Tag: JPO Business Case

  • Hours are not dollars

    Hours Are Not Dollars

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

    ⚠ Where the Number Sits

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

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

    In One Paragraph

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

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

    Start Here

    What a discount rate is, in ordinary words

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

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

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

    13¢
    what a dollar of benefit in year 60 is worth today at ALTO’s 3.5 per cent
    23¢
    the same dollar at 2.5 per cent, the rate ALTO’s own cited manual requires be tested
    the same dollar at 8 per cent, the rate identified in 2007 Treasury Board guidance

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

    The Arithmetic, Shown Openly

    How much the answer moves

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

    Discount rate usedValue of the streamRelative to 3.5%$49.5B scaled
    2.5 per cent21.341.43×$71.0B
    3.0 per cent17.761.19×$59.1B
    3.5 per cent — ALTO’s rate14.891.00×$49.5B
    UK declining schedule15.611.05×$51.9B
    5 per cent9.110.61×$30.3B
    7 per cent5.090.34×$16.9B
    8 per cent3.900.26×$13.0B

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

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

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

    Where 3.5 Per Cent Comes From

    A number with a family tree

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

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

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

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

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

    Those three add to 3.5.3

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

    The detail that cuts in ALTO’s favour

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

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

    The Canadian Comparison

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

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

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

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

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

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

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

    Even the academic case for 3.5 per cent has conditions

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

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

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

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

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

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

    The Precedent

    The last time anyone published these numbers for this corridor

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

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

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

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

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

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

    The same two sources, five years apart

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

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

    And it kept the two ledgers apart

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

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

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

    Following the Money

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

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

    1. The appraisal rate — 3.5 per cent

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

    2. What it costs the government to borrow

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

    3. What a private partner needs to earn

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

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

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

    Why the $49.5 billion cannot pay for anything

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

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

    A Canadian Example, Fully Documented

    How the Montréal REM is actually funded

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

    Who put up the capital
    CDPQ Infra $2.95B; the Government of Québec $1.283B; the Government of Canada $1.283B; Hydro-Québec $295M; the regional transit authority $512M. The construction estimate rose from $6.3 billion in 2018 to $7.95 billion by 2023, an increase CDPQ Infra absorbed under its agreement.11
    How the money returns
    Not through fares. The regional transit authority pays CDPQ Infra 72 cents for every kilometre every passenger travels, indexed annually to the Consumer Price Index. That single rate covers construction, operation and long-term maintenance.12
    If ridership beats forecast
    The rate steps down. CDPQ Infra has described trips beyond 15 per cent above forecast being paid at roughly 57 cents, and trips beyond 40 per cent above forecast at the user fare itself.13
    The two return targets
    8 to 9 per cent for CDPQ Infra. 3.7 per cent for the governments. Both were set at the outset and publicly reaffirmed during construction.14

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

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

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

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

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

    Limits of This Explainer

    What this does not claim

    On the rate

    3.5 per cent is not wrongIt is a mainstream, well-supported choice for long-lived public investment. This explainer does not argue that ALTO’s rate is too low.
    Two omissions favour ALTOBoth the stepped-down schedule and the sensitivity test its cited manual requires would have produced a larger benefit figure. The omissions do not all run one way.
    The arithmetic is illustrativeThe table uses a level benefit stream and a stated start year. It shows the shape of the sensitivity, not a recalculation of ALTO’s result.
    The 2021 ratios are not ALTO’sHigh Frequency Rail was a different and cheaper project assessed over thirty years, and its authors called the results preliminary. Those figures are cited as evidence that a ratio can be produced at this stage, not as an estimate of ALTO’s.

    On the comparisons

    Nothing here binds ALTOMetrolinx guidance, UK Treasury practice and federal regulatory policy carry no legal force over this project. They are offered as points of comparison, one of which ALTO chose to cite itself.
    The federal figure is unverifiedThe 8 per cent rate is documented from 2007 guidance through peer-reviewed sources. The current edition of that guide is not publicly posted, and the Initiative does not assert what it now specifies.
    We do not say whyWhere the report does not state something — a fare, a payment mechanism, a sensitivity test, a range — this page says so rather than inferring it, and makes no claim about why any figure was or was not published, or about the intentions of anyone who prepared it.
    This is a public report, not a business caseA submission to Cabinet in 2029 may contain material this document does not. What is examined here is what has been placed in public.
    What Would Settle It

    Two questions, answerable without releasing a model

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

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

    2. What fare, and what revenue?

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

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

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

    Sources

    Primary documents

    1.
    ALTO, Canada’s Moment: The Economic Opportunity of High-Speed Rail, August 2026, 83 pp. Discount rate, sixty-year appraisal period and price base in the Appendix A methodology box, sourced at footnote 65 to the Metrolinx manual; capital cost and AACE Class 5 estimate at pp. 5 and 65; direct-benefit tables headed “upper estimate”. Analysed in full in the Initiative’s companion brief Two Parameters, None of the Conditions, summarised at It Left the Rules Behind.
    2.
    Metrolinx, Business Case Manual Volume 2: Guidance, August 2021, 222 pp. Economic parameters at Table 5.8: social discount rate 3.5 per cent, evaluation period five to sixty years, single blended value of time. Verified as the current edition, 21 August 2026. metrolinx.com
    3.
    HM Treasury, Review of discounting in the Green Book: Terms of Reference, 16 December 2025. Sets out the derivation of the 3.5 per cent Social Time Preference Rate. The Treasury specifies four parameters — pure time preference, catastrophe risk, the elasticity of marginal utility and the growth rate — the last two of which multiply to the 2.0 per cent component described above as a single judgement. and the declining schedule of 3.0 per cent for years 31 to 75 and 2.5 per cent thereafter. gov.uk
    4.
    HM Treasury, Green Book supplementary guidance: discounting, updated 5 February 2026. Instructs practitioners to use 3.5 per cent for years 1 to 30 and 3.0 per cent for years 31 to 75. gov.uk (PDF)
    5.
    A. E. Boardman and M. A. Moore, “The Social Discount Rate for Canada Based on Future Growth in Consumption,” Canadian Public Policy, vol. 36 no. 3 (2010), pp. 325 onward. Records the Treasury Board Secretariat’s 2007 interim recommendation of an 8 per cent social discount rate with sensitivity rates of 3 and 10 per cent on a weighted social opportunity cost of capital basis; argues instead for 3.5 per cent, conditional on a horizon under fifty years and no crowding out of private investment, with a shadow price of capital of 1.26 applied to investment flows, and a declining schedule beyond fifty years. Canadian Public Policy
    6.
    Treasury Board of Canada Secretariat, Policy on Cost-Benefit Analysis, in force since 1 September 2018. Requires departments to use the opportunity cost of capital specified in the TBS guide, with a social discount rate permitted in defined cases including impacts of fifty years or more, and requires opportunity-cost results to be reported in any event. canada.ca
    7.
    Treasury Board of Canada Secretariat, “Requirements for developing, managing and reviewing regulations,” canada.ca, page updated 26 November 2025, accessed 21 August 2026. States that the most current version of Canada’s Cost-Benefit Analysis Guide for Regulatory Proposals is available exclusively on the Cabinet Directive on Regulation GCwiki page. The 2022 edition remains catalogued in Government of Canada Publications as an archived document. canada.ca
    8.
    Transport Canada, Economic Evaluation Branch, Guide to Benefit-Cost Analysis in Transport Canada, Ottawa, 1994. Catalogued in the Transport Research International Documentation database. TRID
    9.
    Bank of Canada, selected benchmark bond yields, accessed August 2026; Bank of Canada policy interest rate held at 2.25 per cent through mid-2026 against a 2 per cent inflation target. Long-bond yields move daily and should be checked against the source rather than quoted from this page. bankofcanada.ca
    10.
    Réseau express métropolitain, “Information about the agreement with the ARTM and its rate mechanisms.” Sets out the 72-cent per passenger-kilometre invoice to the regional transit authority, the reduction once ridership projections are exceeded, and the turnkey scope covering construction, operation and long-term maintenance. rem.info
    11.
    Capital structure as reported on award of the construction contracts: CDPQ Infra $2.95B, Government of Québec $1.283B, Government of Canada $1.283B, Hydro-Québec $295M, ARTM $512M, against a construction cost of $6.3B. The estimate was revised to $7.95B in September 2023, with CDPQ Infra absorbing the increase under its agreement with the Québec government. International Railway Journal
    12.
    Gouvernement du Québec, ARTM and CDPQ Infra, “Release of the management and implementation agreement and of the integration agreement for the Réseau express métropolitain,” 23 April 2018. Confirms the $0.72 per passenger-km base cost and annual indexation to Canada’s Consumer Price Index, and the cap limiting additional municipal costs to roughly $45 to $60 million a year in then-current dollars. quebec.ca
    13.
    CDPQ Infra, “7 myths about the REM de l’Est,” February 2022. Describes the ridership relief mechanism: the rate falls by about 20 per cent, to roughly $0.57, for trips above 15 per cent over forecast, and equals the user fare for trips above 40 per cent over forecast. Published in the context of a later project; the mechanism described is the REM’s. cdpqinfra.com
    14.
    Réseau express métropolitain, semi-annual project update, 3 June 2021. Reaffirms the 72-cent rate set in the 2018 agreement and states the performance targets: 8 to 9 per cent for CDPQ Infra and 3.7 per cent for the government partners. rem.info
    15.
    Discounting arithmetic in this explainer computed by the Initiative on the stated assumptions: a level annual benefit stream, sixty years of operation beginning in year 16, discounted to a year-zero base; the declining-schedule row applies 3.5 per cent to years 1 to 30, 3.0 per cent to years 31 to 75, per source 3.
    16.
    Joint Project Office (VIA Rail Canada and the Canada Infrastructure Bank), High Frequency Rail Project: Business Case Update, V.002, 10 December 2021, 150 pp., released by the Canada Infrastructure Bank under the Access to Information Act, November 2025. Capital cost breakdown and 30-year revenue at p. 7; benefit-cost ratio, net present value and the Table 4 subsidy comparison at p. 8; economic appraisal parameters sourced to Metrolinx and MTQ guidance at p. 40; incremental capex and opex at Table 9; other impacts at Table 12; impact results and both ratios at Table 14, p. 43; net present value assumptions, including the 2.5 per cent discount rate sourced to the ten-year average 30-year Government of Canada benchmark bond, at Figure 38, p. 85.
    17.
    The same document released as Annexe A to access request 22-2207 (148 pp., stamped Demande d’accès à l’information #22-2207 AI(D)). In that version, section 9.7 Net Present Value Analysis survives as a heading at p. 84 with pp. 84–86 otherwise blank; section 9.8 Financial Structuring at p. 87 is withheld in full; the capital cost and 30-year revenue sentences are truncated mid-clause at p. 21, leaving the grammar intact around the removed figures; and the subsection headings of section 7 Economic Case are withheld within the table of contents, together with the title of section 8 and all of its subsections, which appear as bare dot leaders against pp. 40–43 and 44–63. The construction employment sentence at p. 21 is severed in the same way: “an estimated ___ annual equivalent jobs could be created.” That figure — 71,000 to 96,000 annual equivalent — is disclosed in full in the Canada Infrastructure Bank release at note 16. No exemption provisions are marked against any of the severed passages. Both versions held by the Initiative.
    18.
    Cadence consortium membership and CDPQ Infra’s leadership role: Cadence, “About us,” and CDPQ Infra, “Alto high-speed rail,” both accessed August 2026; consortium announced as preferred private development partner 19 February 2025, co-development agreement signed March 2025. AtkinsRéalis (formerly SNC-Lavalin) was a member of NouvLR, which held the REM engineering, procurement and construction contract, and of the group now operating as Pulsar with Alstom under the rolling stock, systems, operations and maintenance contract. cadence.info
  • It left the rules behind

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

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

    ⚠ The Document Under Examination

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

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

    Critical Finding

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

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

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

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    Start Here

    Why this matters

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

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

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

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

    What the report gives you

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

    What its own cited source requires

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

    What that leaves a reader with

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

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

    The Two Numbers

    What the report borrowed, and from where

    3.5%
    the discount rate ALTO uses, taken from the Metrolinx manual
    Appendix A, footnote 65
    $22.32
    the value of one hour of a traveller’s time, the same figure for every trip
    justified as following Metrolinx method
    64%
    the top-up the same manual requires on construction costs at this stage of design
    not applied in the report

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

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

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

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

    The Manual’s Own Terms

    The numbers come as a set, not a menu

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

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

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

    The Missing Tests

    What a project this size is supposed to publish

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

    Re-run the numbers at a different discount rate

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

    Re-run the numbers with a rising value of time

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

    Run the costs and assumptions through a range analysis

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

    Report the odds that the project is worth doing

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

    Publish the standard indicators

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

    Model low, medium and high growth scenarios

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

    This is not a theoretical requirement

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

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

    The Missing Lower Number

    The report concedes a range it never publishes

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

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

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

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

    The Optimism Adjustment

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

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

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

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

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

    The Central Inversion

    Too early to divide, but not too early to multiply

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

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

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

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

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

    Limits of This Analysis

    What this brief does not say

    Stated here rather than left for others to find.

    On the analysis

    The rate is not wrong3.5 per cent is a defensible choice, used by the United Kingdom Treasury and by Metrolinx, and well supported for long-horizon public investment. This brief does not argue that ALTO’s rate is too low or too high.
    Metrolinx does not bind ALTOA provincial agency’s manual has no legal force over a federal Crown corporation. The argument is about the coherence of a citation, not about jurisdiction.
    One choice runs in ALTO’s favourThe 3.5 per cent rate is applied flat across sixty years. The UK Treasury, whose Social Time Preference Rate this figure matches, steps its rate down to 3.0 per cent after year 30. Applying that schedule would have made ALTO’s benefit total larger, not smaller.
    One cited source was not reviewedGuidance from the Ministère des Transports du Québec is cited separately for the value of time. The Initiative has not reviewed it and takes no position on what it requires.

    On the report and its source

    The report does apply conservatism in placesAccident reductions are capped after twenty years, and car emission factors are assumed to improve to 2050, which the report notes limits the emissions benefit. These are the two smallest monetised lines. No equivalent constraint is disclosed for travel time, which is 78 per cent of the total.
    The manual itself is datedMetrolinx said in 2021 that a revised version with updated values would follow in 2022. Five years on, it has not. That is a limitation of the source document, not a fault of ALTO’s — but a reader assessing where a federal appraisal input came from is entitled to know it.
    Which figures are whoseEvery figure attributed to ALTO, Metrolinx, the Joint Project Office, HM Treasury or Statistics Canada is quoted from the sources listed below and can be checked there. Three figures are our own arithmetic and are marked as such where they appear: the $98 to $148 billion uplifted capital range, the $21.40 inflation-escalated value of time, and the five per cent effect of the declining Green Book schedule. Where the report does not state something, we say so rather than inferring it, and we make no claim about why any requirement was or was not carried across.
    This is a public report, not a formal submissionA business case submitted to Cabinet in 2029 may well contain material this document does not. The claims examined here are the claims ALTO has chosen to put in public.
    What Would Settle It

    Two questions ALTO can answer without releasing a model

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

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

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

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

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

    Where Things Stand · August 2026

    Summary ledger

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

    Carried across
    The 3.5 per cent discount rate, correctly cited to the manual.
    Carried across
    The single blended value of time, expressly justified by reference to the manual.
    Partial
    The thirty-year cap on benefit growth: applied to accident and emissions lines, not stated for travel time, which is 78 per cent of the benefits.
    Partial
    A single price year throughout: the appraisal is in 2024 dollars, the GDP result in 2019 dollars.
    Left behind
    Discount rate sensitivity test at 2.5 per cent.
    Left behind
    Value of time sensitivity test at 0.75 per cent real growth.
    Left behind
    Range analysis of costs and assumptions, reported with a confidence level.
    Left behind
    The probability that benefits exceed costs, and the benefit-cost ratio itself.
    Left behind
    The standard set of performance indicators: net present value, benefit-cost ratio, capital utilisation, return on investment, internal rate of return.
    Left behind
    The optimism-bias top-up on construction costs, 64 per cent at this level of design — not applied and not mentioned.
    Left behind
    The lower end of the range, on figures the report itself labels an upper estimate.

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

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

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    Two Parameters, None of the Conditions (PDF)
    Full research brief with page references, parameter tables, worked figures and sources
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    If the terms in this brief are unfamiliar — what a discount rate actually does, why a benefit figure is not money, and who ends up paying — the companion explainer Hours Are Not Dollars covers the same ground in plain language, and sets out the 2021 business case figures in full.

    Sources

    Primary documents

    1.
    ALTO, Canada’s Moment: The Economic Opportunity of High-Speed Rail, August 2026, 83 pp. Discount rate, appraisal period and price base in the Appendix A methodology box, sourced at footnote 65 to the Metrolinx Business Case Manual Volume 2; value of time and the single-parameter justification in the same appendix, with Ministère des Transports du Québec guidance at footnote 66. Direct-effects tables headed “upper estimate, $2024 CAD”; benefit-cost ratio discussion at p. 62 and reference to the benefit-cost ratio at p. 80; capital cost and AACE Class 5 at pp. 5 and 65; scenario-robustness claims at pp. 3 and 69.
    2.
    Metrolinx, Business Case Manual Volume 2: Guidance, August 2021, 222 pp. Economic parameters at Table 5.8; sensitivity requirements at Tables 5.1 to 5.3; optimism bias at Tables 5.4 to 5.6; worked range example at Table 5.7; Economic Case lifecycle requirements and key performance indicators; business case principles at pp. 11 and 13; guidance revision cycle at p. 4. metrolinx.com
    3.
    Metrolinx, “Business Cases — Resources,” accessed 21 August 2026. The Business Case Guidance link resolves to the Volume 2 file under an asset version token corresponding to 15 September 2022; no Volume 2 revision has been issued.
    4.
    B. Flyvbjerg, Procedures for Dealing with Optimism Bias in Transport Planning (UK Department for Transport, 2004), cited in the Metrolinx Guidance as the basis for the optimism-bias uplift.
    5.
    Statistics Canada, Table 18-10-0004-01, consumer price index, used for the 2021 to 2024 escalation of the Metrolinx value of time. The comparison is arithmetic and is not an attribution of method.
  • Transport Action Canada

    The Voice ALTO Has Already Heard From

    Transport Action Canada and Transport Action Ontario — the country’s principal pro-rail civil-society voice — have made detailed substantive recommendations about ALTO. What they asked for. What the record shows ALTO has so far addressed. What their voice contributes that nothing else in the public record does.

    ⚠ Documents Under Analysis

    On March 16, 2026, Transport Action Canada and Transport Action Ontario submitted an 18-recommendation written response to ALTO at the close of the January–March 2026 consultation period. The organizations also published an open letter setting out what they believe the substantive questions about the project are, and what credible alternatives have been studied previously.

    They are explicitly pro-rail. They are not opposed to high-speed rail in principle. Their concerns are technical, financial, and service-continuity concerns, and they are asking for the same documents and analyses that Parliament’s own Transport Committee asked for in September 2024 — and that have not been produced.

    Critical Finding

    The questions about ALTO’s cost, ridership, document release, and VIA-service impact are not coming only from project-affected landowners, from anti-rail critics, or from research initiatives. They are coming from the country’s principal pro-rail civil-society voice, in March 2026, on the public record, having formally engaged with ALTO through ALTO’s own consultation process.

    The brief sets out what Transport Action asked for, what the record shows ALTO has addressed, and what credible alternatives they have publicly identified.

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    What Transport Action Canada and Transport Action Ontario asked of ALTO, what ALTO has addressed, and what their voice contributes to the public record
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    The Witness

    Who Transport Action is

    Transport Action Canada describes itself as “Canada’s citizen advocacy organization for public transportation,” with members who have “discussed and debated the subject over the past five decades, including of course High Speed Rail and possible alternatives.” It and its provincial affiliates — including Transport Action Ontario, jointly authoring the consultation letter analysed here — are the principal national civil-society voice on Canadian intercity rail policy.

    Their position on ALTO is unambiguous. The open letter opens by welcoming “serious discussion of all options to improve passenger rail.” The consultation letter opens by describing the organizations as “a knowledgeable, passenger-focussed NGO that is very supportive of intercity passenger rail.” They explicitly recognize the underlying problem ALTO is intended to address — that VIA Rail’s constrained access to CN’s Kingston Subdivision “has long been recognized as untenable, which prompted the development and launch of VIA’s High Frequency Rail proposal in 2015.”

    They acknowledge the limits of incremental improvement: “just improving the CN route in isolation while continuing to operate alongside freight would not come close to the quintupling of capacity and slashing of travel times possible with some kind of dedicated track.” They are, in plain terms, an organization that wants more passenger rail in Canada and is substantively critical of how this particular HSR project is being delivered.

    What They Asked For

    The March 2026 consultation response

    Transport Action’s March 16, 2026 letter to ALTO’s Government and Stakeholder Relations office contains eighteen specific recommendations across seven sections. The four recommendations that most directly overlap with the existing CRI evidence base are set out below.

    Recommendation 1
    On the business case and cost
    What Transport Action asked

    “There is considerable skepticism from the public and stakeholders about the business case for HSR… It is urgent that a detailed Business Case be completed as soon as possible, including preferred corridor, capital cost, detailed ridership, fares, revenue and methods of calculation.”

    Mapped onto the parliamentary record

    This is, in substance, the same request as Recommendation 4 of TRAN Report 18 (September 2024), which asked the Minister to require an HFR-versus-HSR cost analysis within six months. As CRI’s brief The Report That Vanished documents, that analysis was never produced. Transport Action is asking, eighteen months later, for the same kind of cost-and-business-case work.

    Recommendation 2
    On ridership transparency
    What Transport Action asked

    “No details are provided on the ridership model, population assumptions, network assumptions, demand per segment, fares, cost of gasoline etc. Although the ridership assumption may be reasonable when lifted from European ridership, there is skepticism that this would be replicated in central Canada, due to lower fuel prices, absence of road tolls etc.”

    Mapped onto the parliamentary record

    This maps directly onto Claim 3 in Reading the Answer — the government’s 43-million-by-2084 ridership figure in Q-923. Transport Action specifically raises the central-Canadian fuel-price and road-toll conditions that distinguish the corridor from the European benchmarks, and quantifies the Ontario provincial subsidy to personal car use at $2.5 billion per year as a “politically tilted playing field” that any credible ridership model must account for.

    Recommendation 3
    On document release
    What Transport Action asked

    “We urge you to release a full unredacted version of the JPO report, plus any other reports that were in the ‘data room’ made available to the three bidders. At this time, with the tender process completed, there should be nothing in these reports that is business-confidential.”

    Mapped onto the parliamentary record

    This is — almost word for word — the same request as Recommendation 6 of TRAN Report 18. Transport Action makes an additional point that the procurement-completion rationale for non-disclosure no longer applies: with the bidder data-room phase concluded, there is no remaining commercial confidentiality argument. The reports have still not been released.

    Recommendation 6
    On the future of VIA service
    What Transport Action asked

    “Recent media reports from Kingston regarding possible diminution of current VIA Rail services when ALTO is operational must be heeded… It is important that ALTO and VIA Rail jointly issue a statement promptly about plans for services at these cities. Otherwise, local elected officials and residents will continue to impede ALTO’s progress.

    Mapped onto the parliamentary record

    This maps directly onto Recommendations 8 and 10 of TRAN Report 18 — the VIA-impact analysis and the no-service-reduction commitment, both unanswered since September 2024. The Senate TRCM raised the same concern in February 2026. The question has now been asked across two parliamentary chambers and one substantial stakeholder consultation submission; it has not been substantively answered.

    Transport Action’s remaining fourteen recommendations cover downtown and shoulder station design, affordable fares, intercommunity bus access for towns currently outside the rail network, emergency-management cooperation with rural fire and EMS, wildlife crossings, sufficient road and trail bridges, recognition of Ontario’s 1834 Drainage Act, First Nations contingency planning for archaeological discovery, sensitive-agricultural-use mapping (sugar bushes, vineyards, certified organic land), and compensation frameworks for intensive agricultural operations that would need to be relocated. Several bear directly on issues documented in CRI’s Five Hundred Farms brief.

    Three Alternatives They Identified

    What pro-rail technical analysis says is possible

    A question CRI has not previously had answered by a technically literate pro-rail body: were credible alternatives to ALTO actually studied, and what did the studies show? Transport Action’s open letter identifies three.

    01

    Targeted CN-route improvements

    “Further investments to improve passenger and freight fluidity, like the third track between Belleville and Napanee and station improvements… would make a big difference to reliability at modest cost.”

    Transport Action concedes this alone is insufficient to deliver the “quintupling of capacity and slashing of travel times” possible with a dedicated track — but lays out a complementary package of known modest cost.

    02

    The freight grand bargain

    “Moves most CN freight over to the CPKC route through Perth… The existing CN route could then be upgraded to support more passenger services at up to 170 km/h, with travel times of around 4 hours between Toronto and Montreal or Ottawa.”

    This is the High Performance Rail framework substantially as CRI has documented it, here independently advocated by Transport Action as a technically credible option.

    03

    HFR on the original Havelock alignment

    “A dedicated track that takes a more direct route between Toronto and Ottawa, with the advantage of reconnecting Peterborough to the railway network, was VIA Rail’s preferred option, while also preserving service on the existing route through Kingston.”

    This is the project the Joint Project Office was funded in 2017 to study, the project the Transport Committee studied in 2023–24, and the project the federal government redesignated in late 2024.

    Why earlier HSR-along-the-lakeshore studies did not proceed

    Of independent technical interest is Transport Action’s observation about why HSR following the Lake Ontario lakeshore has been studied multiple times without proceeding:

    High Speed Rail following a lakeshore from Toronto through Kingston has also been studied before, more than once, by both the federal and provincial governments, without proceeding. For safety reasons, and to achieve 7 km+ minimum radii for higher speeds, such a dedicated track could not be placed too close to the existing alignment nor right alongside Highway 401. It would thus require significant expropriation, and the number of homes and businesses close to CN’s tracks and the 401 has only grown since the last such study in 2011. The chances are that communities like Port Hope and Trenton would be bypassed entirely, and route from Kingston to Ottawa would also then also go through the same sensitive Frontenac Arch region and many of the communities expressing most concern about Alto’s southern study corridor.

    Transport Action Canada, open letter on ALTO HSR route options in eastern Ontario. read the letter

    This is the route-geometry argument set out by a pro-rail body with the technical standing to make it — the same observation about HSR’s 7-km curve-radius requirement that CRI’s engineering research has documented, here presented as a published critique by an established advocacy organization.

    What Their Voice Contributes

    A fifth source category, otherwise absent

    The Citizen Research Initiative’s briefs to date have drawn on four categories of source. Each has its own evidentiary weight; each has its own limitations. Transport Action contributes a fifth that has been substantively absent until now.

    Parliamentary record

    Order Paper questions, Transport Committee reports, Senate committee testimony, the High-Speed Rail Network Act. Authoritative but procedurally bounded.

    Academic studies

    The McGill Transportation Research and Munk School Global Economic Policy Lab analyses. Methodologically rigorous but bounded by funding and study scope.

    Journalism

    The Canadian Press and Globe and Mail reporting; CBC News; Globe coverage of the NFU response. Documentary but episodic.

    Affected stakeholders

    OFA, UPA, CFA, BFO, NFU. Authentic to affected communities but advocating for their members’ specific interests.

    Pro-rail advocacy

    Transport Action Canada and Transport Action Ontario. A credible, technically literate, pro-rail civil-society voice with no opposition to the project in principle, no economic interest in its outcome, and a fifty-year record of engagement with Canadian intercity passenger rail policy.

    This matters in two specific ways. First, it forecloses the response that the questions about ALTO’s cost, ridership, document release, and VIA-service impact are coming only from project-affected landowners or from anti-rail critics. They are coming from the country’s principal pro-rail civil-society voice, on the public record, having formally engaged with ALTO through ALTO’s own consultation process. Second, it puts the alternatives that have been considered — including the HPR framework the Initiative has been documenting — into the technical vocabulary of an organization that has the standing to describe them.

    Recommendations That Remain Live

    What still has not been produced

    As of May 2026, the public record shows that:

    The cost analysis Transport Action’s March 2026 letter asked for — and that TRAN Report 18 Recommendation 4 had asked for in September 2024 — has not been produced. The $60–90 billion AACE Class 5 figure in Q-923 stands without it.
    The Joint Project Office report Transport Action’s March 2026 letter asked to be released — and that TRAN Report 18 Recommendation 6 had asked to be released in September 2024 — has not been released. Transport Action’s additional point that the procurement-completion rationale for non-disclosure no longer applies has not been addressed.
    The VIA-impact analysis Transport Action’s March 2026 letter asked for, that the Senate TRCM raised concerns about in February 2026, and that TRAN Report 18 Recommendations 8 and 10 had asked for in September 2024, has not been produced. ALTO’s published material continues to refer to “optimization” of existing VIA services without a binding commitment.
    The ridership-model assumptions Transport Action’s March 2026 letter asked be made public have not been published. The government’s 43-million-by-2084 figure in Q-923 stands without disclosed methodology behind it.

    None of these are partisan demands. None of them is hostile to the project. All of them are recommendations from an established pro-rail advocacy organization, made through ALTO’s own consultation process, asking the same things that Parliament’s own committee was asking. Their continued non-fulfilment is procedural, not substantive — and procedurally, as The Report That Vanished sets out in detail, the questions remain available to be revived by parliamentary or stakeholder action.

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    Sources

    Primary documents and references

    1.
    Transport Action Canada and Transport Action Ontario, Comments arising from ALTO HSR Stakeholder Roundtable and Public Consultation Sessions (letter to Peter Paz, Government and Stakeholder Relations, ALTO), March 16, 2026. Signed by Terry Johnson (President, Transport Action Canada) and Peter Miasek (President, Transport Action Ontario). ontario.transportaction.ca
    2.
    Transport Action Canada, Why did the government chose Alto? (open letter on ALTO HSR route options in eastern Ontario), 2026. ontario.transportaction.ca
    3.
    House of Commons Standing Committee on Transport, Infrastructure and Communities, Issues and Opportunities: High Frequency Rail in the Toronto to Quebec City Corridor. 18th Report, 44th Parliament, 1st Session. Tabled September 2024. ourcommons.ca
    4.
    Order Paper Question Q-923, 45th Parliament, 1st session. Asked by Philip Lawrence (MP for Northumberland–Clarke), March 5, 2026; answered April 22, 2026.
    5.
    ALTO HSR Citizen Research Initiative companion briefs: Reading the Answer (May 2026); Reading the Footnote (May 2026); The Report That Vanished (May 2026); What We Know About ALTO’s Reporting and Accountability (May 2026); Five Hundred Farms (May 2026).