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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
Six questions ALTO can answer today
The letter makes commitments specific enough to be checked. None of the following requires a finalised route.
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.
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.