Tag: HS2

Where you put a railway

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

Where you put a railway decides almost everything else

Build beside a highway that already exists, or cut a new line through open country. That single choice sets the carbon, the habitat damage, the disruption during construction and the opposition — and it sets the cost too.

Chapter 5 · The HPR Research Report · September 2026

−15 Mt

Carbon removed over fifty years by the brownfield route, on our model

+15 Mt

Carbon added over the same period by the greenfield route

29 v 65

Community friction scores, brownfield against greenfield

The environmental case for a railway is usually made with one number: the carbon saved by taking people out of cars and planes. That number matters, and we deal with it first. But the bigger environmental fact about a railway is decided before a single train runs — by where the line is put.

A route that follows an existing transport corridor inherits ground that has already been cleared, drained, fenced and cut through. A route driven across open country creates a new line of disturbance where there was none. The same choice governs the human side: whether a project takes its land from beside a highway people already live next to, or from farms and communities that never expected a railway.

This page covers the four consequences that follow from that one decision. On each of them the two routes differ not by a margin but in kind.

1. Carbon: the two routes have opposite signs

Over fifty years the brownfield route is a net removal of carbon. The greenfield route, measured the same way, is a net emitter. Not smaller — opposite.

Three things drive that. Construction carbon is the one-off emission of building the line. Building at grade beside an existing highway needs no tunnelling through the Canadian Shield, no deep cuts, and no treatment of the unstable marine clay south of Ottawa. Our estimate is 4.9 Mt for the brownfield line against 14.9 Mt for the greenfield one — roughly three times more.

Running the trains turns out to be almost a rounding error either way. On Ontario’s grid, electric traction at 200 km/h emits about 6 grams of carbon per passenger-kilometre.

Freight is what decides it. A passenger line built beside the existing freight railway frees capacity on that railway. Every long-haul truck that moves off Highway 401 onto rail saves about a quarter of a tonne of carbon on a typical haul. At 3,000 trucks a day — about eight freight trains — that is roughly 13.5 Mt over fifty years. The greenfield route has no freight function, so it cannot claim any of it.

Fifty-year carbon balance — our estimate, central case
What counts	Brownfield (electric)	Greenfield
Building it	+4.9 Mt	+14.9 Mt
Running the trains	+1.3 Mt	+5.4 Mt
Roads closed by fencing	—	+1.7 Mt
Trucks moved to rail	−13.5 Mt	none
Passengers out of cars	−7.9 Mt	−7 Mt
Net over 50 years	−15.2 Mt	+15 Mt

Both columns are Initiative estimates, not published figures. A dash means the project structurally has no such term. The two routes differ in length — roughly 485 km against roughly 1,000 km — which is itself part of the comparison, because the longer line is the heavier one to build.

Why the freight credit matters so much

The carbon saved by taking a passenger out of a car shrinks every year as more cars become electric. By the 2050s it is close to nothing. The carbon saved by taking a truck off the road and putting the load on a train does not shrink the same way, because trucks stay diesel far longer — and it grows as the electricity grid gets cleaner.

So the brownfield route’s carbon case rests on something that strengthens with time. The greenfield route’s rests on something that weakens.

That shows up most clearly in how long each takes to pay back its construction carbon. The brownfield line breaks even in 12 to 18 years and stays in credit after that, and the timing barely changes with passenger numbers because freight carries it. The greenfield line depends entirely on passengers: about 22 years at the ridership its reference class suggests, 39 years at a more central figure, and at low ridership it does not break even within fifty years at all.

2. Habitat: a new barrier in the wrong place

A railway is a barrier to animals. Where you put the barrier decides whether it cuts through habitat that is still whole, or adds one more strand to ground that is already crossed by a highway and a freight line.

The greenfield alignment runs through or beside three of eastern Ontario’s most sensitive landscapes.

The Frontenac Arch

A billion-year-old granite ridge linking the Canadian Shield to the Adirondacks, a UNESCO Biosphere Reserve since 2002, and the narrowest point on the wildlife corridor running from Algonquin to the Adirondacks. It holds Blanding’s turtle, the grey ratsnake, the eastern whip-poor-will and somewhere between half and two thirds of Canada’s cerulean warblers, along with fisher, black bear, moose and eastern wolf.

Because it is already the tightest pinch-point in a continental corridor, a new barrier laid across it does disproportionate harm. It does not just disturb habitat; it narrows the last gap animals still move through.

The Napanee Limestone Plain

Alvar — flat limestone pavement with almost no soil, flooded in spring and parched in summer. It exists in only two places on Earth, the Great Lakes basin and the Baltic, and about 85 per cent of North America’s alvar is in Ontario. It supports part of Ontario’s remaining eastern loggerhead shrike population, a bird now down to a handful of nesting pairs province-wide.

A brownfield route is not ecologically free. Its right-of-way still crosses natural land. The point is comparative: it adds a strand where a barrier already exists, rather than opening a fresh one through the ground that the biosphere designation exists to protect.

We say that plainly because it matters. The corridor audit in Chapter 4 finds the brownfield spine still crosses about 41 per cent natural cover. It is not a route through nothing. It is a route through ground that a four-lane highway and a Class I freight main already run down.

3. Construction: where the trucks go

A 479-kilometre construction site has to be fed. The brownfield spine needs roughly 9.8 million tonnes of fill, ballast, track and concrete — about 20,400 tonnes for every kilometre built. Delivered entirely by road, that is around 390,000 loaded truck trips, running on the same Highway 401 the railway is being built beside, during the decade that highway is itself being widened.

Britain has already run this experiment. HS2 moved more than 10 million tonnes of material by rail, and the reason it did is the instructive part: it was not a carbon measure. Local councils refused the lorry routes the project had planned. Moving material by train was how the works stayed consented.

The honest size of the carbon saving

Moving 60 to 80 per cent of the material by rail instead of road would avoid somewhere between 0.05 and 0.08 Mt of carbon. That is one to two per cent of the line’s construction emissions. It is a real saving and a small one, and the carbon case on this page does not rest on it.

What it changes is something else: whether people along the route can live with the construction. That is the variable that decides whether a corridor gets built at all.

And this is not a strategy a project can simply decide to adopt. It is a property of where the line is. A route beside an existing freight railway has yards at Belleville, Kingston, Brockville, Cornwall and Coteau available as railheads, and on the Ottawa legs runs on publicly owned track. A greenfield route through the Frontenac Arch has no railway to deliver to. Materials arrive by road on haul roads built for the purpose, and excavated rock leaves the same way, through the same rural communities.

4. Communities: friction is priced into the cost

We score this two ways. The Latent Friction Index measures the structural friction a route will generate, before any opposition has appeared. The Community Friction Index measures opposition that has actually materialised. On the forward measure the brownfield spine scores about 29 and the greenfield corridor about 65. On the realised measure the greenfield project has already reached 54, and is rising.

This is not only a political point. In our reference-class cost model, community friction is a statistically significant predictor of cost escalation — it carries most of the explanatory power in what a kilometre actually costs to build, across the international sample. The friction a new corridor generates gets priced into the bill.

A low-friction route is not just quieter. It is cheaper, and those are the same fact seen from two sides.

The difference comes down to where the land is taken from. Both routes need new land; a railway cannot be laid inside a live highway. But land taken beside an existing highway and freight line is already fragmented, already severed, and already next to infrastructure. Land taken across open country is none of those things, and the people it is taken from had no prior relationship with the project.

One thing that cuts the other way

The margin beside Highway 401 that makes the brownfield route cheap is being consumed — by interchange development, logistics parks moving east, subdivisions at growth centres and utility lock-in. Chapter 4 puts the cost of waiting until the corridor fills in at around $20 billion, which would roughly halve the route’s benefit-cost ratio and erase the advantage that is the reason to prefer it.

The brownfield option is the low-friction one, but only while the window is open.

5. What the corridor could give back

Everything above treats the corridor as something done to the land it crosses. There is a reciprocal question worth asking.

Against the intuition that Ontario’s sun improves as you go south and west, the province’s strongest solar yields are in the east. Kingston records about 1,194 kilowatt-hours per installed kilowatt per year and Ottawa about 1,140, against roughly 1,096 for Toronto and 1,084 for London. The railway is proposed through the sunniest ground in southern Ontario — and developers noticed first. Four ten-megawatt solar farms stand within a few kilometres of the 401 around Ingleside alone — Rutley, Cornwall, David Brown and South Stormont, built between 2012 and 2015 — and at Edwardsburgh Cardinal a partnership including the Algonquins of Pikwàkanagàn First Nation is building the largest battery storage system in Canada.

This matters for a reason that has nothing to do with electricity. A right-of-way takes a strip of land and pays for it once. A generation lease pays on the land that remains, every year, for decades. The awkward leftover parcels created by a railway are poor ground for crops and perfectly good ground for solar panels. The Rutley farm gives a sense of the scale: ten megawatts across about ninety acres.

Being clear about the numbers

The contracts that built the existing solar farms paid up to 44.3 cents a kilowatt-hour and are closed to new entrants. At today’s rates a ten-megawatt facility earns closer to a million dollars a year than the five to seven million those contracts paid. The existing arrays are a poor guide to what a new one is worth.

A million a year through a lease and a tax roll is still a different thing from a single expropriation cheque.

The limits deserve stating as plainly as the opportunity. Solar output peaks in summer and stops at night, while a railway’s demand is flat and year-round — so this is a commercial and community proposition, not a way to power trains. Provincial policy restricts ground-mount solar on prime farmland. Connection capacity governs what can actually be built. None of that is a reason to leave it unexamined; it is a reason to examine it while the route is still being decided, rather than after the land has been taken and the relationships have set.

How to read the numbers on this page

Figures attributed to a named source — Alto, HS2, the C.D. Howe Institute, Metrolinx, Environment and Climate Change Canada, the Treasury Board, Natural Resources Canada, UNESCO, or a named developer — are quoted from the full chapter’s source lists and can be checked there.

Everything else is output from our own models: both columns of the carbon table, the freight credit, the breakeven years, the friction scores, the land-cover audit, the materials tonnage and the delay-escalation estimate. These are estimates built on stated assumptions, not measurements. The assumptions are set out in the full report so that any of them can be replaced and the arithmetic re-run.

Where Alto has not published a figure, we say so rather than inferring one, and we make no claim about why any figure has not been published.

Read the full chapter

Chapter 5 — Environmental and Community Impact (PDF)

Nineteen pages. The full lifecycle carbon account with its discount-rate sensitivity, the traction comparison including bi-mode trainsets, the species and habitat assessments, the materials-by-rail analysis against HS2 outturn, the friction indices, the corridor solar assessment, and the complete source lists for each section.

Sources and notes

1Discount rates: Metrolinx Business Case Manual Volume 2 (3.5 per cent); Environment and Climate Change Canada, social cost of greenhouse gas emissions (2 per cent near-term Ramsey rate); Treasury Board of Canada Secretariat, Canadian Cost-Benefit Analysis Guide: Regulatory Proposals (8 per cent); US Office of Management and Budget Circular A-4, revised November 2023, in which the 7 per cent capital rate was withdrawn.

2C.D. Howe Institute, All Aboard: The Benefits of Faster, More Frequent Passenger Trains between Ontario and Québec (D. Jones and T. Fariha), February 2025 — 3.5 per cent social discount rate over a 60-year appraisal, and the only published benefit analysis of this corridor.

3Habitat: UNESCO Man and the Biosphere Programme, Frontenac Arch Biosphere Reserve; Birds Canada, cerulean warbler profile; COSEWIC and Environment and Climate Change Canada recovery strategies; Important Bird and Biodiversity Areas Canada, Napanee Limestone Plain (ON152); Wildlife Preservation Canada, eastern loggerhead shrike. Initiative assessments of the Frontenac Arch (A. Hyett) and the Napanee Limestone Plain (S. Moore and K. Hennige), March 2026.

4Materials by rail: HS2 Ltd, Materials by Rail, HS2 Learning Legacy, and HS2 media releases 2020–2023; Crossrail Excavated Materials Story; Railway Association of Canada on rail fuel efficiency.

5Solar: Natural Resources Canada photovoltaic potential data; Canada Energy Regulator market snapshot; Firelight Infrastructure Partners, Saturn Power and Clearlight Energy project data; The Energy Mix on the Skyview 2 storage project at Edwardsburgh Cardinal.

Coalition for Better Rail · ALTO HSR Citizen Research Initiative · beyondalto.ca · citizenresearch.ca · The HPR Research Report · Chapter 5 Independent, non-partisan research on Canada’s proposed Toronto–Québec City high-speed rail corridor. This page is a plain-language summary of Chapter 5; the full chapter sets out the models, the tables and the complete source lists. Nothing on this page is a statement about the motives or conduct of any person or organisation. It is a comparison of two route choices and of what follows from each.

September 5, 2026

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

50000 jobs

ALTO HSR Citizen Research Initiative · Plain Language Brief

Where do 50,000 jobs come from?

Alto says building the railway will support about 50,000 jobs. We checked that figure against two railways that publish both what they spend and who they employ.

September 2026

50,000

Jobs Alto says the project will support during construction. Its report defines the figure once, in an appendix.

~18,000

People actually working on the railway, on our estimate, at Alto’s own budget and schedule.

The number is not wrong. It is a standard output of a standard economic model, and when we rebuilt it from scratch we got almost exactly the same answer. But roughly two thirds of it is not people building a railway, and Alto’s report says so in only one place.

What Alto says

Alto’s report Canada’s Moment: The Economic Opportunity of High-Speed Rail, published in August 2026, says the Québec City–Toronto line will support approximately 50,000 jobs while it is being built, and more than 5,000 once it is running. The figure has been repeated in federal announcements and in news coverage since. Almost everywhere it appears, it appears on its own: 50,000 jobs during construction.

An earlier version of the number was slightly different. The federal announcement of 19 February 2025 gave over 51,000 jobs and a GDP gain of up to $35 billion a year. Transport Canada was still publishing that pairing in its 12 December 2025 release. Canada’s Moment, eight months later, gives 50,000 jobs and $24.5 billion. The report does not explain the difference between the two GDP figures, which is about 43 per cent.

What the report actually says

Further into the report, in section 4.3.3 and in two identical tables — Table 7 in the body and Table A4 in the appendix — the figure is described much more fully. There it is:

50,000 full-time equivalent jobs. A full-time equivalent is work converted to a standard full-time measure. It is not a count of people.
Spread across a ten-year construction period.
Three kinds of work counted together. Direct work on the project; supply chain work at the firms that supply it; and induced work, meaning jobs supported when those workers spend their wages in shops, restaurants and everywhere else.
Produced by the 2019 Statistics Canada input-output model. This is a standard tool that estimates how spending in one part of the economy ripples through the rest of it.
Labelled an upper estimate.

The appendix is careful about what this does and does not mean. It says the results describe economic activity supported by spending rather than a net gain to the country. It leaves them out of the project’s benefit-cost ratio. And it notes that the method does not allow for labour shortages or other limits on how much the economy can absorb.

That is a fair and reasonably candid description. The difficulty is where it sits. Those two pages of an eighty-four page report carry it, and nothing else does. The summary at the front, the table comparing high-speed rail with the alternative, Alto’s website, the government announcements and the news coverage all carry the number without any of it.

The number reaching the public is not the number the appendix defines. It is the same figure with its definition left behind.

How we checked it

Two railways publish both halves of the equation — how much they spend in a year, and how many people that spending puts to work.

HS2 in Britain publishes audited capital spending and a programme workforce figure every year.
The Réseau express métropolitain in Montréal, built by CDPQ Infra, published a jobs claim and periodic counts of workers on site. It is also the closest match anywhere to the way Alto has been set up.

Both land in the same place: roughly 2,200 to 3,300 people working for every billion dollars spent in a year.

Alto’s own published figures are $60 to $90 billion of capital over ten to fourteen years. That works out to $4.3 to $9.0 billion a year, which is around half the rate HS2 is spending at present. Applying the observed rate from those two projects to Alto’s own budget and schedule gives 13,000 to 21,000 people working on the programme in the central cases, and a ceiling near 30,000 if the project spends at the top of its range on the fastest possible build.

We then rebuilt the whole 50,000 the way the appendix says it is built — adding supply chain and induced work on top of the people on site, using standard multiplier ratios.

Rebuilding the 50,000 — ten-year build at the top of Alto’s capital range
Layer	What it means	People
Owner and engineering	Alto’s own staff and the designers	700 – 2,000
Site and contractor	People building the railway	16,000 – 17,300
Supply chain	Staff at firms supplying the project	14,400
Induced	Jobs supported when those wages are spent	18,200
Total	Alto publishes 50,000	50,600

Initiative estimate, built from HS2 and REM published spending and workforce figures and standard supply-chain and induced multiplier ratios, applied to Alto’s own published capital range and schedule.

What the check found

50,600, against Alto’s published 50,000. The two agree to within one per cent, using the same three categories Alto names in its own appendix, by a route that borrows nothing from Alto’s model. On that basis the figure stands up as an output of the model that produced it.

What the agreement also does is fix what is inside the number. On Alto’s own budget, roughly 18,000 of the 50,000 are people working on the railway. The rest — nearly two thirds — are jobs at supplier firms and jobs supported when wages are spent again. Fewer than four in ten are on the railway itself.

A second and completely separate check gives the same answer. Direct labour usually accounts for 30 to 40 per cent of spending on heavy civil construction. Applied to $75 billion over ten to twelve years, at a fully loaded cost of $100,000 to $140,000 per worker-year, that supports somewhere between 13,400 and 30,000 people, centred near 19,000. Two methods that share no inputs bracket the same range.

The other way of reading it

Turn the question round and the arithmetic bites. If 50,000 really meant 50,000 people working on the railway, the project would need to spend $15.2 to $22.7 billion every year — a programme of $152 to $273 billion, against the $60 to $90 billion Alto has published. That is close to the $142 billion the Initiative’s own cost model predicts for this corridor. On the arithmetic set out here, Alto’s employment claim implies a more expensive railway than the one Alto has costed.

The question the report leaves open

“50,000 full-time equivalent jobs during a ten-year construction period” can be read two ways. It can mean 50,000 full-time equivalents working in each year of the decade. Or it can mean 50,000 years of work in total, spread across the decade. The two readings are ten times apart, and the report does not say which is meant.

Only the first works arithmetically. The second would put the project at 0.67 job-years for every $1 million spent, against 2.6 at HS2 and 2.6 to 3.3 at the REM — roughly a quarter of the labour intensity of any comparable railway now being built. So this analysis treats the figure as an annual average, which is the reading that makes it defensible. A reader has no way to know without being told.

Two more things in the tables

Upper, not central

Both tables head their value column “upper estimate”. One appendix earlier, the $24.5 billion GDP figure is labelled a central estimate, drawn from a stated range of sensitivity tests. So a range exists behind the 50,000 as well. What has been published is its top. The Initiative has recorded the same pattern twice before in this report: ranges that appear in the commissioned studies but not in the public summaries.

The comparison figures have no source

Table 2 sets high-speed rail against the alternative, “high-frequency rail”, and credits that alternative with 44,000 construction jobs at a capital cost of $45 to $75 billion. Neither figure carries a footnote, a source or a method anywhere in the document. The implied job intensity is internally consistent with the high-speed figures, so the numbers do not look wrong. The point is that a reader has no way to check them.

This has been released before

Employment modelling for this corridor has been published once already, and what happened to it is worth knowing. The Joint Project Office — VIA Rail and the Canada Infrastructure Bank — produced a business case for High Frequency Rail, the slower predecessor to this project, in December 2021. It gives construction employment as 71,000 to 96,000 annual equivalent jobs. That is a third unit of measure again, different from Alto’s 50,000 and from the 51,000 in the 2025 announcement, but stated plainly enough that a reader knows what is being counted.

The Canada Infrastructure Bank released that document in full in November 2025. The same document, released under a separate access request, cuts the identical sentence: “an estimated ___ annual equivalent jobs could be created,” with the sentence left grammatical around the missing number and no exemption provision marked against it. We hold both versions.

So the same employment figure, for the same corridor, has been treated as releasable by one federal body and withheld by another. That is worth putting on the record now, before anyone argues that the modelling behind the 50,000 is too commercially sensitive to publish.

What we are asking Alto to publish

Alto holds all of this already. None of it would cost anything the organisation does not have.

Whether the 50,000 is an annual average, or a cumulative count of full-time-equivalent years.
How it splits across the three categories Table A4 names: direct, supply chain and induced.
The range the upper estimate was drawn from, and the central value within it.
The year-by-year profile across the ten-year construction period.
The assumption made about imports and Canadian content in the input-output run.
The capital and operating spending profile that was fed into the model.
The source of the 44,000 jobs and the $45 to $75 billion attributed to high-frequency rail in Table 2.

And, more simply than any of that: carry the appendix definition alongside the number, wherever the number appears.

How to read the numbers on this page

Every figure attributed to Alto, HS2, CDPQ Infra, the California High-Speed Rail Authority or a Government of Canada release is quoted from the published source listed below, and can be checked there.

Every other figure on this page is a calculation by the Initiative from those published inputs, and is described as an estimate where it appears. The reconstruction is an estimate rather than a measurement: it applies labour intensity observed on two comparator projects, together with standard supply-chain and induced multiplier ratios, to Alto’s own published capital range and schedule.

Where Alto has not published something, this page says so rather than inferring it, and makes no claim about why any particular figure was or was not published.

Read the full paper

50,000 Jobs? — the research paper (PDF)

Ten pages. Sets out the method in full, the year-by-year spending and workforce figures for HS2 and the Réseau express métropolitain, the layer-by-layer reconstruction, the job-years-per-dollar comparison against California and the US Federal Highway Administration, and the complete source list.

Sources and notes

1Alto, Canada’s Moment: The Economic Opportunity of High-Speed Rail, August 2026. Section 4.3.3 and Tables 7 and A4 (50,000 full-time equivalent jobs across direct, supply chain and induced effects, ten-year construction period, upper estimate; $86 billion value added; $23 billion tax revenue). Appendix A.2 methodology box (2019 Statistics Canada input-output model; static; excluded from the benefit-cost ratio; no account taken of labour shortages or capacity limits). Table A2 ($24.5 billion GDP, central estimate). Table 2 (44,000 construction jobs and $45 to $75 billion capital for high-frequency rail, unsourced). Section 4.3.3 sidebar (Canadian materials commitment).

2Prime Minister of Canada, news release, 19 February 2025 (over 51,000 jobs during construction; GDP gain of up to $35 billion annually).

3Transport Canada, news release, 12 December 2025, naming Ottawa–Montréal as the first segment (51,000 jobs during construction; up to $35 billion in GDP).

4HS2 Ltd, Annual Report and Accounts 2022–23 to 2025–26 (capital expenditure and workforce), and six-monthly reports to Parliament, December 2024, July 2025 and May 2026 (jobs supported, supply chain businesses, spend to date, cost range and schedule).

5CDPQ Infra, REM fact sheet and project pages; REM news releases of April 2018, November 2020 and June 2021 (34,000 jobs; over 30,000 direct and indirect jobs; more than 2,000 and then more than 3,000 workers on site).

6California High-Speed Rail Authority, economic impact analyses for FY2023–24 and FY2024–25, and the March 2024 release on construction jobs and daily dispatch.

7US Federal Highway Administration, Employment Impacts of Highway Infrastructure Investment (13,000 job-years per US$1 billion; 64/36 split between direct-and-indirect and induced).

8Exchange rates: Bank of Canada daily rates, 1 September 2026. 1 GBP = C$1.8795; 1 USD = C$1.3896. Per-kilometre cost comparison uses the Initiative’s own ECI/CFI cost model.

ALTO HSR Citizen Research Initiative Independent, non-partisan citizen research on the proposed Toronto–Québec City high-speed rail corridor. This page is a plain-language summary of the research paper 50,000 Jobs?, September 2026. The full paper sets out the method, the tables and the complete source list. Nothing on this page is a statement about the motives or conduct of any person or organisation. It is an analysis of published figures and of what those published figures do and do not say.

September 5, 2026

Procured and then

ALTO HSR Citizen Research Initiative · Brief · September 2026

Procured, and Then?

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

Independent, non-partisan research · citizenresearch.ca

In Plain Language

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

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

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

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Procured, and Then? (PDF)

The full brief, with sources

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Related

HPR Research Report, Chapter 1

The forecasting framework this brief applies, set out in full

Read Chapter 1

01 · The Instrument

ALTO commissioned the outside view

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

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

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

02 · The Question

Buying the instrument is not the same as letting it bind

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

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

A test, not an accusation

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

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

03 · The Clock

The record will arrive after the decision has moved on

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

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

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

Why timing decides this

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

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

04 · The Benefit Case

Two studies, no cost side

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

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

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

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

Adverse mechanisms are identified but do not reach the total

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

The two studies disagree, and each resolves the disagreement upward

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

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

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

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

05 · The Ask

Publish the comparison

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

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

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

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

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

How to read this brief

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

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

Sources

Documents relied on

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

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

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

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

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

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

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

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

September 2, 2026

Bound before briefed

City of Kingston: Bound Before Briefed

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

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

⚠ Update · The agreement has been signed

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

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

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

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

Critical Finding

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

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

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

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

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

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

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What was signed

“This is not optional”

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

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

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

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

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

Part One · The mechanism

Access conditioned on silence

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

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

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

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

Part Two · The scale, and the creep

Four agreements became three hundred and thirty-nine

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

confidentiality agreements signed in 2012–13, at the outset

HS2 Ltd, via FOI

112

signed in 2018 alone, as the practice took hold

HS2 Ltd, via FOI

339

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

Hansard

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

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

The creep has already begun here

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

Part Three · The terms

Twenty-six of twenty-eight had no end date

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

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

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

Part Four · Both sides, fairly stated

The promoter’s case, and what the record shows

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

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

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

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

Part Five · The independent verdicts

What Britain concluded, in public, before Kingston signed

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

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

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

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

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

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

The culture did not stay in its lane

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

Part Six · The neighbours

The same request, refused twice next door

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

United Counties of Prescott and Russell — refused, May 2026

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

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

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

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

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

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

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

The choice Kingston was offered is not a real choice

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

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

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

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

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

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

Part Seven · Where things stand

Five questions, one answered

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

Answered

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

Unanswered

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

Unanswered

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

Unanswered

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

Unanswered

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

Outstanding

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

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

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

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City of Kingston: Bound Before Briefed (PDF)

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

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The English record

The confidentiality did not protect HS2

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

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

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

How to read this brief

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

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

Sources

Primary documents and reporting

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

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

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

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

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

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

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

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

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

10.

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

11.

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

12.

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

13.

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

July 14, 2026

Reading Lovegrove

Reading Lovegrove

What the UK Cabinet Office’s review of the HS2 Civil Service failures tells us about ALTO.

ALTO HSR Citizen Research Initiative · Governance Brief · Published May 2026

⚠ New UK Cabinet Office Review Published

In May 2026 the UK Cabinet Office published a review by Sir Stephen Lovegrove — former National Security Adviser and former Permanent Secretary of the Ministry of Defence — into how the British Civil Service failed to identify and act on the deterioration of HS2 before its costs reached £82.2 billion for the London–Birmingham section alone. The review is short, unusually candid, and addresses the institutional architecture Canada is now using to deliver ALTO. gov.uk

The Lovegrove Review is not about why HS2 went wrong as an engineering project. Its purpose is to explain how a senior G7 civil service, with all the oversight tools a Westminster-system government has, failed to see the disaster coming. That makes it directly relevant to the question Canadians need to ask about ALTO.

Critical Finding

The Lovegrove Review documents a four-fold real-terms increase in HS2 Phase 1 costs between 2012 and 2026 — from £20.5 billion to £82.2 billion in constant 2019 prices — on a 225-kilometre stretch of railway. A directly parallel Canadian cost-escalation trajectory has already occurred on the corridor ALTO now proposes to serve: from under C$5 billion for the abandoned High Frequency Rail option in 2016 to C$80–120 billion for ALTO as confirmed in February 2025, a sixteen-to-twenty-four-fold increase within a decade.

Three Lovegrove findings translate directly to ALTO. First, the corporate form of an arm’s-length delivery body funded entirely from the public purse — HS2 Ltd in the UK, ALTO HSR Inc. in Canada — is, in Lovegrove’s words, “fundamentally ill-suited to this type of arrangement” because the commercial disciplines the corporate form is supposed to deliver do not flow from grant-in-aid funding alone. Second, HS2 Ltd’s board and executive developed a “fortress mentality,” becoming cheerleaders for high-speed rail rather than rigorous delivery managers — a pattern the CRI has been documenting in ALTO’s recent public outputs. Third, and most directly applicable: external reviews must not substitute for official advice on alternative ways of delivering a project before a Final Investment Decision.

The Lovegrove Review also contains an unusually explicit vindication of dissenting analysis. Lord Berkeley’s January 2020 dissent from the Oakervee panel was dismissed at the time as methodologically unsound. Six years later, the Cabinet Office writes that the thrust of his judgements has proved correct and his estimates closer to today’s outturn than those on which ministers gave the go-ahead. This is the most authoritative G7 government statement to date on the credibility of structured citizen reference-class analysis in high-speed rail governance.

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Reading Lovegrove — Full Brief (PDF)

Detailed analysis of the Lovegrove Review’s findings and their direct application to ALTO’s current trajectory

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A Published Reference Class

The cost trajectory the UK Cabinet Office published this month

The single most useful artefact in the Lovegrove Review is its published trajectory of HS2 Phase 1 cost estimates over time, all expressed in a 2019 price base for comparability. Phase 1 is the London to West Midlands section of approximately 225 km — the only section now being constructed, after the cancellation of Phase 2 north of Birmingham.

Year Phase 1 cost estimate (£bn, 2019 prices)

2012 20.5

2013 26.8

2020 44.6

2023 54

2024 66

2026 82.2

In 2019 prices, the 2026 estimate is more than four times the 2012 estimate for the same 225 km of railway. The increase from 2024 to 2026 alone — two years — is larger than the entire original 2012 budget. This is not a critic’s estimate. It is not an academic reconstruction. It is the British government, today, publishing the official trajectory of its own project’s cost.

For ALTO, the importance of this trajectory is twofold. The comparator is not ancient: HS2 Phase 1 was at roughly the same stage of pre-construction maturity in 2012–2015 that ALTO is at now. And the trajectory is now an official UK government data point — not contested or speculative — which removes one of the standard rhetorical defences used in ALTO’s framing.

The Canadian Parallel

The same trajectory has already occurred on the Toronto–Quebec City corridor

In 2016 the federal government funded a serious study of High Frequency Rail (HFR) for the Toronto–Quebec City corridor: 170–177 km/h conventional rail on largely dedicated tracks, costed at under C$5 billion in 2016 dollars, or under C$10 billion adjusted for construction inflation to 2024. A December 2021 Joint Project Office Business Case prepared by VIA Rail Canada and the Canada Infrastructure Bank confirmed the preferred option. tc.canada.ca

In March 2022 the federal government issued a Request for Expressions of Interest that pivoted the procurement to a Design-Build-Finance-Operate-Maintain (DBFOM) structure and explicitly invited proposals for speeds above 200 km/h. In February 2025, without publishing a side-by-side comparison of the HFR and high-speed options, the government confirmed the project would become ALTO at 300 km/h+, costed at C$80–120 billion. Passengers will not board until the 2040s.

~5×

HS2 Phase 1 real-terms increase, 2012–2026 (UK)

Lovegrove Review, May 2026

16–24×

HFR to ALTO escalation, 2016–2025 (Canada)

CRI From HFR to ALTO, March 2026

$0

published side-by-side comparison of HFR vs ALTO

As of May 2026

The escalation from HFR’s published baseline to ALTO’s announced range is of the same order of magnitude as, and on a comparable timescale to, the four-fold real-terms increase Lovegrove documents for HS2 Phase 1. The HS2 cost-trajectory table above is not a foreign curiosity. It is the comparator for a transformation that has already occurred on the project Canada is now committing to deliver.

The “Original Sins”

Lovegrove’s consensus diagnosis — and its ALTO analogues

Lovegrove summarises the consensus diagnosis of why HS2 cost forecasts proved so wrong. The list is short and direct: original gold-plating of the high-speed concept; a decision to begin construction at the hardest points of the route; changing objectives and political priorities; award of the Main Works Civils Contracts at insufficient design maturity and on terms which did not manage risk; and costs and risks badly underestimated.

The pursuit of 300 km/h electrified high-speed running across a route with the geological and ecological profile of the proposed southern corridor is itself a gold-plating decision. Reference-class analysis shows that the marginal capital cost of moving from a conventional or near-conventional dedicated passenger railway to a fully grade-separated electrified high-speed alignment is the dominant driver of total programme cost — and is the primary mechanical reason the HFR-to-ALTO transformation generated the cost escalation set out above. An alternative configuration — a lower design speed in the order of 200 km/h, on a route making use of the 401 corridor rather than a new southern alignment across Eastern Ontario — would shift the project into a different cost class and a different environmental and community-impact profile. Whether such a configuration is preferable, on a full set of criteria, is precisely the comparative question the Lovegrove framework says government should answer before a Final Investment Decision.

The HS2 phasing parallel is not exact: ALTO plans to begin with the Ottawa-to-Montréal segment, which involves real engineering complexity including Leda clay deposits and the Ottawa River crossing, but is not the hardest section of the proposed corridor. The more challenging geological and ecological terrain remains to be worked through downstream of any Notice-to-Proceed-equivalent decision. The category of risk Lovegrove identifies nonetheless applies: committing to a DBFOM contractual architecture spanning the full corridor before the hardest sections have been designed in detail locks in contractual obligations under the same design-immaturity conditions HS2 entered when it awarded its Main Works Civils Contracts. The HS2 mistake was not solely the geographical choice to start in the Chilterns; it was the contractual choice to commit before maturity, and that part of the parallel remains direct.

Sir Jon Thompson, the Executive Chair of HS2 Ltd, set out the resulting contractual problem directly in evidence to the House of Commons Transport Committee on 10 January 2024. parliament.uk He told the Committee that the Government and the company had decided to let cost-plus contracts under which 99% of the financial risk sat with the Government and only 1% with the contractor, describing the arrangement as extraordinary. Under a fixed-percentage fee, he noted, a contractor who runs over budget receives the same percentage of a much larger number, which effectively incentivises overspending rather than restraining it.

The risk allocation under the ALTO co-development contract with the Cadence consortium has not been publicly disclosed. Whether it replicates, mitigates, or improves on the HS2 risk allocation cannot be assessed from public information. Under Lovegrove’s framework, that absence of disclosure is itself the relevant problem: the contractual terms that drive cost outcomes over the lifetime of a project are exactly the terms that the sponsor department, Parliament, and the Auditor General require visibility into before, not after, commitment.

The Crown Corporation Problem

Lovegrove’s structural critique of the delivery vehicle

Lovegrove’s most pointed structural critique is of HS2 Ltd’s status as a Company Limited by Guarantee with government as sole guarantor. The Review concludes that this construct was institutionally incoherent. The arguments traditionally offered for it — independence from government, ability to hire at market rates, commercial discipline, decision-making at commercial speed — are real benefits, but they only work when the entity has genuine third-party shareholders with capital at risk.

“Company structures are arguably fundamentally ill-suited to this type of arrangement.”

— Lovegrove Review, May 2026

HS2 Ltd received 100% of its funding from government grant-in-aid. There were no third-party shareholders, no commercial counterparties with capital at risk, no governance mechanisms forcing cost-benefit discipline from below. The advantages of the company form were thus retained only in name. What HS2 Ltd actually got was the freedom to hire at private-sector rates and to operate at arm’s length from ministers, without the corresponding discipline of having investors who would have insisted on cost control.

ALTO HSR Inc. is in a structurally comparable position to HS2 Ltd at the corporate level. It is a federal Crown corporation, 100% publicly funded, with no third-party shareholders in the corporation itself. The contractual relationship with the Cadence consortium under the DBFOM arrangement is not publicly disclosed in sufficient detail to assess how risk, financing, and return are allocated between the parties or over what time horizon. What can be observed from the public record is the corporate-form question: a Crown corporation receiving 100% of its funding from the federal purse, used to obtain independence from political cycles and freedom to hire specialist talent, is in the same structural category as HS2 Ltd — the category Lovegrove diagnoses as institutionally incoherent because the disciplines that normally accompany the corporate form do not flow from grant-in-aid funding alone.

The “Fortress Mentality”

A cultural pathology, and a downstream information failure

Beyond structure, Lovegrove identifies a cultural pathology that should be familiar to anyone tracking ALTO’s public communications. The Review records that HS2 Ltd’s board, and particularly its executive management and chair, developed what interviewees described as a fortress mentality — becoming cheerleaders not only for HS2 but for the cause of high-speed rail in the UK more generally, framing the project as ushering in a new era. The Review is unambiguous that this conception of the company’s role was misguided. Transport policy is for ministers; the company’s job is delivery within scope and budget.

“The Board, and especially the executive management and Chair, had adopted a ‘fortress mentality’ and had become ‘cheerleaders’, not merely for HS2 but for the cause of high-speed rail in the UK more generally.”

— Lovegrove Review, May 2026

This cultural finding matters because it generated a downstream information failure. Lovegrove quotes board members and reviewers describing the management information packs given to the HS2 Ltd board as forming a veil behind which less good news became difficult to assess or even identify, with the same problem persisting unaddressed years later — packs remaining unwieldy, format-inconsistent, and lacking prioritisation. Because the same data flowed through to government, the sponsor department was working from the same compromised information.

The CRI’s post-consultation work has documented precisely this pattern in ALTO’s public outputs. The disclosures in Q-923 on cost, ridership, and the self-sustaining claim use confidence framings that do not survive parametric stress-testing against McGill TRAM and Munk School sources. The marketing pivot identified through the Cossette ATI disclosures, and the unanswered status of TRAN Report 18 — published by the House of Commons Standing Committee on Transport, Infrastructure and Communities and left without a government response when Parliament was prorogued — are the documentary symptoms of an executive culture that has begun to treat advocacy as primary and delivery information as secondary. Lovegrove’s framework gives that observation a name and an authoritative diagnostic basis.

The candour of Sir Jon Thompson’s evidence to the Transport Committee on 10 January 2024 is worth pausing on, because it confirms the Lovegrove diagnosis from inside the institution. Thompson — himself a former Permanent Secretary at HM Revenue and Customs and at the Ministry of Defence, and a double-qualified accountant — told the Committee that when he joined the HS2 board in 2021 he was struck by the lack of data and scrutiny of programme finances; that the management information presented to the board was not robust enough to assess whether main civils contractors were meeting productivity targets; and that significant improvement only arrived in October 2023, two and a half years later. He described it as a shocking thing to say, but acknowledged that the quality of board-level management information had not been good enough. That is the senior executive of a major UK arm’s-length delivery body, on the parliamentary record, confirming the exact information failure the Lovegrove Review now documents externally.

The Notice-to-Proceed Moment

When external reviews substitute for official advice

The Lovegrove Review devotes substantial attention to the Notice to Proceed decision in early 2020, when government formally committed to construction of HS2 Phase 1. The sequence is instructive. The Oakervee Review, an independent panel chaired by a former HS2 Ltd chair, recommended proceeding with the full route. Its report was published shortly after a Prime Minister–Chancellor–Secretary of State trilateral meeting had already reached the same conclusion. The formal Notice to Proceed was confirmed in March 2020.

Lovegrove’s criticism is not that the Oakervee Review was conducted in bad faith. It is that the official advice provided to ministers alongside the Oakervee report did not address alternative ways of delivering the project — as distinct from alternative projects — including options which would have led to a delay in construction while alternative designs, options, or contractual arrangements were sought. The external review effectively substituted for official advice on strategic choice.

“Reviews by external actors (including this one) have their place in informing policy formulation, but they should not substitute for official advice.”

— Lovegrove Review, Recommendation 14

This is the recommendation with the most direct bearing on where ALTO now sits. The work being produced by Cadence under its co-development contract, the public outputs of ALTO HSR Inc., and the materials prepared for the parliamentary process are all in danger of functioning as external review substituting for official advice on alternatives. The category of alternative Lovegrove insists should not be foreclosed before a Final Investment Decision — different speed classes, different route alignments, different contractual structures, different phasing — is exactly the category that has not been comparatively analysed for ALTO. A lower design speed in the order of 200 km/h, and a route making use of the 401 corridor rather than a new southern alignment, are concrete examples of the alternatives that would normally be costed and compared at this stage. They have not been.

The CRI’s March 2026 brief From HFR to ALTO already constitutes the kind of structured comparison Lovegrove says government itself should produce. It identifies eight pivotal changes that occurred between the December 2021 HFR Business Case and the February 2025 confirmation of ALTO as a high-speed system, and documents the absence of a published side-by-side cost-benefit comparison between the two options. The point under Lovegrove’s framework is not that citizen research is a substitute for official advice. It is that when an arm’s-length delivery body and the sponsor department do not produce that comparison themselves, and the government nonetheless proceeds, the conditions Lovegrove identifies as the proximate cause of the HS2 failure are present.

Vindication of the Dissenting Voice

The lone dissenter the Cabinet Office now says was right

One paragraph of the Lovegrove Review deserves to be read by every parliamentarian considering ALTO. When the British government was deciding whether to proceed with HS2 in 2020, it commissioned an independent panel chaired by a former HS2 chair, Douglas Oakervee. The panel recommended proceeding with the full project. One member dissented — Lord Berkeley, a peer and former rail executive. His dissenting report cast doubt on the costings, the schedule, and the capability of HS2 Ltd to manage the project. He was dismissed at the time as methodologically unsound. His report was excluded from the panel’s formal conclusions.

“There is no escaping the fact that the thrust of his judgements, in particular about the capability of the Company to manage the project, have proved to be correct, and his estimates much closer to today’s outturn than those upon which ministers ultimately gave the go-ahead.”

— Lovegrove Review, May 2026

That is the UK Cabinet Office, six years later, on the public record, telling Parliament that the man it ignored was right. His estimates were closer to reality than the ones ministers used to make the final decision. The institutional process designed to test his concerns failed.

This matters for Canada because it is the most authoritative statement any G7 government has ever made about the value of structured outside-the-tent analysis on a major infrastructure project. It does not validate every dissenting analysis automatically — Lovegrove notes that some of Berkeley’s specific methodological steps were questionable and that some of the cost increases arose from factors Berkeley did not identify — but it establishes that the dismissal of dissenting reference-class work as inherently less credible than insider forecasts has now been formally repudiated by one G7 government.

Corporate Overlap

Two Cadence members were inside HS2

Two of the six members of the Cadence consortium selected by Canada to design, build, finance, operate and maintain ALTO were directly embedded in HS2 work during the period that the Lovegrove Review now criticises.

AtkinsRéalis

The Canadian engineering firm that rebranded from SNC-Lavalin in 2023, and the lead Canadian engineering member of Cadence, was part of the CH2M / Atkins / SENER Engineering Delivery Partner joint venture for HS2 Phase One. That ten-year contract was awarded in 2016 and was valued between £250 million and £350 million. The Engineering Delivery Partner role placed Atkins inside HS2 Ltd, fully integrated, with explicit responsibility for supporting the preparation and procurement of the Main Works Civils Contracts — the contracts that the Lovegrove Review identifies as awarded at insufficient design maturity and on terms which did not manage risk. Atkins’s UK arm was acquired by SNC-Lavalin in 2017, mid-way through the contract, and is now part of AtkinsRéalis.

SYSTRA

The French rail engineering firm and a Cadence member was part of the Mott MacDonald / SYSTRA design joint venture working alongside the Balfour Beatty VINCI construction joint venture on HS2 Lots N1 and N2 of the Main Works Civils Contracts — the 90 km West Midlands stretch including the Long Itchington Wood Green tunnel and the Birmingham approaches. SYSTRA was also a partner in the BBV-SYSTRA (BBVS) joint venture for the Old Oak Common station in London. SYSTRA’s role on HS2 was thus across both design and construction-management functions on the very contracts whose financial architecture HS2’s own chair has publicly criticised before the UK Public Accounts Committee.

These observations are factual, not attributive. The Lovegrove Review is explicit that the institutional failure on HS2 lay primarily with HS2 Ltd’s governance and culture and secondarily with the Civil Service, not with the contractor firms per se. Many of the firms involved are world-leading rail engineers, and their inclusion in Cadence reflects that. The point is that two firms whose immediately prior major HSR engagement is now the subject of a Cabinet Office post-mortem on cost control are now central to ALTO’s design, build, and ongoing operation under a DBFOM structure. For parliamentarians and analysts considering whether the lessons of HS2 are being absorbed into ALTO’s procurement and oversight, this is a fact that warrants disclosure in any briefing material on the project.

Implications for ALTO

What this changes

Canada has the same parliamentary system as the United Kingdom. The same Treasury Board controls. The same Crown corporation tools. The same Public Accounts Committee. The same Auditor General. The institutional architecture that failed at HS2 — and that Lovegrove has now diagnosed in unusual detail — is the architecture being used to deliver ALTO.

The HS2 cost trajectory is now an official G7 reference class

The Cabinet Office published trajectory — £20.5bn (2012) to £82.2bn (2026) in constant 2019 prices — is now an official G7 data point. It belongs in every cost-related submission, briefing letter, and parliamentary communication on ALTO between now and a Final Investment Decision.

The Crown corporation critique applies directly

The structural critique of the Company Limited by Guarantee model translates directly to ALTO HSR Inc. The case for Crown-corporation delivery has been overstated; the commercial discipline its proponents claim does not flow from the structure adopted when 100% of funding comes from the public purse.

Recommendation 14 creates a concrete obligation

Government, not contractors, must produce the comparative analysis of alternative ways of delivering the project — including alternative speed classes and route corridors — before any Notice-to-Proceed-equivalent decision. Doing it after commitment is, in Lovegrove’s framework, too late.

Berkeley’s vindication establishes a precedent

The Cabinet Office’s 2026 vindication of Lord Berkeley’s 2020 dissenting report establishes a public-record precedent for the credibility of structured citizen reference-class analysis in HSR governance. That precedent is now available to be cited.

The AtkinsRéalis / SYSTRA overlap warrants disclosure

The involvement of two Cadence members in the HS2 work the Lovegrove Review now criticises is a material fact for parliamentarians considering whether ALTO’s procurement reflects institutional learning from HS2, or the application of the same contractual architecture in a different jurisdiction.

The Lovegrove and Stewart Reviews together represent the most current, most senior statement by a G7 government on what arm’s-length high-speed rail delivery requires of a Westminster-system sponsor department. The lessons set out in the Lovegrove Review are not lessons Canada needs to learn the hard way. They are available now.

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Reading Lovegrove (PDF)

Complete analysis for parliamentarians, the Parliamentary Budget Officer, the Auditor General, and constituents tracking ALTO’s governance and procurement

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Sources

Primary documents and statements

1.
Lovegrove, Sir Stephen. Review of implications for the Civil Service and wider public sector of findings of the James Stewart Review. Cabinet Office, May 2026. Published under Open Government Licence v3.0. gov.uk

2.
Stewart, James. The HS2 Experience: Major Transport Projects Governance and Assurance Review. 2025.

3.
Thompson, Sir Jon, Executive Chair, HS2 Ltd. Oral evidence to the House of Commons Transport Committee, HS2: progress update, HC 85, 10 January 2024, Questions 393–471 (in particular Qq. 410–412 on cost-estimation methodology, Q417 on the 99/1 risk allocation under cost-plus contracts, Q428 on inadequacy of board-level management information, and Q435 on the limits of corrective action under existing contractual fundamentals). parliament.uk

4.
Lord Berkeley. HS2 Review Dissenting Report, January 2020.

5.
Government of Canada / Cadence Consortium. Announcement of selection of Cadence as preferred private developer partner for the ALTO HSR project, February 2025.

6.
Joint Project Office (VIA Rail Canada / Canada Infrastructure Bank). High Frequency Rail Project Business Case Update. December 2021.

7.
Transport Action Canada. Statement on the selection of the Cadence consortium for ALTO HSR co-development. February 2025. transportaction.ca

8.
ALTO HSR Citizen Research Initiative. From HFR to ALTO: How a $5 Billion Plan Became an $80–120 Billion One. March 2026.

ALTO HSR Citizen Research Initiative · citizenresearch.ca · Governance Brief · May 2026
Independent, non-partisan research on the proposed Toronto–Quebec City high-speed rail corridor.

May 19, 2026

Tag: HS2

Where you put a railway

Where you put a railway decides almost everything else

1. Carbon: the two routes have opposite signs

2. Habitat: a new barrier in the wrong place

The Frontenac Arch

The Napanee Limestone Plain

3. Construction: where the trucks go

4. Communities: friction is priced into the cost

One thing that cuts the other way

5. What the corridor could give back

How to read the numbers on this page

Sources and notes

Counting the crossings

Counting the Crossings

What ALTO’s own numbers work out to

How many roads are we talking about?

What ALTO told Kingston in February

The reassurance

The qualification, in the same answer

The objective

And the fencing

Why the structure count does not settle it

You are being shown half a fraction

Not every structure reconnects anything

A different landscape

What France also built

A structure is not automatically an answer

Size

Upkeep

What closure pushes onto the road

One claim that cannot be tested as written

Six questions ALTO can answer today

Primary documents and statements

50000 jobs

Where do 50,000 jobs come from?

What Alto says

What the report actually says

How we checked it

What the check found

The question the report leaves open

Two more things in the tables

Upper, not central

The comparison figures have no source

This has been released before

What we are asking Alto to publish

How to read the numbers on this page

Sources and notes

Procured and then

Procured, and Then?

ALTO commissioned the outside view

Buying the instrument is not the same as letting it bind

The record will arrive after the decision has moved on

Two studies, no cost side

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

Adverse mechanisms are identified but do not reach the total

The two studies disagree, and each resolves the disagreement upward

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

Publish the comparison

Documents relied on

Bound before briefed

City of Kingston: Bound Before Briefed

“This is not optional”

Access conditioned on silence

Four agreements became three hundred and thirty-nine

The creep has already begun here

Twenty-six of twenty-eight had no end date

The promoter’s case, and what the record shows

What Britain concluded, in public, before Kingston signed

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

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

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

The culture did not stay in its lane

The same request, refused twice next door

United Counties of Prescott and Russell — refused, May 2026

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

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

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

The choice Kingston was offered is not a real choice

Five questions, one answered