Tag: Cadence

Counting the crossings

Counting the Crossings

ALTO says it will not wall off communities, and points to France and Spain. Those countries did something else as well, and the letter leaves it out.

ALTO HSR Citizen Research Initiative · Analytical Brief · Published August 2026

⚠ What ALTO Told Kingston Readers

On 14 August 2026, a letter in the Kingston Whig-Standard from ALTO’s Chief Project Management Officer and Cadence’s Project Director told corridor residents the railway “will not create a wall between communities”, nor a barrier to wildlife or water. As proof it can be done, the letter offered two numbers: France has built more than 4,000 structures across roughly 2,700 km of high-speed line, and Spain more than 900 across roughly 750 km.

The letter does not mention Kingston, the route, where stations would go, what any of it costs, or expropriation. It does say preserving access has been a key principle from the beginning. ALTO’s own Preserving Access and Movement page carries a last-modified date of 7 May 2026 — after the consultation closed on 24 April.

The Short Version

Take ALTO’s own figures and divide them through. France works out to about one structure every 675 metres. Spain, about one every 833 metres. Those are the rates being offered as reassurance.

The trouble is that a count of structures built tells you nothing about how many crossings were closed. A railway can put in 900 bridges and still cut off 3,000 field entrances, farm lanes and township roads. The letter gives the top half of the fraction and leaves out the bottom.

Kingstonians already have ALTO’s own answer to this. In February 2026, ALTO’s Vice-President of Systems Engineering told Kingston City Council that crossings would be consolidated to bring costs down, and that the company would try to limit how many overpasses get built. That was six months before the letter, to the same city, on the same subject.

There is a larger omission. France did not solve farm severance with bridges. It has a legal procedure that lets the state reorganise the surrounding farmland so that a farm cut in two can be put back into a workable shape, paid for by the project. On one French high-speed line, 3,700 hectares of land were bought up in advance so that farmers could be compensated in land rather than only in cash. Ontario has nothing of the kind.

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Counting the Crossings — Full Brief (PDF)

The arithmetic behind ALTO’s France and Spain comparison, and the land instrument the letter leaves out

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The Arithmetic

What ALTO’s own numbers work out to

Neither figure in the letter is disputed here. They are simply divided through. A structure count only becomes meaningful once you know how far apart the structures are, and how far apart the things they are meant to replace used to be.

~675 m

average gap between structures on the French network, using ALTO’s figures

4,000 structures over 2,700 km

~833 m

average gap on the Spanish line ALTO cites

900 structures over 750 km

1.25–2 km

typical spacing of public roads across eastern Ontario’s concession grid

before counting farm lanes and driveways

There is a third number the letter does not offer, and it cuts the other way. HS2 in Britain is the most recent comparable project of this kind: a brand-new high-speed line built through peri-urban and rural England. Its first phase runs about 225 km and will carry more than 500 bridging structures, including over 50 major viaducts — roughly one structure every 450 m. That is about half again the French rate, through country a good deal more built up than eastern Ontario. The most recent comparable project provided more, not fewer, than the average ALTO offers as reassurance.

The spread between the three is itself worth noticing. A fifty per cent difference between two European networks tells you that these totals are governed by terrain, by how much of a route sits in tunnel or on viaduct, and by what each project counts as a structure. About nine tenths of HS2’s first phase runs in tunnel, in cutting or on structures, so a large share of those 500 exist to carry the railway over the landscape rather than to carry a community across the railway. A structure count is a construction statistic, not a standard of community access.

Eastern Ontario was surveyed on a grid. Roads run at regular intervals, and between them sit farm lanes, private driveways and municipal drains. Whether a European average is enough for that grid is exactly the question people along the corridor are asking. Quoting the French figure does not answer it. It assumes the answer.

There is a comparison closer to home that nobody has yet made. Highway 416 is a modern, fully grade-separated corridor built through the same survey grid, the same farmland and several of the same municipalities. How many crossings Ontario provided on that road is not something this brief has established, but it is the obvious yardstick, and it ought to be established before a French average is relied on.

The Missing Number

How many roads are we talking about?

The denominator is not actually a mystery. Canada’s own transport department has published it.

In a briefing note prepared for a Parliamentary committee in March 2023, Transport Canada set out what a full high-speed line between Québec City and Toronto would require: a fully enclosed and fenced corridor, a straighter alignment, double tracking throughout, and complete grade separation on a route that currently carries more than 1,000 public and private crossings.

That figure described the northern route, through comparatively empty country — Canadian Shield, wetlands, big rural lots. The southern corridor now being prioritised runs through some of the most intensively farmed land in eastern Ontario, where the concession grid is tightest. On the southern option, 1,000 is more likely a floor than a ceiling.

The Initiative’s own road severance analysis puts the proportion of crossings permanently closed rather than bridged on rural high-speed corridors at somewhere between 30 and 60 per cent. Applied to a floor of 1,000, that is 300 to 600 roads dead-ended — our estimate, not a figure ALTO or Transport Canada has published.

1,000+

public and private crossings on the alignment

Transport Canada, March 2023

300–600

roads likely closed, on the Initiative’s estimate

30 to 60 per cent of crossings

$3.2–8.4B

Initiative’s estimated cost of the crossings that would be built

never shown as a separate line

That last figure matters for a different reason. Grade separation is one of the most expensive parts of any high-speed corridor, and a sum of that size has never appeared as its own line in ALTO’s published capital estimate. Neither has any methodology explaining how many crossings will be built, or to what standard, or how it will be decided which roads are simply stopped up.

The reassurance in the August letter is offered in the absence of the one document that could support it. Further detail is set out in the Initiative’s technical analysis of road severances.

On the Record

What ALTO told Kingston in February

Six months before this letter appeared in Kingston’s paper, ALTO’s Vice-President of Systems Engineering and Interface sat before Kingston City Council and was asked about exactly this. The transcript is the fullest account ALTO has given in public of how it approaches road crossings, and it does not read the way the letter does.

The reassurance

Asked by a councillor whether there would be a standard distance between crossings, he described a working assumption that every road would get some form of duct or overpass, since the roads belong to municipalities or road authorities and cannot be cut unilaterally.

The qualification, in the same answer

He went on to say that in reality some crossings would be looked at for consolidation, to lower costs and improve construction, subject to discussion with the road authority.

The objective

Pressed by the Deputy Mayor, he set it out plainly: grade separations would vary by area, would be settled during route selection, and ALTO would “try and limit the number of overpasses that we’ll need to get created”.

And the fencing

He confirmed that modern high-speed rail must be completely segregated and fully fenced anywhere level access is possible, whether the line runs at 200 or 300 km/h.

Read together: a starting assumption that is subject to cost-driven consolidation, an explicit goal of building as few overpasses as possible, and continuous fencing between whatever crossings survive.

The councillor’s actual question — is there a standard distance between crossings — was not answered, and no standard has been published since. February’s statements and August’s letter were addressed to the same city.

Three Problems

Why the structure count does not settle it

You are being shown half a fraction

The number that answers the severance question is a ratio: structures built, divided by accesses cut off. The letter supplies only the first. Every complaint recorded by French and Spanish farmers over the last forty years is perfectly compatible with the figures quoted.

Not every structure reconnects anything

“Engineering structures” and “viaducts” include everything the railway needs to build itself: bridges over rivers, crossings of existing motorways and railways, tunnels through hills. A viaduct over a river gorge restores nobody’s access to their back field. How many of the 4,000 exist to reconnect a severed local road or laneway is not stated, and is certainly a much smaller number.

A different landscape

The French network largely runs through consolidated farming country. Eastern Ontario is a survey grid of concession roads, side roads, long farm lots and dead ends. The same rate of crossings produces a very different result depending on how much there was to cross in the first place.

The Missing Piece

What France also built

The most important thing missing from the letter is not a number. It is a law.

Two of the countries with the longest high-speed rail experience did not leave farm access to be worked out project by project. They legislated it. France did so through its rural code; Germany passed a federal land consolidation statute in 1953 that covers exactly this situation. In both, farmers sit on the body that decides, that body can compulsorily redraw the farms and the farm tracks together, the proponent pays, and there is a right of appeal to the courts.

France has a statutory procedure called aménagement foncier agricole et forestier — land reorganisation, formerly known as remembrement. Its stated purpose includes repairing the damage that major linear projects, high-speed railways among them, do to rural land. Where a line slices a farm in half, the surrounding parcels can be legally reorganised so that holdings are handed back in a shape a farmer can actually work. Local commissions run it under departmental authority, and the project pays for it.

Land is also bought up ahead of time. A national rural land agency, SAFER, holds first refusal on farmland coming up for sale, so that displaced farmers can be given land instead of only a cheque. Spain has its own version of the same idea.

This matters for who gets a say. In Canada there is no seat and no statutory role. On 4 June 2026 the five organisations representing effectively the whole farm sector in Ontario and Quebec concluded that ALTO’s proposed collaboration agreement was not in their members’ interests to sign. In France they would not have had to negotiate for a place at the table. They would already have had one, in law.

This is not a minor administrative detail. On the Le Mans to Rennes high-speed line, roughly 3,700 hectares were placed in reserve, with agricultural land bought up as it came to market within three kilometres of the future route. In Ille-et-Vilaine alone, 48.5 km of new railway took about 480 hectares of crops and pasture — and against that, 720 hectares of land reserve were assembled and parcels across some 1,200 hectares either side of the track were reorganised, affecting more than 4,400 landowners, financed by the project and delivered through intercommunal commissions.

In France and Germany	In Ontario
A legal procedure to reorganise farmland around a new line, whose express purpose includes repairing damage done by major linear infrastructure.	No equivalent. There is no statutory land reorganisation for farms severed by infrastructure.
Farmers hold seats on the deciding body, and decisions can be appealed to the courts.	No seat and no statutory role. Five farm organisations declined ALTO’s collaboration agreement in June 2026 rather than accept its terms.
A rural land agency with first refusal on farmland coming to market, used to assemble land reserves years ahead of construction.	No equivalent agency and no statutory land reserve mechanism.
Local commissions empowered to redraw parcel boundaries, operating under departmental authority.	No equivalent body. No one can redraw the neighbours’ boundaries to make a severed farm whole again.
Compensation in land is possible: a farmer who loses acreage can be given workable acreage back.	Compensation in money only, for what is physically taken. Expropriation and negotiated purchase are the available tools.

So the comparison in the letter is accurate and, at the same time, does not carry over. The French result rests partly on a legal instrument Canada does not have. A letter that cites France’s bridge count while saying nothing about France’s land reorganisation is describing half of how the problem was solved.

Cadence’s Project Director is quoted in French farming trade coverage of that same Le Mans to Rennes project, explaining that the land reserve had to account for the right-of-way, the land reorganisation and the environmental compensation together.

That gap is a problem in Canadian law rather than a failing of the project sponsor. It is still a gap, and it has to be closed before European results can reasonably be promised here. Closing it is not something ALTO can do on its own.

Not Just How Many

A structure is not automatically an answer

Even where a crossing is built, two questions decide whether it is any use, and ALTO has published nothing on either.

Size

A livestock crossing and a machinery crossing are not the same structure. A standard cattle underpass runs about 2.1 metres high. A modern combine or grain cart needs 4 metres or more. A structure built to the wrong dimension is a closure as far as the equipment is concerned. No minimum dimensions have been published, and no spacing standard.

Upkeep

Nobody has decided who maintains these crossings over the decades that follow. ALTO describes its approach as still being developed. France took roughly a decade of litigation and legislation to settle the same question. Municipalities along the corridor have a direct interest in the answer.

What closure pushes onto the road

When a farm crossing is extinguished, the equipment does not disappear. It goes onto the public road. By the Ontario Federation of Agriculture’s own figure, slow-moving farm vehicles are 3.8 to 4.8 times more likely to be involved in a fatal collision per kilometre travelled. Severance is therefore also a road-safety question, and one that has not been assessed.

The Initiative has examined the two halves of this problem separately: road severances and wildlife crossings.

The Wall

One claim that cannot be tested as written

A railway running at over 300 km/h is fully grade-separated and fenced along its entire length. That is what grade separation means. The structure is a continuous barrier by engineering necessity. The real question is where the openings are and how many there are, not whether the barrier exists.

What ALTO could reasonably promise is that severance will be mitigated at designed crossings, to a stated standard, at a stated spacing. A flat undertaking that no wall will be created is not something anyone can test — and it is a sentence that will be read back to ALTO by every landowner and every township that later finds an access closed.

The same applies to wildlife. Continuous fencing is a barrier to animals except where crossings are designed in, and how well those crossings get used varies a great deal by species — a question examined at length in the Initiative’s work on wildlife crossings.

An early study along a Spanish high-speed line, monitoring fifteen underpasses and two overpasses over two years, recorded no deer or wild boar crossings at all. That was 1996, and crossing design has moved on a great deal since; it should not be read as the last word. But the more recent evidence does not settle the question the other way either. A systematic review of crossing structures across roads and railways found that animals did cross them in almost every study examined — and yet a decline in wildlife movement after construction was prevented in fewer than 40 per cent of cases, with many structures poorly built or poorly monitored.

On Spain’s network the best-documented harm is to birds. Camera monitoring from on board trains estimated 60.5 bird collisions per kilometre per year on a stretch carrying 53 trains a day, and 26.1 on a stretch carrying 25. Later work found the surrounding bird community changing species by species, and uncapped catenary poles acting as pitfall traps for birds that nest in cavities. Anti-birdstrike screens are routinely fitted to viaducts, and how well they work is still being studied.

None of this says the corridor cannot be crossed by wildlife. It says that whether it can depends on design decisions and monitoring commitments not yet made, and that a flat undertaking given before them is not one a reader can test. Of the three promises, the one about natural water flows is the most straightforward to deliver.

What Can Be Asked Now

Six questions ALTO can answer today

The letter makes commitments specific enough to be checked. None of the following requires a finalised route.

The ratio

Against Transport Canada’s figure of more than 1,000 crossings, how many are assumed to get a structure, and how many will be closed?

Composition

Of the French and Spanish structures cited, how many exist to reconnect a severed local access, as opposed to carrying the line over a river, motorway or railway?

Ontario benchmark

What crossing rate is assumed for the Ontario segments, and how was it arrived at? A comparison with Highway 416 through similar country would be useful to communities along the route.

Criteria

What method decides whether a road is bridged or dead-ended, and what detour distance is treated as acceptable in the countryside?

Cost

What provision for grade separation sits inside the capital estimate, and why has it never been shown as a separate line?

Dimensions

What minimum height and width will agricultural crossings meet, and what spacing standard applies? Will structures be sized for machinery or only for livestock?

Maintenance

Who owns and maintains each crossing structure over its life, and who carries that cost — ALTO, Cadence, or the municipality?

Detours

Where an access will not be reinstated, how much further will people have to drive to reach the nearest crossing, and what work supports that figure?

Emergency access

Which paramedic services and municipal fire departments have been consulted about response routes, on what dates, and what did they find?

Severed farms

Is any land reorganisation or land reserve contemplated for farms cut in two, and under what legal authority would it operate?

The letter is right that decades of international experience exist and should be drawn on. The difficulty is that it draws on one half of that experience and leaves out the other. France built more than four thousand structures. France also rebuilt the farms. The second of those depended on machinery Ontario does not have, and no number of overpasses substitutes for it. Meanwhile the company’s own engineering executive has told this city’s council that the aim is to build as few overpasses as it can.

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Counting the Crossings (PDF)

Full analysis for municipal councils, farm organisations, MPs and residents along the corridor — with the per-kilometre working, the French statutory provisions and the complete source list

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How to read the numbers on this page

The French and Spanish structure counts are as given in the 14 August letter and used here as stated. The Transport Canada crossing count, the HS2 figures, the Kingston council statements, the French statutory provisions, the HS2 petition figures, the emergency-response research and the wildlife findings are all quoted from the sources listed below and can be checked there.

Everything else is our own calculation or estimate, and is marked as such where it appears: the per-kilometre and spacing rates, the 30 to 60 per cent closure proportion and the 300 to 600 closures that follow from it, the $3.2 to $8.4 billion grade-separation range, and the detour arithmetic. Where ALTO or Transport Canada has not published a figure, we say so rather than inferring one, and we make no claim about what anyone knew or intended.

Sources

Primary documents and statements

Maria Luisa Dominguez and Loïc Dorbec, “Building on decades of high-speed rail experience,” letter to the editor, Kingston Whig-Standard, 14 August 2026. Structure and length figures for France and Spain are as stated in that letter and are used here as given; the per-kilometre rates are the Initiative’s arithmetic.

Chambres d’agriculture France, on aménagement foncier agricole et forestier and its role in repairing disruption caused to rural land by the route of major linear works, high-speed railways included. chambres-agriculture.fr

Département d’Ille-et-Vilaine, on the LGV Bretagne–Pays de la Loire land reorganisation and land reserve programme: 48.5 km of new line, 480 ha absorbed, 720 ha of reserve constituted, 1,200 ha of parcels reorganised, more than 4,400 landowners affected, financed by the project owner. cg35.fr

WikiAgri, on the land reserves assembled through SAFER for the Le Mans–Rennes high-speed line: approximately 3,700 ha placed in reserve, with agricultural land pre-empted within three kilometres of the future alignment. Contains the quoted remarks of Cadence’s Project Director on the composition of that reserve. wikiagri.fr

Transport Canada, TRAN Committee Appearance Binder, Item 15: High Frequency Rail, 7 March 2023 — source of the figure of more than 1,000 public and private crossings on the alignment.

City of Kingston, Council meeting of 17 February 2026, closed-captioning transcript — remarks of ALTO’s Vice-President of Systems Engineering and Interface on crossing consolidation, overpass numbers and corridor fencing.

HS2 Phase 1 structure count: more than 500 bridging structures including over 50 major viaducts, per HS2 Ltd’s head of civils structures, reported in New Civil Engineer, 15 June 2022, and repeated on the Institution of Civil Engineers project page. Route length taken as approximately 225 km; some sources give 208 route km, which would raise the per-kilometre rate rather than lower it.

Wildlife. Rodríguez, Crema and Delibes (1996), on underpass and overpass use along Spanish high-speed line. Rytwinski and others, systematic review and meta-analysis of crossing-structure effectiveness, for the finding on movement decline. Barrientos and Borda-de-Água, “Railways as Barriers for Wildlife: Current Knowledge,” in Railway Ecology (Springer, 2017). García de la Morena and others (2017) for the on-board camera collision estimates; Malo and others (2017) on bird response and catenary-pole mortality; and work on high-speed rail and bird-community change published in PLOS One (2024).

Erin Durant, “Alto: Which farm roads stay open and who pays?” 16 August 2026 — source for the German Flurbereinigungsgesetz parallel, the seats-and-appeal structure of the French and German commissions, crossing dimensions for livestock versus machinery, the unresolved maintenance question, the OFA slow-moving-vehicle collision figure, and the last-modified metadata on ALTO’s agricultural pages.

10.

Joint statement of the Ontario Federation of Agriculture, l’Union des producteurs agricoles, National Farmers Union (Ontario), Christian Farmers Federation of Ontario and Union des cultivateurs franco-ontariens, 16 June 2026, following their 4 June meeting on ALTO’s proposed collaboration agreement.

11.

ALTO HSR Citizen Research Initiative, Road severances (technical analysis, March 2026 — source of the closure proportions and grade separation cost range) and Wildlife crossings.

12.

Ontario road spacing reflects the concession survey pattern across the corridor study area. Highway 416 is proposed here as a benchmark for comparison; no crossing-provision figure for that corridor has been established for this brief.

September 5, 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

The wrong answer to the right question

Coalition for Better Rail · ALTO HSR Citizen Research Initiative · The HPR Research Report

The Wrong Answer to the Right Question

The corridor genuinely needs better trains. What it got instead was a project that grew far beyond its original plan during procurement — and that can’t be fixed with tweaks, because its problems come from how it was chosen, not how it’s being built.

Chapter 2 · The HPR Research Report

This chapter doesn’t dispute that the Windsor–Toronto–Ottawa–Montréal corridor needs better intercity rail. It does. What it disputes is ALTO — on grounds that are about method and evidence, not politics. We trace how a modest upgrade of a largely existing, disused rail corridor turned into a 300 km/h greenfield megaproject during a competitive bidding process, lay out four structural problems with the project as designed, and explain why none of it can be patched from the inside.

Source Note

Much of this chapter draws on documents obtained through Access to Information requests — internal board and executive records, procurement files, and the independent fairness monitor’s final report — along with the Initiative’s own independent cost, ridership, and route-friction models. Specific releases are cited by their file numbers throughout. Some key documents, including the internal slide where the project’s scope was reframed, remain withheld.

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Chapter 2: The Wrong Answer to the Right Question (PDF)

The full chapter, with footnotes and sourcing

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2.1 · The Real Problem

The corridor genuinely needs better trains

The Windsor–Toronto–Ottawa–Montréal corridor connects Canada’s two largest metro areas and the national capital, and generates roughly half the country’s GDP. Despite that, intercity rail service on it is among the worst in any comparable wealthy country. VIA Rail shares track with CN freight, and freight trains get priority — when both need the same stretch of track, the passenger train waits in a siding. The result is slow, unreliable, and infrequent service.

<64%

VIA Rail’s on-time performance in 2023 — worse than Air Canada’s 63%, which itself ranked last among North America’s ten largest airlines

4h+

Scheduled Toronto–Montréal journey time — more than double a competitive flight, including check-in

~50%

Share of Canada’s GDP generated in this corridor — the economic weight today’s rail service fails to serve

Schedules are padded with hours of slack to absorb the delays that freight priority makes routine. The result isn’t competitive with driving or flying, and VIA can’t simply add more trains without bumping freight that has the contractual and legal right of way. So the question this report asks isn’t whether the corridor needs investment. It’s what kind of investment actually delivers it — at what cost, on what timeline, with what risk.

2.2 · How This Happened

A modest upgrade grew into a much bigger, much pricier project — during the bidding process

ALTO’s cost and ambition problems didn’t come from ordinary planning drift. Records obtained through Access to Information show the project’s scope escalating in the middle of the bidding process itself — not through any public announcement or debate. Understanding how that happened explains why ALTO costs what it costs today.

One thing to be clear about up front: this is not a claim that the procurement was run improperly. BDO Canada, the independent fairness monitor appointed in 2022, concluded in its final report of May 2025 that the process it observed was carried out in a fair, open and transparent manner, and recorded no fairness concerns at any stage. The problem is not that rules were broken. It is that a process run properly within its own terms produced a project no one had put to Parliament.

What was on the table originally

The project ALTO replaced was VIA Rail’s High Frequency Rail (HFR) plan: a dedicated-track plan running at up to 177 km/h, largely reviving a long-disused rail right-of-way through Peterborough, Havelock, and Smiths Falls — a separate, more direct route away from the CN Kingston Subdivision VIA still shares with freight today — delivered incrementally, segment by segment. Its own 2021 business case projected about 13.5 million riders a year, at a capital cost roughly a quarter to a third of what ALTO now proposes. That’s the baseline the public was never shown as a discrete choice against what came next.

An open-ended bidding process

The request for proposals went out in October 2023 without a settled route — internal records show the route was still being debated at the executive and board level as late as March 2024, five months after bidding opened. It also asked every bidder for two designs: one topping out at 200 km/h, and a second, more ambitious one with high-speed sections. The process then included 36 structured private meetings between the government and each bidder over eight and a half months.

All three bidders proposed something bigger

A Privy Council Office briefing note of 20 February 2025, released under access to information, records that as the bidding progressed all three shortlisted consortia put forward designs more ambitious than the high-frequency plan — new routes on largely new land, above 250 km/h. The jump in scope did not come from any one bidder. The winning consortium, Cadence — CDPQ Infra, AtkinsRéalis, Keolis, SYSTRA Canada, SNCF Voyageurs, and Air Canada — brings substantial experience in dedicated, higher-speed rail: its members built Montréal’s REM and operate France’s TGV network. What has never been published is the comparison the bidding process was set up to produce. The same briefing note credits an unnamed third party with concluding those bigger proposals would deliver greater benefits, and that analysis has not appeared in any release to date.

Billions committed before the plan was finished

The government committed $3.9 billion in the 2024 Fall Economic Statement before the business case was finalized and before a route was chosen. The internal slide that appears to document the scope escalation — titled “Level of Ambition Supported by Business Case” — remains withheld from public release. Once the funding commitment was public, there was effectively no way back to the smaller project.

Selling the bigger, pricier version

With the scope already locked in, the government faced a communications problem: a project that started as “VIA HFR” was now something much closer to European-style high-speed rail. Internal records show “high frequency” tested poorly with Ontario audiences, while the name “Alto” tested well with 18–34-year-olds and worked bilingually. A national ad campaign promoting the project’s benefits ran while the business case and route documents were still being withheld from information requesters.

The pattern, stated plainly

A project that entered the bidding process as a $9–12 billion, 177 km/h upgrade of a largely disused rail corridor came out the other side as a $60–90 billion (on the government’s own published figures — our independent estimate is materially higher), 300 km/h greenfield railway. That change in scope was never put to Parliament or the public as a choice. It emerged from the mechanics of the procurement itself.

2.3 · Four Problems Built Into the Design

Route, math, price tag, ridership — each one falls short

Having won a mandate for a much bigger project than the one that went to bid, ALTO’s proponents faced four separate problems: a route through sensitive land, a business case that has to clear a federal investment bar, a cost estimate that has to hold up, and a ridership forecast that has to be believable. None of the four holds up well under independent scrutiny.

2.3.1 · The route runs through some of the most sensitive land in the corridor

ALTO’s proposed new corridor crosses the Frontenac Arch Biosphere Reserve — a UNESCO-designated ecological corridor — the Napanee Limestone Plain, habitat for several species at risk, and Leda clay deposits south of Ottawa with known engineering hazards at high speed. This wasn’t a routing choice made for technical reasons; it reflects a decision to build an entirely new, 300 km/h-optimized corridor rather than follow existing, already-disturbed infrastructure. In our Participant Experience Survey, only 2% of respondents received direct notification about ALTO, and 88% found the information they did get inadequate. Our Community Friction Index — which scores corridors on land conflict, municipal pushback, expropriation exposure, ecological sensitivity, and public mobilisation — puts ALTO’s corridor at 54 out of 100, in the high-friction range. That matters financially, not just politically: in our statistical model, community friction is a significant predictor of cost overruns.

2.3.2 · The math doesn’t clear the government’s own bar

The only published economic appraisal of this corridor is the December 2021 business case for the predecessor project. It puts the benefit-cost ratio at about 0.13 over a 30-year period — about thirteen cents of measured value for every dollar spent — rising to about 0.4 once two newer and less established benefit categories are added in. A separate calculation in the same document shows a net loss of $21.1 billion in present-value terms. These are the government’s own figures. A ratio of 1.0 is simply break-even, the point where benefits equal costs. Our independent analysis, which grounds every input in how comparable projects have actually performed rather than project-specific projections, finds the ratio is likely far worse still.

Scenario	What it shows
Published (Dec 2021 appraisal) 30-year evaluation period	Benefit-cost ratio ~0.13, or ~0.40 on the expanded basis
Initiative reference-class estimate Cost assumed: ~$143B	Benefit-cost ratio ~0.03–0.11
Break-even	Benefit-cost ratio of 1.0 — benefits equal costs

In plain terms

ALTO fails its own government’s investment test on the government’s own numbers. Checking those numbers against how similar projects have actually performed makes the gap worse, not better.

2.3.3 · The price tag is very likely too low

ALTO’s published cost range of $60–90 billion comes from an early-stage estimate — the type quantity surveyors flag as accurate only to within roughly ±50%, which makes it a planning figure, not a firm commitment. Our own cost model, built from 16 comparable rail megaprojects worldwide and calibrated to those projects’ actual outcomes, puts ALTO’s realistic central cost at around $143 billion, with a worst-case scenario approaching $200 billion or more once cold-climate engineering risk (frost-susceptible clay, karst terrain, freeze-thaw cycles at high-speed tolerances) is factored in.

2.3.4 · No independent study backs the ridership numbers

ALTO projects 24 million riders a year by 2055. No car-dependent North American corridor without existing high-speed rail has ever come close to that. Research on transportation megaprojects generally finds ridership forecasts overstate actual results by about 51% on average. Our own bottom-up model — built from corridor population, trip-making patterns, and VIA’s own ridership data, tested under three different fare and subsidy scenarios — puts 2055 ridership at 3.7 to 17.2 million, with 9.2 million as the central estimate. ALTO’s 24-million target sits 40% above even our upper bound.

Source	2055 ridership estimate
ALTO’s public target	24 million
ALTO’s internal Corporate Plan figure (by 2059)	17 million — about 30% below the public figure
McGill TRAM stated-preference study	~19.7 million (year 50)
Munk School (U of T) model	18–19 million (year 30)
Standard bias correction applied to ALTO’s own figure	8.4 million
Initiative bottom-up model, central case	9.2 million (range: 3.7–17.2 million)

The pattern here too

Every independent forecast built from a published methodology lands within or close to our range. ALTO’s own public target is the outlier — and it’s the one figure whose methodology has never been disclosed.

2.4 · Why Patching It Won’t Work

These aren’t execution problems — they’re the project’s founding choices

A different route doesn’t fix the business case. A revised ridership forecast doesn’t fix the cost problem. Tighter project management doesn’t undo the fact that funding was committed before the business case was finished, on a specification set by the bidding process rather than by public need. Four reasons why this can’t be corrected from within:

It’s been treated as one-of-a-kind, so nothing gets checked against it

ALTO’s documentation consistently describes the corridor as having no real comparator, which is exactly the reasoning pattern researchers have found opens the door to over-optimistic numbers. Every genuinely comparable project elsewhere in the world gets waved away as not relevant — leaving the project’s own estimate as the only “evidence” available.

The most optimistic version of the numbers is the one that won

In competitive funding processes, the most optimistic projection tends to win, because optimism produces a better-looking business case than realism does. A version built on our reference-class numbers — a benefit-cost ratio of 0.03–0.11 — could never have survived the funding decision. The optimistic version did, but only because the more realistic numbers weren’t available yet when the commitment was made.

The first segment is too weak to stand alone — which is exactly the point

The planned first segment, Ottawa–Montréal, is the corridor’s weakest market: roughly 98% of that travel is currently by road, and there’s barely any competing flight traffic for a speed premium to beat. It can’t pay for itself. Its economics only work if the network keeps extending toward Toronto — which locks in a public commitment to the rest of the corridor before its full price has ever been disclosed. Britain’s HS2 project shows how badly this can go if it doesn’t: two legs cancelled, leaving a line more than double its original budget serving less than half the original network. HS2 at least stranded into its strongest market. If ALTO’s later phases stall, it strands into its weakest.

The alternative is quietly being closed off while this proceeds

The report’s proposed alternative, HPR, would run alongside the existing Highway 401 corridor. Ontario’s ongoing 401 widening is already consuming the road margin that alternative would need, section by section. Every year ALTO’s planning phase continues is a year in which that door narrows further — a real cost that doesn’t show up in any of ALTO’s published figures.

What’s Next

What’s in the rest of this report

This chapter has traced one argument in four parts: the corridor’s need is real (2.1); a modest upgrade became a much bigger project during procurement (2.2); the resulting project has four structural problems (2.3); and none of it can be fixed by refinement (2.4). The chapters that follow set out the alternative.

Ch. 3

The HPR alternative. How a passenger line built along the existing Highway 401 and rail corridor can free up freight capacity at the same time, instead of building an entirely new line elsewhere and leaving the freight problem untouched.

Ch. 4

Route and cost. Where the line would go and what it would cost, using the same cost model applied consistently to both ALTO and HPR.

Ch. 5

Environment and communities. How the two options compare on carbon emissions and disruption to the communities along the route.

Ch. 6

How many people would ride it. Ridership estimates built on the real-world pattern, checked four different ways.

Ch. 7

Running costs. The ongoing yearly balance between what it costs to operate and maintain the railway, and what fares plus any subsidy bring in.

Ch. 8

Is it worth it. A full cost-benefit and financial analysis across a range of scenarios, including the value of the freed-up freight capacity.

Ch. 9

Getting it built. How to phase construction, manage the risk of cost overruns, and keep the project accountable to the numbers in this report.

August 10, 2026

Ready to tender

Ready to Tender, Not Yet Approved

Cadence has opened the procurement for the first segment of ALTO — while its own notice says the project is not yet approved.

ALTO HSR Citizen Research Initiative · Procurement Brief · Published July 2026 · ALTO consultation closed April 24, 2026

⚠ What the document says

On June 23, 2026, Cadence — the private partner chosen to develop ALTO — published a Preliminary Notice to Market for the Ottawa–Montreal segment, the first part of the line to be built. It sets out the contracts, the delivery models, and a tendering schedule that starts this summer. Cadence PNM

The same notice states that construction has “no official launch date” and that the entire build-and-operate phase is “subject to the government of Canada’s final confirmation of the investment.” In other words: the machinery to build this is being switched on before the decision to build it — and the money to pay for it — has been confirmed.

The point in one sentence

You do not need an access-to-information request to see this one. It is a public document, unredacted, published by the developer itself — and on its own pages it does two things at once: it commits the construction industry to a two-year tendering calendar for the project’s biggest contracts, and it confirms that the project is not yet funded, not yet finally approved, and does not yet have a confirmed start date.

This is the same sequence this Initiative has documented at every earlier stage: the commitment comes first, the decision that would justify it comes later. What is new is that it is now happening in the open, in the developer’s own words, rather than in a briefing note released years after the fact.

None of this settles whether high-speed rail should be built. It is a question about order of operations — whether a project should be this far into procurement before the public analysis, the final business case, and the funding decision are in place.

Read the source

Cadence Preliminary Notice to Market — Central Segment

A public document (document no. ALTO-CPDP-00000-PW-080000-500BC10-000001F), issued June 2026 by Projet Cadence Rail s.e.c. Available in French and English.

Download PDF

What it is

A tender calendar, not a green light

A “Preliminary Notice to Market” is a signal to construction firms: here is the work that is coming, here is roughly when it will be tendered, start putting your teams together. Cadence is careful to say it is not a formal call for bids and not a commitment to buy anything. That caution is worth taking at face value — but it cuts both ways. The document is not a decision to proceed; it is the paperwork that gets the supply chain ready to proceed. And it is being issued now, ahead of the decision that determines whether there is anything to proceed to.

The notice is explicit about that gap. It says construction is “contemplated to begin in 2029–2030, although no official launch date has been confirmed,” and that the build-and-operate phase — the phase where the line actually gets built — happens only “subject to the government of Canada’s final confirmation of the investment.” Yet the tendering timetable it publishes does not wait for that confirmation. It begins in the summer of 2026.

Summer
2026

first major tender opens (trains), with stations and the Montreal tunnel to follow through 2027

Cadence PNM, Table 2

2029–30

construction “contemplated,” but with no confirmed start date

Cadence PNM

Not yet

federal investment decision — the build phase is “subject to” it

Cadence PNM

The order here is the whole story. Under any ordinary reading of how a public project should work, the sequence is: decide whether to build it, confirm the money, then tender the work. This notice runs two of those steps in parallel — the tendering starts while the decision and the money are still described, on the same pages, as outstanding.

The Two Columns

What the notice commits to, and what it leaves open

The clearest way to read the document is to line up what it treats as fixed enough to build a procurement schedule around against what it says is still undecided. Both columns are drawn from the same notice.

Treated as ready to tender	Still described as undecided
The contract packages. The notice sets out more than seventeen contract packages (WP1–WP17) — trains, signalling, stations, the Montreal access tunnel, two major bridges, and the track itself — each with a delivery model already assigned.	The final route. The “more precise corridor” is still promised for autumn 2026. For the Toronto–Ottawa segment, the notice leaves open the choice between a northern route through the Canadian Shield and a southern route through farmland — unresolved.
The timetable. A tender calendar running from summer 2026 (trains) through 2027–2028 (tunnel, bridges, civil works), package by package.	The start date. Construction has no confirmed launch date; 2029–2030 is described only as “contemplated.”
The delivery company. A dedicated entity, “InfraCo,” led by CDPQ Infra, is to be the contracting party for all the builders, with a second company, “OpCo,” to run operations.	The funding. The entire build-and-operate phase is “subject to the government of Canada’s final confirmation of the investment” — which the notice does not report as having been given.
The technical spec. Design speed of 320 km/h; full electrification; no level crossings; a twin-bore tunnel roughly 15 km long and 9 m wide under the Riviere des Prairies and Mount Royal into Montreal.	The business case. No final business case has been published. The government’s own answer to Parliament in June 2026 was that the cost-benefit, net-present-value, and 30-year subsidy figures are “not finalized.”

Read together, the two columns describe a project detailed enough to hand contractors a two-year work plan, and unsettled enough that its route, its price, its business case, and its go-ahead are all still open. Those are not usually true of the same project at the same time.

The Machinery

What is actually being tendered

The notice divides the first segment into more than seventeen work packages. Most people following this issue do not need the package numbers — but the shape of the list matters, because it shows how much of the hardest and most expensive work is being brought to market before its design is finished.

The trains and the systems come first

The first tender out the door, in summer 2026, is for the rolling stock — roughly 60 trainsets. The signalling and control systems follow in the autumn. These are network-wide contracts: they are written for the first segment but carry options to extend to the rest of the line later.

The tunnel and bridges are tendered before they are fully designed

The single most demanding piece — the Montreal access tunnel, a twin-bore ~15 km bore under a river and a mountain into the downtown — is brought to market on an early-involvement basis because its design and ground conditions are not yet settled. Two major bridges (the Riviere des Mille-Iles and the Ottawa River) are in the same position. The riskiest, priciest work is being tendered at the point where the least is known about it.

The benefit numbers arrive without a source

The notice repeats headline figures — $24.5 billion a year in GDP, more than 50,000 construction jobs, 5,000 operating jobs — with no study, method, or citation attached to any of them. They are stated as facts in a document whose own government has told Parliament the underlying cost-benefit analysis is not finished.

Who Runs It

Who is in the room

The notice confirms the structure of the group that would build and run the line. This is a matter of public record from the document itself; it is set out here as fact, not as accusation.

Cadence is a consortium. The notice names CDPQ Infra (the infrastructure arm of Quebec’s public pension fund) as the lead infrastructure and equity member, with Air Canada as an equity member; SYSTRA and AtkinsRealis as the design leads; and Keolis and SNCF Voyageurs as the operations leads. The new delivery company, “InfraCo,” would be led by CDPQ Infra and would sit above and contract with all the individual builders.

Two features are worth noting plainly, both straight from the document. First, the same consortium that is designing the strategy also sits atop the company that will award and manage the contracts — while the notice’s own rules bar consortium members from bidding on the major contracts and require engineering firms to take part “as subcontractors.” Second, Air Canada — the airline whose routes this train is meant to compete with — is an equity holder in the developer, a position the notice describes by reference to the airline’s experience linking its flights with rail in Europe. Readers can weigh what those arrangements mean; the point here is only that the developer’s own notice puts them on the record.

The Fine Print

Three things easy to miss

The contracts would be in English only

The notice contemplates publishing the major contracts in English only, with French “courtesy versions” available on request — a notable choice for a federal project running through Quebec and Ontario. It justifies this by pointing to the English-language agreement Cadence signed with Alto.

You may not talk to the people who run it — except through Cadence

Firms taking part in the procurement are told they “must refrain from any direct communication” with “Project Stakeholders” — a category the notice defines to include landowners and communities — except as Cadence permits, on pain of disqualification.

A federal law puts the project largely beyond local jurisdiction

The notice cites the High-Speed Rail Act, which declares the railway a “work for the general advantage of Canada.” That designation places the project under federal jurisdiction and applies provincial and municipal law only “to the extent that such laws may validly apply” — the mechanism that narrows what municipalities and provinces can require.

None of these is hidden. They are in the notice, in plain sentences. They are collected here because, together, they describe a procurement that is moving quickly, keeping tight control of who may speak to whom, and operating under a statute that limits local say — all before the funding decision the same document says is still to come.

Where things stand · July 2026

Summary ledger

Reading the notice against the question a citizen would reasonably ask — is this project actually decided? — here is where the document leaves things.

Under way

Procurement. Tendering for the first segment’s major contracts begins summer 2026 and runs through 2028.

Under way

Delivery structure. InfraCo (led by CDPQ Infra) and OpCo are to be set up as the contracting and operating companies.

Stated but unsourced

Benefits. $24.5B annual GDP, 50,000+ construction jobs, 5,000 operating jobs — asserted with no study or method attached.

Not yet done

Final route. The precise corridor is promised for autumn 2026; the Toronto–Ottawa north/south choice is left open.

Not yet done

Business case. No final business case published; the government told Parliament the cost-benefit, NPV, and subsidy figures are “not finalized.”

Not yet done

Start date. Construction has no confirmed launch date; 2029–2030 is only “contemplated.”

Not yet done

The go-ahead. The build-and-operate phase is “subject to the government of Canada’s final confirmation of the investment” — not reported as given.

The top of that list is moving. The bottom of it is not. A procurement this advanced usually means a project this decided — and by the developer’s own account, this one is not. The notice asks the construction market to get ready to build something the government has not yet committed to build, at a price no one has finalized, on a route not yet chosen. The reasonable question for anyone following this is not whether the train is a good idea. It is why the building has started before the deciding.

Sources

Primary documents

Projet Cadence Rail s.e.c., Preliminary Notice to Market / Avis préalable au marché — Alto Project Central Segment, document no. ALTO-CPDP-00000-PW-080000-500BC10-000001F, dated June 23, 2026 (cover) / June 22, 2026 (milestone table). A public document issued in French and English. All quotations and figures in this brief — the tender schedule (Table 2), the “no official launch date” and “subject to…final confirmation of the investment” language, the WP1–WP17 package structure, the InfraCo/OpCo and consortium structure, the 320 km/h and tunnel specifications, the English-only contract approach, the stakeholder-communication restriction, and the GDP and jobs figures — are drawn from this notice. citizenresearch.ca (PDF)

Government of Canada, response to Order Paper Question Q-1191 (Scott Reid, Lanark–Frontenac), House of Commons, tabled June 17, 2026 — source for the statement that the project’s cost-benefit, net-present-value, and 30-year subsidy figures are “not finalized.”

ALTO / Cadence, statements that a more precise corridor is to be unveiled in autumn 2026, referenced in the notice’s appendix and in prior public communications.

This brief summarizes a single public document in plain language. It does not argue that high-speed rail should or should not be built; it examines the order in which this procurement is proceeding relative to the decisions that would authorize it. A fuller treatment of the notice appears in the Initiative’s Accountability Record.

July 3, 2026

Freight and the Vanishing train

The Freight Dividend and the Vanishing Train

Alto’s own freight report builds its economic case on removing passenger trains from the shared Toronto–Montreal corridor — the same line VIA Rail runs through Eastern Ontario.

ALTO HSR Citizen Research Initiative · Research Brief · June 2026

⚠ Companion to “VIA Rail on the Kingston Subdivision”

In April 2026 we set out how Alto would foreseeably erode intercity passenger service on the Kingston Subdivision. Alto’s own June 2026 freight report now supplies the missing piece from the proponent’s side: a business case in which that erosion is not a risk to be managed but a source of value to be captured. Read the April brief →

The finding in brief

In June 2026 Alto published a report, High-Speed Rail and Freight Capacity (CPCS in association with HDR), whose central benefit is the capacity freed by lowering the number of passenger trains on the shared CN corridor between Toronto and Montreal — the Kingston Subdivision that carries VIA Rail through Oshawa, Cobourg, Belleville, Kingston, Brockville and Cornwall.

The benefit grows as passenger service shrinks. In the report’s own words it “would be shared between passenger and freight, depending on the level of passenger rail services that may be maintained on the CN corridor.” The party positioned to decide how much survives is Alto’s own development partner, the Cadence consortium — also slated to operate the corridor’s existing passenger trains. The risk falls squarely on VIA Rail.

The report is right about one thing: separating passenger and freight traffic relieves both. But Alto achieves that separation by removing the passengers. A dedicated passenger spine along the same corridor achieves the same separation while keeping the lakeshore served — the constructive alternative set out below.

↓ Download the full brief (PDF)

The Freight Report

What the report claims

The report’s stated purpose is to show how Alto could “generate economic and strategic benefits for freight rail by lowering passenger traffic on the shared corridor.” It documents that the Toronto–Montreal segment runs on CN-owned track with a passenger-to-freight mix close to 50-50, and that passenger trains — because of higher speeds and precise scheduling — consume more track capacity than freight trains.

From this it assembles a set of claimed freight benefits: deferred or avoided capital investment in the CN corridor; headroom to “protect for” 55 per cent higher freight volumes over 30 years; induced freight demand and mode shift; new rail-adjacent industrial development; and roughly $90 million a year in avoided societal costs from shifting one daily intermodal train off Highway 401. Every one of these flows from the same source: fewer passenger trains on the shared line.

The Mechanism

The benefit is the removal of passenger trains

The report is explicit that the enabling condition is fewer passenger trains, and it ties the size of the avoided-investment benefit directly to how much passenger service is cut: the benefit “would be shared between passenger and freight, depending on the level of passenger rail services that may be maintained on the CN corridor.” Read plainly, the fewer passenger paths retained on the Kingston Subdivision, the larger the freight benefit Alto can claim.

The report then treats the retreat of passenger rail as an inducement to development, suggesting that reducing the volume of passenger trains may signal to industry that rail-adjacent parcels have become more desirable. Yet the same report opens with a disclaimer that its introduction is “not assumed to result in the discontinuation of local passenger rail services.” These two positions cannot both hold at full strength: the benefit is defined as the capacity released by removing passenger trains, while the disclaimer promises they will not be removed. The gap is bridged only by soft language — and by recasting intercity trains as “local offerings” that feed the high-speed line.

Who Benefits, and How

Who gains from fewer VIA trains

Freight does gain — that much is the report’s central claim: CN, the freight railway, avoids the spending it would otherwise need to expand its own line. But CN does not decide how much VIA service survives, and it is not the only party that gains. The consortium positioned to make that decision, Cadence, runs no freight and earns nothing from it — its stake is in Alto. So the pressure to thin VIA’s service comes not from freight alone, but from four further interests the report’s framing keeps in the background.

Alto’s ridership depends on it

Cadence is paid to fill Alto, whose business case rests on very high ridership: a target of 24 million passengers a year by 2055 — roughly eight times the three million or so the corridor carries today. The only independent modelling of the route (University of Toronto’s Munk School) projects about 9 to 10 million, and a reference-class adjustment for the ~65 per cent overstatement typical of rail forecasts lands near 8 million. As a single concessionaire with no open-access competition, Cadence has every reason to price for yield, not volume — making a cheaper conventional train on the same corridor competition to be minimized, not preserved.

It makes the case for building Alto look better

The report’s headline “avoided investment” benefit is explicitly larger the more passenger service is cut, inflating the benefit-cost ratio used to justify the project — the very project that gives the consortium’s contract its reason to exist.

It lowers the subsidy the government pays

VIA Rail’s Toronto–Montreal corridor service ran an operating shortfall of about $117 million in 2025 — roughly $50 of public subsidy per passenger, at a corridor cost-recovery ratio near two-thirds (VIA Rail, 2025 Annual Report). Shrinking that service, or folding it into the Alto concession, reduces what the federal funder pays; the party deciding the corridor’s future is also the party writing that cheque.

It sheds the cost of using CN’s track

Passenger trains on the Kingston Subdivision run on CN-owned track under access and cost-sharing arrangements — including, as the report notes, payments to CN to maintain track at passenger speeds. Moving intercity trains onto Alto’s dedicated line sheds those payments.

The gains flow to Cadence, to CN, and to the federal treasury. VIA Rail — and the passengers between Toronto and Montreal — bear the loss.

The Consequence

The risk to VIA Rail

What Alto describes is two passenger railways on one corridor. A dedicated high-speed line, built and operated by Cadence, would carry the fast intercity market. What remains on the Kingston Subdivision — the trains that serve Oshawa through Cornwall — is left as a residual “local” service, running between freight trains on CN-owned track, with no committed frequency and no protected floor.

Under the project’s public-private structure, even that residual service is not assured to remain with VIA Rail: the existing corridor passenger operations, designated the “Local Services” in the procurement, are slated to pass to the same Cadence consortium as feeders to the high-speed line. And this is not a distant hypothetical. VIA Rail’s corridor on-time performance has already collapsed — from 72 per cent to 30 per cent inside a single year — as passenger trains are squeezed on infrastructure the operator does not own.

The National Dimension

The risk reaches the whole network

The danger does not stop at the lakeshore. The Quebec City–Windsor corridor is not merely VIA Rail’s busiest route — it is the financial engine of the entire national network. More than 90 per cent of VIA’s passengers, and about 80 per cent of its revenue, come from this one corridor (VIA Rail, 2025 Annual Report). That revenue is what helps sustain the long-distance and regional trains connecting the rest of the country — Vancouver and Prince Rupert, the Prairies, Churchill, and the Maritimes.

Hand the corridor’s ridership and revenue to a private consortium, and VIA is left, in the words of the federal NDP transport critic Taylor Bachrach, with “the crumbs” — a fraction of the revenue it uses to operate rail across Canada. Alto’s own answer is that corridor services will “eventually” be “integrated with Alto services into a single network”; asked what the loss of that revenue would mean for VIA, the proponent did not say. The choice being made on the busiest corridor, in other words, quietly decides the future of passenger trains in places thousands of kilometres away. CBC News reported the warning.

A Constructive Alternative

A straighter, quieter line

The freight report identifies a real prize: separating passenger and freight traffic on the Toronto–Montreal corridor relieves the mixed-traffic conflict that degrades both. The question is how that separation is achieved. Alto achieves it by removing the passengers — routing a 300 km/h greenfield line inland through Peterborough and Ottawa, past the lakeshore communities entirely, and leaving VIA’s corridor service to wither.

There is a straighter, quieter way to reach the same result. Build a dedicated, lower-speed passenger spine along the existing Toronto–Montreal transportation corridor — the lakeshore route the CN Kingston Subdivision and Highway 401 already follow. Give passengers their own tracks, engineered for reliable service at conventional-to-higher-performance speeds (up to about 200 km/h), and the passenger–freight conflict is resolved the same way — by separation — but without deleting the service the corridor’s communities depend on. The strong Toronto–Montreal market runs fast and reliably on the direct line; Ottawa and Quebec City are reached on upgraded existing track; and Kingston, Cobourg, Belleville, Brockville and Cornwall stay on the intercity network rather than being bypassed. The routing and demand-density case for this spine is set out in our companion brief, A Straighter Line. And because the spine stays in public hands, the fare revenue from the country’s busiest corridor keeps flowing to VIA rather than to a private concession — sustaining, rather than starving, the national network it helps fund.

Alto as planned	A dedicated passenger spine
A 300 km/h greenfield line detouring inland via Peterborough and Ottawa, roughly 900 km of all-new track.	A direct passenger line along the existing lakeshore corridor, far less new build, largely alongside the rail line and Highway 401 already there.
Cobourg, Belleville, Kingston, Brockville and Cornwall are bypassed entirely.	The lakeshore communities stay on the intercity network, served on the way through.
Today’s VIA corridor service is demoted to a residual “Local Service,” slated to the private concession, with no protected floor.	The corridor service is the spine — upgraded, reliable, and kept in the public interest.
Freight relief is delivered by removing passenger trains from the shared line.	Freight relief is delivered by giving passengers their own dedicated line within the existing corridor.
Operated by a single private consortium pricing for premium yield, with a $60–90 billion cost baseline.	Operated in the public interest at affordable conventional fares, at a fraction of the greenfield cost.
Corridor fare revenue flows to the private concession, weakening the cross-subsidy that helps fund VIA’s national network.	Corridor revenue stays in the public system, where it can keep supporting long-distance and regional service across Canada.

In plain language

The freight report is right that passengers and freight should not have to fight over the same tracks. But there are two ways to end that fight: take the passengers away, or give them their own line. Alto takes them away — and prices the loss as a benefit.

The alternative keeps the trains and separates the traffic: a dedicated passenger spine down the existing Toronto–Montreal corridor, reliable and affordable, serving the lakeshore towns Alto would leave behind. It delivers the genuine freight dividend the report identifies — without the vanishing train.

Sources

Primary sources

High-Speed Rail and Freight Capacity: Potential Freight Benefits of Alto (June 2026). Prepared for Alto by CPCS in association with HDR. Cited pages: 5, 6, 8, 11, 18, 19. Read the report.

VIA Rail on the Kingston Subdivision: Service Erosion, Funding Collapse, and the National Rail Risk from ALTO HSR (April 2026). ALTO HSR Citizen Research Initiative. Read the brief.

VIA Rail Canada, 2025 Annual Report — Toronto–Montreal corridor operating shortfall of roughly $117 million, per-passenger subsidy of about $50, and corridor cost recovery near two-thirds.

On the ridership targets: this Initiative’s ridership analysis, setting Alto’s stated 24 million (2055) and 43 million (2084) figures against the corridor’s current ridership of roughly three million; the University of Toronto Munk School (Global Economic Policy Lab) independent projection of about 9 to 10 million; and the reference-class forecasting literature (Flyvbjerg) finding rail ridership overstated by an average of 65 per cent.

On the operating model and the transfer of corridor “Local Services” to the private consortium: Government of Canada, “Canada is getting high-speed rail” (news release, 19 February 2025); Transport Action Canada, “Cadence wins $3.9B High-Speed Rail development contract” (2025).

On the national-network risk: A. Kurjata, “NDP warns privatizing high-speed rail from Toronto to Quebec could kill passenger trains in rest of Canada,” CBC News (19 February 2025) — corridor revenue as roughly 80 per cent of VIA’s total; MP Taylor Bachrach’s warning on cross-subsidy of national service.

A Straighter Line (June 2026). ALTO HSR Citizen Research Initiative — routing and reference-class demand-density analysis for the dedicated passenger spine.

June 30, 2026

Alto accountability

What We Know About ALTO’s Reporting and Accountability

A $60–90 billion Crown project, governed under the same regime as Canada Post.

ALTO HSR Citizen Research Initiative · Governance Brief · Published May 7, 2026 · Senate Finance Committee hearing on Bill C-15: February 4, 2026

Critical Finding

ALTO was created by Order-in-Council in 2022, as a wholly-owned subsidiary of VIA Rail. There is no enabling Act of Parliament establishing its mandate, powers, or reporting obligations. Under the Financial Administration Act, ALTO has been deemed a parent Crown corporation for reporting purposes — an administrative designation rather than an Act of Parliament. The framework that follows from this designation requires only summary-level reporting to Parliament, on Treasury Board’s timing.

This was confirmed on the Senate record by senior Transport Canada officials before the Senate Finance Committee on February 4, 2026, and by the Minister of Transport in his appearance before the Senate Transport and Communications Committee in December 2025. The two descriptions match. This is not a partial picture — it is the entire accountability architecture for the largest federal infrastructure project of the post-war period.

Download

ALTO’s Accountability Architecture — Full Brief (PDF)

Comprehensive analysis of ALTO’s governance, reporting obligations, contractual opacity, and the gaps documented in Senate testimony

Download PDF

The Structure

Three structural facts

Bill C-15 — the omnibus budget implementation legislation passed earlier this year — has granted ALTO the power to expropriate privately owned land for the high-speed rail corridor. The corporation that will exercise this power has the following structural characteristics, all of which are matters of public record.

$60–90B

public cost estimate, characterized by ALTO’s CEO as a working assumption

Imbleau, May 2 interview

enabling Acts of Parliament establishing ALTO’s mandate, powers, or accountability

created by Order-in-Council, 2022

Same

parliamentary reporting regime as Canada Post applies to ALTO

FAA Part X, by deemed designation

Most parent Crown corporations — Canada Post, the Bank of Canada, the CBC, VIA Rail’s older sister corporations — were established by their own enabling Acts. ALTO was not. It is a subsidiary of VIA Rail, which itself has no enabling legislation, and it was created through an Order-in-Council. The Financial Administration Act applies to it because the Order-in-Council deems it to apply, not because Parliament expressly decided that it should.

The Senate Finance Committee asked about this directly on February 4. The Transport Canada witness confirmed each of these facts on the record.

A further structural fact, less visible than the absence of an enabling Act but worth recording, is how ALTO’s directors come into office. Appendix 3 of the Corporate Plan Summary 2025–26 to 2029–30 confirms that directors are identified by the Board itself, recommended to the Minister of Transport, and then formally appointed by VIA Rail (ALTO’s sole shareholder) in consultation with the Minister. The Minister consults rather than appoints. The parent corporation appoints, but only candidates the subsidiary’s own board has nominated. ALTO’s directors are not Governor-in-Council appointees and do not appear in the public GIC appointments database. The board overseeing expropriation and $60–90 billion in proposed capital expenditure is, in appointment terms, substantially self-perpetuating.

The Reporting Architecture

What Parliament actually receives

Under the Financial Administration Act, every parent Crown corporation submits a corporate plan and an operating budget to its responsible minister, who forwards approved versions to the Governor-in-Council. Parliament receives a summary of the corporate plan and a summary of the budget. Treasury Board determines when those summaries are tabled. Annual reports are required and tabled. Parent Crown corporations may be called before parliamentary committees when summoned.

That is the regime under which a project with public cost estimates between $60 billion and $90 billion will be governed. The Transport Canada witness confirmed this framework before the Senate Finance Committee on February 4. The Minister of Transport described the same framework in his appearance before the Senate Transport and Communications Committee in December 2025.

Two Officials, One Framework

What senior officials have told the Senate

Set side by side, the two appearances — the Minister of Transport before the Senate Transport and Communications Committee in December 2025, and senior Transport Canada officials before the Senate Finance Committee on February 4, 2026 — describe a single, consistent reporting architecture. The fact that two separate officials, before two separate Senate committees, described the same framework in the same terms is itself a finding. There is no additional layer the public has not been told about. What follows is the entire accountability architecture as senior officials understand it.

Reporting Mechanism	What it Provides — in Officials’ Own Descriptions
Crown corporation status. The legal foundation for ALTO’s existence and reporting obligations.	ALTO is a wholly-owned subsidiary of VIA Rail, created by Order-in-Council in 2022. Because VIA Rail has no enabling Act, ALTO has none either. It is deemed a parent Crown corporation under the Financial Administration Act for reporting purposes. There is no legislated mandate, no statutory definition of its powers, and no statutory framework for its accountability. (Confirmed by the Minister before the Transport and Communications Committee, December 2025; and by the Transport Canada witness before the Finance Committee, February 2026.)
Corporate plan. The forward-looking strategic and financial document setting out what the corporation intends to do.	Submitted to the Minister of Transport for approval, then to the Governor-in-Council. Parliament receives a summary, not the full document. Treasury Board determines when the summary is tabled. The corporate plan itself has not been published.
Operating budget. The annual financial plan, central to public accountability for a project of this expenditure scale.	Submitted with the corporate plan. Parliament receives a summary, not the full budget. The summary’s level of detail is at the discretion of the responsible minister and Treasury Board.
Annual report. The retrospective accountability document covering the previous fiscal year.	Tabled in Parliament, as for all parent Crown corporations. Subject to the same disclosure standards as Canada Post and other established Crown corporations.
Committee appearances. The mechanism by which Parliament can question ALTO directly.	ALTO may be called before parliamentary committees, and has appeared before Senate committees on two occasions to date. Appearances are at the committee’s invitation; there is no scheduled or recurring appearance obligation specific to this project.
The ALTO–Cadence contract. Described in February 2026 testimony as the project’s first layer of accountability, including a gain-share, pain-share mechanism between the Crown and its private partner.	Not publicly available. When asked directly during the February hearing, the Transport Canada witness declined to provide the agreement, characterizing it as a commercial relationship.

The accountability framework that exists is not a sub-set of a larger framework. It is, on the consistent testimony of the Minister and his senior officials, the framework. There is no additional statutory mechanism that has been mentioned, alluded to, or held in reserve. Parliament knows what it knows, and that knowledge is summary-level, on a schedule controlled by the executive.

Currently Outside Public View

What is not in the public domain

Four documents that would, in a typical major federal infrastructure project, be in the public domain — or at least available to Parliament in unredacted form — are not currently available for ALTO.

The ALTO–Cadence agreement

The contract between ALTO and the consortium that will design and operate the high-speed rail system was described by the Transport Canada witness on February 4 as the project’s first layer of accountability, including a gain-share, pain-share mechanism between the Crown and its private partner. Asked directly whether the agreement is publicly available, the witness said it is not, characterizing it as a commercial relationship. The contract that the government has identified as the project’s primary accountability tool is itself unavailable for public scrutiny.

The financing structure

The public-private split has not been finalized. The Caisse de dépôt et placement du Québec and Air Canada have committed to equity participation in the Cadence consortium, but the magnitude of private investment relative to public funding has not been disclosed. ALTO’s chief executive has indicated that the published $60–90 billion cost figure is a working assumption rather than an estimate, with reliable cost estimates expected only in 2027 or 2028.

The ALTO corporate plan

The full corporate plan submitted to the Minister of Transport and the Governor-in-Council has not been published. Only summaries reach Parliament, on Treasury Board’s timing. For a project of this expenditure scale and physical footprint, the corporate plan is the central document setting out what the corporation will do, when, and at what cost. Its public unavailability is a structural feature of the FAA Part X regime, not an oversight.

The operational governance instruments

The Minister of Transport’s mandate letter to the Chair of ALTO, reproduced as Appendix 1 of the Corporate Plan Summary, identifies three operational accountability instruments by name: a Co-Development Charter setting out the government-approved parameters of the Initiative and including a Decision Matrix identifying “Designated Matters” that require ministerial or governmental approval before ALTO may proceed; a bilateral collaboration agreement between Transport Canada and ALTO; and a tripartite agreement among Transport Canada, ALTO, and VIA Rail. None of these three instruments is publicly available. The Financial Administration Act is published statute. The instruments that determine how it is applied to ALTO in operational practice are not.

Two Clarifications from the February Hearing

Corrections to the public record

Two points emerged from the February hearing that correct widespread misunderstandings about the project’s regulatory posture. Both were stated directly by the Transport Canada witness on the Senate record.

ALTO is not designated under Bill C-5

Bill C-5 — the Building Canada Act — established the Major Projects Office and its expedited federal review framework. Public reporting and political messaging have at times implied that ALTO is a designated project under this regime. The Transport Canada witness corrected the record on February 4: ALTO has been determined to be a transformative strategy, but it is not currently designated under Bill C-5 as a major Crown project. Whether it will be designated remains undetermined. As of the February hearing, it is not.

The corporation’s posture toward designation, however, is on the public record. Appendix 5 of the Corporate Plan Summary 2025–26 to 2029–30 identifies, as a formal risk-mitigation activity, “active representation to Government of Canada officials to ask to be designated a project of national interest under C-5.” The plan adds elsewhere that designation “would result in schedule changes and variances in Alto’s funding requirements.” The Crown corporation is on the record lobbying for a regulatory designation that would alter the impact assessment framework applicable to its own project. The channels, content, and recipients of that “active representation” are not disclosed.

The federal declaration is designed to displace provincial environmental assessment

Section 4 of the High-Speed Rail Network Act declares the railway to be for the general advantage of Canada. Asked why this declaration was necessary, the witness explained that without it, a provincial environmental impact assessment process might apply to segments wholly within one province — a regulatory uncertainty the legislation is designed to remove. The federal declaration is not, on the witness’s own account, a clarification of pre-existing federal jurisdiction. It is the active mechanism by which provincial environmental review of the corridor is foreclosed. For Eastern Ontario, the practical effect is direct: the Ontario Environmental Assessment Act will not apply to the southern corridor.

Why This Matters

Expropriation powers without proportionate oversight

Bill C-15 has granted ALTO expropriation powers — the authority to take privately owned land for the high-speed rail corridor. The Initiative’s research on the bill has established that this power, on the bill’s terms, can be exercised before the federal Impact Assessment process is complete; that a temporary notice of prohibition of work can attach to land that has not yet been formally expropriated; and that the federal expropriation regime has been adjusted in this legislation to align more closely with provincial practice.

A power of this magnitude, exercised on this scale, by a corporation without enabling legislation, with summary-only reporting on Treasury Board–controlled timing, with an undisclosed contract with a private consortium, is an architecture that needs strengthening — not because the officials involved are unprofessional, and not because the project is necessarily ill-conceived, but because expropriation of private property at this scale, with public expenditure at this scale, is precisely the situation that parliamentary oversight exists to govern.

The C-15 powers are not where ALTO’s legislative posture ends. Appendix 5 of the Corporate Plan Summary 2025–26 to 2029–30, under the Land Acquisition and Real Property risk category, lists as risk-mitigation activities “work with the Government of Canada on options to streamline legislative measures by adapting them to the Alto project context and reality” and “provide more efficiency and predictability with regards to the expropriation process.” The corporation that has just received expropriation powers under C-15 has placed on the public record its intention to seek further legislative refinement of those powers. The channels and content of that engagement are not disclosed.

The Senate Finance Committee’s questioning on February 4 made the gap visible on the parliamentary record. The Initiative’s research has documented the gap from outside Parliament. The two are now mutually reinforcing. What remains is for the gap to be addressed.

What the Initiative Is Calling For

Four steps that would close most of the gap

None of the following requires the project to be paused, cancelled, or fundamentally redesigned. Each is a discrete accountability commitment, available within Parliament’s existing authority, that would bring ALTO’s governance closer to the standard that other major federal Crown projects already meet.

Within Parliament’s authority now

Enabling legislation for ALTO An Act of Parliament establishing ALTO’s mandate, powers, and reporting obligations, replacing the Order-in-Council foundation. This brings ALTO into line with other parent Crown corporations of comparable scale and provides Parliament with a statutory anchor for future oversight.

Public release of the ALTO–Cadence contract With redactions only for genuinely commercial-sensitive information, on the model of routine federal procurement disclosure. The contract that the government has identified as the project’s first layer of accountability cannot serve that function while it remains sealed.

Standing committee actions

A Parliamentary Budget Officer review of the project’s economic case, including the benefit–cost ratio, the cost-estimate methodology, and the public-private financing assumptions. A senator has already raised this question with the Minister of Transport at the Transport and Communications Committee, where the Minister confirmed that the PBO is available to senators.

A standing committee study of the project’s governance and procurement architecture, addressing the gaps documented in the February hearing. Such a study can be initiated under existing Senate or House committee mandates without requiring legislative change.

Sources

Primary documents and proceedings

Standing Senate Committee on National Finance, Evidence, February 4, 2026 — subject-matter study of Bill C-15. Witnesses from Transport Canada High-Speed Rail Initiative. sencanada.ca

Standing Senate Committee on Transport and Communications, Evidence, December 2025 — testimony of the Minister of Transport on the High-Speed Rail Initiative. sencanada.ca/committees/trcm

Bill C-15, Budget Implementation Act, 2025, No. 1 — the High-Speed Rail Network Act is contained in Division 1 of Part 5. parl.ca

Financial Administration Act, R.S.C. 1985, c. F-11, Part X (Crown corporations). laws-lois.justice.gc.ca

Andrew Pinsent, “High-Speed Rail in Eastern Ontario: Rural Backlash, Land Expropriation and Next Steps,” CFRA / Substack, May 2, 2026 — carrying the Imbleau interview confirming acquisition footprint and working-assumption status of the cost figure. Substack

Order-in-Council establishing VIA TGF (now ALTO) as a wholly-owned subsidiary of VIA Rail, 2022. Order-in-Council records available through the Privy Council Office. orders-in-council.canada.ca

VIA HFR – VIA TGF Inc. (Alto), Corporate Plan Summary 2025–26 to 2029–30. Tabled summary of the corporation’s corporate plan under Part X of the Financial Administration Act. Source for the board appointment mechanism, the C-5 active-representation language, the expropriation legislative-streamlining language, and the three named operational accountability instruments. altotrain.ca

May 7, 2026