the very methodology the slide cites, every one of those detours lowers the score rather than raising it. And the segment actually proceeding first, Ottawa–Montreal, does not appear on the chart at all.

The Methodology

What the ranking measures

The “sixth in North America” figure comes from America 2050’s screen of tens of thousands of city pairs, a methodology published in full by the Regional Plan Association. It scores the market between two endpoint metros: downtown employment, population density, transit reach, and the existing air and road travel between them. On those inputs Toronto–Montreal scores well. The endpoints are large, dense, and already heavily travelled.

Two features of that method decide everything that follows, and both are explicit in the source.

It is calculated per mile. Adding distance without adding a major generator pulls a corridor’s score down, not up. The screen normalizes precisely so that longer routes cannot coast on length.

Intermediate stations only help when they are themselves large. The report is clear that longer corridors out-rank shorter ones only when the cities in between are medium or large generators. Otherwise the additional miles are a penalty. The top-ranked corridor on the chart, New York–Washington, scores as it does because the dense intermediate cities of Philadelphia and Baltimore sit directly on the shortest path between the endpoints.

The Route

The corridor on the chart is not the corridor being built

The favourable score belongs to the direct Toronto–Montreal market — the existing lakeshore line, the shortest path, with a dense string of intermediate communities along it. The alignment now taking shape is the opposite of that. From Toronto it runs north to Peterborough; then — assuming the Kingston stop and southern routing the federal government added to its consideration in June 2026 come to pass — it doubles back south to Kingston, climbs north again to Ottawa, and drops south once more to Montreal. The result is a corridor that zigzags between its cities rather than running directly between its endpoints.

Map of the projected Toronto to Quebec City corridor showing the route meandering north and south between cities rather than following a direct line

The projected Toronto–Quebec City corridor. Rather than following the direct lakeshore line, the alignment meanders — north to Peterborough, south to Kingston, north to Ottawa, south to Montreal, and on toward Quebec City.

The direct corridor (what the bar scores)	The alignment being built
Toronto–Montreal, direct. The existing Lake Ontario lakeshore line, on the order of 540 km — the shortest path between the two endpoints.	Toronto–Peterborough–Kingston–Ottawa–Montreal. Roughly 610 km via Ottawa — about 13 per cent longer for the identical endpoints, and longer still with a Kingston dogleg. (This path assumes the Kingston stop and southern routing added to federal consideration in June 2026 proceed.)
Dense intermediate string. Oshawa, Cobourg, Belleville, Kingston — population and employment added steadily along the path.	Sparse flanks, weak axis. Peterborough is small and the stretches on either side of it are thinly populated; reaching Ottawa means importing the Toronto–Ottawa axis the same chart ranks near the bottom.
Highest possible per-mile score for these two endpoints.	A lower per-mile score: more kilometres, less density per kilometre, and a low-scoring leg folded in.

There is a particular irony in Kingston. It is the natural intermediate city on the direct corridor — precisely the stop that would have helped the Toronto–Montreal score. The chosen alignment runs north to bypass it. Now it is being considered for re-inclusion, bolted back onto a route designed to avoid it.

On the Method’s Own Terms

What each detour does to the score

Re-run the published methodology on the alignment actually on the table, and the per-mile score falls below the sixth-place bar. Each of the route’s defining choices works against it:

Length is a straight penalty

Per-mile normalization spreads the same Toronto and Montreal endpoint demand over more kilometres. A longer, more circuitous route scores lower for the identical endpoints — that is what the normalization is designed to do.

Peterborough adds miles faster than density

Intermediate stops only lift the score if they add population and employment per kilometre faster than the corridor’s average. Peterborough is too small, and the stretches on either side are sparse, so it adds length faster than it adds riders — a net penalty.

A Kingston dogleg is more of the same

Re-adding the one city the alignment was routed to avoid means a southern detour off the northern line: a modest generator bought with extra kilometres — again, length outpacing density.

Reaching Ottawa imports a weak leg

Ottawa is the one genuine generator among the added stops. But reaching it is the Toronto–Ottawa axis the same chart already ranks near the bottom of its field. The detour swaps the strong direct Toronto–Montreal axis for a leg the deck itself scores as weak.

Sequencing

What is actually being built first

There is a further mismatch between the headline number and the build. The first segment to proceed is not Toronto–Montreal at all — it is Ottawa–Montreal, confirmed in December 2025 as the opening phase, with construction targeted for 2029. Ottawa–Montreal does not appear anywhere on the chart.

And by the government’s own account, it was chosen first not for demand but for buildability: a relatively short and straight portion of the overall route, since high-speed trains do not handle curves well — the same logic that led California to build its first section across the flat Central Valley, avoiding tunnelling and urban construction. A constructability rationale, not a ridership one.

The corridor that scores sixth, Toronto–Montreal, is only realized once the full line is complete — including the Toronto–Ottawa leg that sits near the bottom of this very chart — work not expected to finish until the 2040s. So the headline ranking and the actual build diverge twice over: the number describes a market the first segment does not deliver, assembled from legs the chart scores unevenly, with the strongest part of the case deferred to last.

In plain language

Strip away the methodology and the point is simple. The federal government’s own briefing says high-speed rail makes the most sense between Toronto and Montreal — two large cities with heavy travel between them. It says nothing in favour of the winding route now being built.

That route keeps collecting stops the demand evidence does not support: north to Peterborough, a proposed southern dogleg to Kingston, and Trois-Rivières on the Quebec leg. Each one adds distance and cost while the case for the line still rests on the direct Toronto–Montreal market. When stations are added that do not earn their place on the numbers, the usual explanation is political — spreading the visible benefits of a marquee project across as many communities as possible to assemble support for it.

This is one of the central problems with the project, and it is a familiar one. Bent Flyvbjerg’s research on megaprojects — the body of work behind this Initiative’s reference-class approach — finds that large infrastructure projects routinely run over budget and under-deliver because their scope and routing are shaped by political bargaining and the need to sell the project, rather than by the demand evidence. A corridor designed around who gets a station rather than where the riders are is precisely the pattern that research warns about.

In Summary

What the slide does and does not say

The “sixth in North America” finding endorses a Toronto–Montreal market. It says nothing in favour of the Peterborough-routed, Kingston-doglegged, Ottawa-and-Montreal-served alignment. On the methodology’s own terms, those inclusions are exactly the choices it would mark down.

A strong endpoint market is a real asset. It is not the same thing as a strong route — and a briefing that uses the first to vouch for the second is measuring the wrong thing. That the slide is marked “DRAFT,” and that adjacent pages were withheld under the Act’s economic-interest and advice exemptions, only sharpens the question: this is the analysis on the record, and on its own terms it does not say what it is being used to say.

A note on method. The deck describes its result as a “sample calculation.” The disclosed page does not show how the path was drawn or scored. The standard America 2050 methodology and the headline result both point to the direct corridor as the basis for the sixth-place figure; if the underlying calculation is obtained, the path it used is the detail to confirm.

Anticipated Objection

“Doesn’t the line serve all those city pairs — Toronto–Ottawa, Ottawa–Montreal, Montreal–Quebec — not just Toronto–Montreal? Combine them and the project makes sense.”

It is true that a corridor serves a whole matrix of city pairs, not only its endpoints. But that observation concedes the point rather than answering it. The “sixth in North America” figure is the score for the direct Toronto–Montreal pair. The moment the case leans on Toronto–Ottawa, Ottawa–Quebec, and Toronto–Quebec, it is no longer resting on that figure — and those are precisely the legs the same chart rates weakest: Toronto–Ottawa sits second from the bottom, Montreal–Quebec City is last, and Ottawa–Quebec, Toronto–Quebec, and Ottawa–Montreal do not appear on it at all.

Two things make “combine the figures” fail on the slide’s own terms. The bars are demand-strength rankings — built from population, GDP, density, and corridor length — not passenger counts that can be summed; a sixth-place pair plus a near-last pair does not add up to a stronger corridor. And because the screen normalizes per mile, stringing the one strong pair onto a longer, detouring alignment spreads the same demand across more track-kilometres, which lowers the score rather than raising it.

The logic in fact argues for the line this brief describes. If the goal is to capture Toronto–Montreal and the markets in between, the alignment that does it best is the direct lakeshore corridor — it serves the sixth-place pair at full strength and threads a dense string of real intermediate cities (Oshawa, Cobourg, Belleville, Kingston) on the way. Adding up the pairs does not rescue the meandering route; it makes the case for the direct one.

Sources

Primary documents and statements

Canada Infrastructure Bank, completed access-to-information release A-2022-005 (disclosed in part), “Success Factors: Where HSR Works Best,” draft briefing slide, page 206. Released under the Access to Information Act; deck marked “Privileged and Confidential — Do Not Share and/or Copy” and “DRAFT.” View the disclosed deck (PDF)

America 2050 / Regional Plan Association, High-Speed Rail in America, January 2011 — the published methodology scoring rail corridors by ridership demand on a per-mile basis.

America 2050, Where High-Speed Rail Works Best — the precursor study of city pairs that the briefing slide reproduces.

Transport Canada / Alto, “Full speed ahead: Ottawa–Montreal chosen as starting point for Alto High-Speed Rail,” December 12, 2025. canada.ca · altotrain.ca

“First segment of Canadian high-speed rail to be built between Montreal, Ottawa,” Trains, December 12, 2025 — carries the Minister of Transport’s rationale for selecting the segment as a short, straight portion of the route. trains.com

“Ottawa-Montreal chosen as 1st segment of promised high-speed rail line,” CBC News, December 12, 2025 — remaining segments (Quebec City–Montreal and Ottawa–Toronto) to begin at a later, unspecified date. CBC News

Federal government statement, June 22, 2026, indicating an additional stop at Kingston would be considered for the corridor.

Bent Flyvbjerg, Nils Bruzelius & Werner Rothengatter, Megaprojects and Risk: An Anatomy of Ambition (Cambridge University Press, 2003); Flyvbjerg, “Survival of the Unfittest: Why the Worst Infrastructure Gets Built — and What We Can Do About It,” Oxford Review of Economic Policy 25, no. 3 (2009): 344–367; and Flyvbjerg, “Design by Deception: The Politics of Megaproject Approval,” Harvard Design Magazine no. 22 (2005) — on strategic misrepresentation, perverse incentives, and the political shaping of megaproject scope and routing.

June 26, 2026

Estimated not simulated

Estimated, Not Simulated

The journey times behind ALTO were drawn from a spreadsheet of international averages — not from a model of the actual corridor. What that distinction means, and who set the target.

ALTO HSR Citizen Research Initiative · Research Note · Published June 2026 · Based on Access to Information release A-2025-00333

Critical Finding

A government record released under the Access to Information Act shows that, of the journey times prepared for the project, only the slowest case was produced by an actual simulation of the railway. That case was a 110 mph (177 km/h) train — a roughly four-hour Toronto–Montréal trip. Every faster time, including those near the speeds ALTO now markets, came from a spreadsheet that applied average speeds borrowed from intercity railways in other countries.

The technical memorandum describes those faster figures, in its own words, as “for information and comparison purposes.” And the email chain attached to it records the most senior Transport Canada official on the file directing that the times not assume Toronto speeds above 160 mph (257 km/h), because a higher figure was “not the intent of the Government.” The journey time, in other words, was managed as a policy and cost target — not derived as an engineering result.

The Record

What the document is

The release (A-2025-00333) was obtained under the Access to Information Act and provided to the Initiative. It consists of an email chain dated August 30 to September 4, 2023 among Transport Canada and Via HFR / Via TGF officials and their technical advisers, together with the attached memorandum “VIA HFR-TGF Journey Times.” It dates from the procurement period, when the project was still a high-frequency rail (HFR) programme under Transport Canada’s lead, before the February 2025 announcement re-scoped it as high-speed rail at 300 km/h.

The memorandum is the engineering note that sits beneath the project’s headline travel times. It is explicit about how those times were calculated — and it used two very different methods for two different parts of the answer.

The Distinction That Matters

Two ways to get a journey time

A train’s journey time is the single number a project like this is sold on — “Toronto to Montréal in X hours.” There are two fundamentally different ways to produce that number, and they are not equally reliable.

A simulation builds a digital twin of the real railway and “drives” a train along it. The software knows the actual track: every curve that forces the train to slow, every hill, every station stop, where the signals are, how fast the specific train accelerates and brakes, and whether other trains — including freight — are in the way. It runs the trip second by second on that line and reports how long it genuinely takes. The memorandum names the tool used for this: RailSys, drawing on the JPO’s 2021 Rail Operational Summary Report. It is the railway equivalent of a flight simulator, or of a mapping app with live traffic.

A spreadsheet estimate does something far cruder: it takes the distance, assumes an average speed borrowed from how fast trains run in other countries, and divides one by the other. It never looks at this corridor’s actual geometry, terrain, urban approaches, or shared freight track. The memorandum is candid that its faster figures are of this kind — an “estimated calculation based on the maximum permissible speed,” provided “for information and comparison purposes.”

Simulation — the RailSys tool	Spreadsheet estimate
Drives the actual route. Models every curve, gradient, station stop, signal and conflicting train on the real Toronto–Québec line, second by second.	Distance ÷ an assumed average speed. Takes the route length and an average operating speed benchmarked to comparable intercity rail abroad, and divides.
Knows the corridor. A curve too tight for high speed shows up as a slower section; a freight train ahead shows up as lost minutes. Constraints surface before construction, not after.	Blind to the corridor. Cannot see this line’s curves, hills, city approaches or freight sharing. The memorandum labels its outputs indicative only.
What ALTO simulated. Only the 110 mph (177 km/h) base case — roughly a four-hour Toronto–Montréal trip.	What ALTO estimated. Every faster time, including the 160 and 186 mph figures (257 and 300 km/h) closest to the marketed speeds.

The difference is the difference between “we modelled it and it works” and “we estimated it from comparables.” The first is a tested result for this railway. The second is an educated guess that a later, detailed study would have to confirm.

What Was Actually Run

The only simulated number is the slow one

~4 hrs

the only Toronto–Montréal time actually simulated (110 mph / 177 km/h base case)

RailSys, per the memorandum

Spreadsheet

the source of every faster journey time on the page

benchmarked to foreign averages

160 mph

(257 km/h) — the speed ceiling set as “the intent of the Government”

TC official, Aug–Sept 2023

The memorandum’s own tables make the gap plain. The single time it produced by simulation — the 110 mph (177 km/h) base case — is roughly 3:59 to 4:19 for Toronto–Montréal. The faster times on the same page, for a 186 mph (300 km/h) or 160 mph (257 km/h) train, run from about 2:40 to 3:10. But those faster figures are the spreadsheet ones. The four-hour trip is the only number anyone actually drove through the model. The under-three-hour trips that make high-speed rail attractive were never simulated for this corridor.

This matters because the public ALTO project is now built on 300 km/h (186 mph) running. Even the “calculated” 186 mph (300 km/h) times in this 2023 record trace back to the spreadsheet, not the simulator — and the simulator was only ever pointed at the slow case.

A second problem: not the door-to-door time

There is a second issue with these numbers, separate from how they were produced. Every figure here — simulated or estimated — is a train-in-motion time, measured platform to platform. It is not the door-to-door time that decides whether a traveller picks rail over flying, and door-to-door time depends on something ALTO has not settled: where the stations are. With downtown stations at both ends the corridor is competitive; with the suburban or peri-urban stations most consistent with the project’s cost structure, the advantage over air narrows or disappears. A separate academic submission to the consultation went further, noting that ALTO’s published times do not appear to even include the time for a stop in Ottawa — so the in-motion figures may be understated before the door-to-door question is reached. We treat that in full in The Station Location Problem and The Last Mile; the point here is narrower — the headline time is an estimate, and even taken at face value it is not the number that matters.

Who Set the Target

The journey time as a government decision

The instruction to hold the journey times down did not come from a technician. The email chain records that when a Toronto figure was put forward assuming sustained speeds above 160 mph (257 km/h), a Transport Canada official objected that it “assumes a full journey time from Toronto at speed greater than 160, which is not the intent of the Government,” and explained that the intent was to have bidders identify the segments with the lowest marginal cost for higher speed. The exchange closes on September 4, 2023 with the project director’s note: “No change to journey time agreed by Vincent.”

That official is Vincent Robitaille. According to Transport Canada’s own published biography, Robitaille has served as Assistant Deputy Minister – High Frequency Rail since December 2021 — the month the project’s governance passed to a Transport Canada–led integrated team — and he leads that team. His background before the role was in commercial policy and financing, not rail engineering: from 2018 to 2021 he was Director General of Transport Canada’s Centre of Excellence on Strategic Investments, working on the commercial elements and alternative financing of major transportation investments, and before that he led the public-private-partnership procurement of the new Champlain Bridge Corridor in Montréal. His credentials are financial and project-management designations (CFA, PMP, Certified Director, and an MBA). Transport Canada

Why the background is relevant, not incidental

This is an observation of record, not of motive. The person defining the journey-time ceiling as the Government’s intent — and steering bidders toward “the lowest marginal cost” rather than the fastest trip — is the project’s most senior Transport Canada official, whose professional expertise is procurement and project financing. It is consistent with a journey time being treated as a commercial and cost target to be managed, rather than an engineering output to be measured. The released record shows the target being set; it does not require any inference about why.

Two Years Later

The same official, now selling the fast times

In a public podcast interview in December 2025, Robitaille — by then leading the project for Transport Canada — described the corridor to a general audience in precisely the terms the 2023 record could not support with simulation: Montréal reachable in well under current rail times, a city you could reach for a day trip and return the same evening, trains “every half an hour,” the corridor as “commuting distance.” Those are the fast, frequent-service figures — the ones drawn from the spreadsheet.

The internal record from 2023 shows the same official holding the specification below those speeds — directing that journey times not assume sustained running above 160 mph (257 km/h), because faster was “not the intent of the Government” — and relying on benchmarked estimates for anything quicker. The public pitch and the internal caution are two years apart and point in opposite directions. The travel times now used to sell the project are of the kind the same official described internally, in 2023, as indicative.

The Bottom Line

A promise, or an estimate?

When a government tells the public “this train will get you there in X hours,” people reasonably assume engineers modelled the actual route and confirmed it. This record shows that, for the fast times, they did not. They did the back-of-an-envelope version — distance against speeds observed in other countries — and said so internally. A spreadsheet estimate is a hope; a simulation is the closest thing to a tested promise. The faster ALTO travels in its marketing, the further it gets from the only journey time anyone actually ran.

One caveat, stated plainly so the point is not overdrawn. The memorandum does say these estimates were always meant to be refined through later design and operational modelling by the eventual private partner. So the fair claim is not that the numbers were invented. It is that the detailed validation was deferred, and that as of this 2023 record the project’s faster journey times — including those near what is marketed today — had no corridor-specific engineering behind them, only benchmarked estimates. No simulation of high-speed running on the Toronto–Québec line appears anywhere in the released record.

Sources

Primary documents

Transport Canada / Via HFR (Via TGF), “VIA HFR-TGF Journey Times” (HFR JT note 20230831) and accompanying email chain, August 30 – September 4, 2023. Released under the Access to Information Act as file A-2025-00333.

Joint Project Office, Phase 2C Rail Operational Summary Report (2021) — the RailSys simulation source referenced in the memorandum for the 110 mph (177 km/h) base case.

Transport Canada, Briefing Documents 2025, biography: “Vincent Robitaille — Assistant Deputy Minister – High Frequency Rail.” tc.canada.ca

“From Bridges to Trains: Career lessons with Vincent Robitaille,” The Supply Chain Ambassador podcast, premiered December 3, 2025. Public interview; transcript auto-generated. youtube.com

June 2, 2026

Tag: Access to Information

Procured, and Then?

ALTO commissioned the outside view

Buying the instrument is not the same as letting it bind

The record will arrive after the decision has moved on

Two studies, no cost side

The scenario range has a floor and no ceiling on the downside

Adverse mechanisms are identified but do not reach the total

The two studies disagree, and each resolves the disagreement upward

The studies import the literature’s upside but not its realisation record

Publish the comparison

Documents relied on

Hours Are Not Dollars

What a discount rate is, in ordinary words

How much the answer moves

A number with a family tree

What the federal government uses, and the gap where a manual should be

The last time anyone published these numbers for this corridor

Three different rates, and only one of them is in the report

1. The appraisal rate — 3.5 per cent

2. What it costs the government to borrow

3. What a private partner needs to earn

How the Montréal REM is actually funded

What this does not claim

On the rate

On the comparisons

Two questions, answerable without releasing a model

1. Who absorbs it if the passengers do not come?

2. What fare, and what revenue?

Primary documents

ALTO Used the Rulebook’s Numbers. It Left the Rules Behind.

Why this matters

What the report gives you

What its own cited source requires

What that leaves a reader with

What the report borrowed, and from where

The numbers come as a set, not a menu

What a project this size is supposed to publish

Re-run the numbers at a different discount rate

Re-run the numbers with a rising value of time

Run the costs and assumptions through a range analysis

Report the odds that the project is worth doing

Publish the standard indicators

Model low, medium and high growth scenarios

This is not a theoretical requirement

The report concedes a range it never publishes

A top-up the manual requires, and the report does not mention

Too early to divide, but not too early to multiply

What this brief does not say

On the analysis

On the report and its source

Two questions ALTO can answer without releasing a model

1. Was the calculation ever run at a rate other than 3.5 per cent?

2. Which parts of the cited guidance were applied, and which were departed from?

Summary ledger

Primary documents

City of Kingston: Bound Before Briefed

“This is not optional”

Access conditioned on silence

Four agreements became three hundred and thirty-nine

The creep has already begun here

Twenty-six of twenty-eight had no end date

The promoter’s case, and what the record shows

What Britain concluded, in public, before Kingston signed

The Raynsford Review (Town and Country Planning Association, 2018)

Raynsford’s line — the most useful distinction in the literature

The House of Lords — criticism from the project’s own supporters

The culture did not stay in its lane

The same request, refused twice next door

United Counties of Prescott and Russell — refused, May 2026

United Counties of Stormont, Dundas and Glengarry — refused, June 15, 2026

Frontenac County — a formal, public vote on the corridor, April 15, 2026

City of Kingston — signed July 10; the authorising process is not on the public record

The choice Kingston was offered is not a real choice

Five questions, one answered

The confidentiality did not protect HS2

Primary documents and reporting

Wind, Ice & the Weather Envelope

The question was examined internally — and never reconciled in public

Why this matters for speed and cost