Tag: project governance

  • A deal that lost its other half

    The Billy Bishop Reversal
    A Deal That Lost Its Other Half

    Reporting says Ontario agreed to go along with ALTO in exchange for the Billy Bishop airport expansion. Ottawa has now pulled back from the airport — so if that account is right, what is holding up the province’s side?

    The short version

    A newspaper report describes an informal trade behind the scenes: the province would support the ALTO high-speed rail line, and in return Ottawa would let Billy Bishop airport expand. Ottawa has now pulled back from the airport. If the report is right, the reason Ontario was cooperating with ALTO has just disappeared — and that matters for every community along the route.

    What the reporting says

    In late July 2026, the Toronto Star reported that Ottawa’s decision to drop the Billy Bishop airport expansion was tied to a behind-the-scenes understanding: the province would go along with ALTO, and in exchange the airport expansion would proceed. One source put it plainly — “It’s Billy Bishop for Alto, that was always the understanding.”1 The paper reported the Premier and Prime Minister had even shaken hands on it. It also noted that the high-speed line — a 300 km/h train cutting through farmland in rural Ontario — has always been a hard sell to the province’s own members whose ridings it crosses.

    A private handshake can’t be independently confirmed, and the account rests on unnamed sources. But it was reported in detail, and it fits how difficult the corridor has been for the province to defend.

    What changed

    Ottawa has now pulled back from the airport expansion. In his July 24 statement, the Minister of Transport said the government’s focus is now only on the already-approved safety work, that Toronto voices would shape any future plans, and that it would not pursue anything that harms treasured public spaces, raises noise, damages the environment, or blocks housing — the effects opponents of the expansion had raised.2 The government cited more than 87,000 public responses;2 the Toronto Star reported that about 87 per cent were opposed.1 Some call the decision a cancellation, others a pause1 — but either way, the province is left holding, at best, a promise that has been put on hold. Whatever it was reportedly getting in return for supporting ALTO is, for now, gone.

    Why this matters for the corridor

    ALTO’s Ontario stretch can’t be built by the federal government on its own. It needs the province and local municipalities to cooperate on the hard, unglamorous parts: assembling land, approving where the line crosses roads, relocating utilities, and separating the tracks from local traffic. If that cooperation was really a trade — support given in exchange for the airport — then taking the airport away removes the reason for the support. That uncertainty lands squarely on the towns, farms, and landowners in the train’s path, who still don’t know whether or how the project moves ahead.

    One standard, for everyone

    Ottawa reconsidered the airport by listening: it counted the public responses, weighed the opposition, and set conditions rather than pressing ahead. Yet the same July 24 statement reaffirmed ALTO as part of the government’s integrated plan for the Greater Toronto Area, alongside the Pearson expansion.2 One waterfront project was reshaped by public feedback; the far larger rail project was restated in the same document without reference to any. Communities along the ALTO route raised their objections too, through the project’s own consultation, which closed on 24 April 2026. No comparable count of responses received, or of concerns raised, has been published for that consultation. If 87,000 responses were enough to change course on one waterfront project, the people who live along a much larger one are entitled to know how their objections are being weighed.

    Questions worth asking

    • Does Ontario still support ALTO now that the thing it was reportedly promised is off the table?
    • If the province’s support was tied to the airport, what is it tied to now?
    • Will the communities along the corridor get the same fair hearing that stopped the airport expansion?

    None of this is about one political party. Unease with ALTO crosses party lines. The Star reports the line has been a hard sell to the province’s own members whose ridings it crosses. This is a straightforward question of accountability: if the reported understanding was what it appeared to be, one public decision has knocked a leg out from under another, and the people in the corridor’s path deserve to know where that leaves them.

    How to read this page

    The trade described here is reported by the Toronto Star on unnamed sources. Neither government has confirmed it, and this page does not treat it as established. Everything that follows from it is written conditionally, because that is all the evidence supports.

    Everything else is quoted from the two named sources below and can be checked there: the Minister’s 24 July statement and its conditions, the figure of more than 87,000 responses, the reported 87 per cent opposition, and the reaffirmation of ALTO in the same statement. Where something has not been published, this page says so rather than inferring it, and makes no claim about anyone’s motives.

    Sources

    1. 1Robert Benzie, Ryan Tumilty and Mark Ramzy, “‘Disappointed’ Doug Ford spoke privately with Mark Carney after decision blocking Billy Bishop expansion,” Toronto Star, July 27, 2026.
    2. 2Hon. Steven MacKinnon, Minister of Transport, Statement on Billy Bishop Toronto City Airport, July 24, 2026.
    ALTO HSR Citizen Research Initiative Independent, non-partisan research on the proposed Toronto–Québec City high-speed rail corridor citizenresearch.ca

  • 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.

    Download
    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.
    Download PDF
    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

    4
    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 saysWhat 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.

    Download Full Brief
    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
    Download PDF
    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

    1.
    Elliot Ferguson, “Kingston signs non-disclosure agreement for high-speed rail talks,” The Kingston Whig-Standard, July 14, 2026. thewhig.com
    2.
    “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
    3.
    “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
    4.
    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
    5.
    County of Frontenac, “Council votes to oppose Alto routes through Frontenac County,” April 15, 2026. frontenaccounty.ca
    6.
    “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
    7.
    “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
    8.
    “Exclusive: HS2 paid £1.67m to silence ex-employees,” New Civil Engineer, October 14, 2019. newcivilengineer.com
    9.
    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.
    ALTO HSR Citizen Research Initiative  ·  citizenresearch.ca  ·  Governance and Transparency Brief  ·  July 2026
    Independent, non-partisan research on the proposed Toronto–Quebec City high-speed rail corridor.

  • Ready to tender

    Ready to Tender, Not Yet Approved

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

    ALTO HSR Citizen Research Initiative · Procurement Brief · Published July 2026 · ALTO consultation closed April 24, 2026
    ⚠ What the document says

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

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

    The point in one sentence

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

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

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

    Read the source
    Cadence Preliminary Notice to Market — Central Segment
    A public document (document no. ALTO-CPDP-00000-PW-080000-500BC10-000001F), issued June 2026 by Projet Cadence Rail s.e.c. Available in French and English.
    Download PDF
    What it is

    A tender calendar, not a green light

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

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

    Summer
    2026
    first major tender opens (trains), with stations and the Montreal tunnel to follow through 2027
    Cadence PNM, Table 2
    2029–30
    construction “contemplated,” but with no confirmed start date
    Cadence PNM
    Not yet
    federal investment decision — the build phase is “subject to” it
    Cadence PNM

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

    The Two Columns

    What the notice commits to, and what it leaves open

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

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

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

    The Machinery

    What is actually being tendered

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

    The trains and the systems come first

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

    The tunnel and bridges are tendered before they are fully designed

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

    The benefit numbers arrive without a source

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

    Who Runs It

    Who is in the room

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

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

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

    The Fine Print

    Three things easy to miss

    The contracts would be in English only

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

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

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

    A federal law puts the project largely beyond local jurisdiction

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

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

    Where things stand · July 2026

    Summary ledger

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

    Under way
    Procurement. Tendering for the first segment’s major contracts begins summer 2026 and runs through 2028.
    Under way
    Delivery structure. InfraCo (led by CDPQ Infra) and OpCo are to be set up as the contracting and operating companies.
    Stated but unsourced
    Benefits. $24.5B annual GDP, 50,000+ construction jobs, 5,000 operating jobs — asserted with no study or method attached.
    Not yet done
    Final route. The precise corridor is promised for autumn 2026; the Toronto–Ottawa north/south choice is left open.
    Not yet done
    Business case. No final business case published; the government told Parliament the cost-benefit, NPV, and subsidy figures are “not finalized.”
    Not yet done
    Start date. Construction has no confirmed launch date; 2029–2030 is only “contemplated.”
    Not yet done
    The go-ahead. The build-and-operate phase is “subject to the government of Canada’s final confirmation of the investment” — not reported as given.

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

    Sources

    Primary documents

    1.
    Projet Cadence Rail s.e.c., Preliminary Notice to Market / Avis préalable au marché — Alto Project Central Segment, document no. ALTO-CPDP-00000-PW-080000-500BC10-000001F, dated June 23, 2026 (cover) / June 22, 2026 (milestone table). A public document issued in French and English. All quotations and figures in this brief — the tender schedule (Table 2), the “no official launch date” and “subject to…final confirmation of the investment” language, the WP1–WP17 package structure, the InfraCo/OpCo and consortium structure, the 320 km/h and tunnel specifications, the English-only contract approach, the stakeholder-communication restriction, and the GDP and jobs figures — are drawn from this notice. citizenresearch.ca (PDF)
    2.
    Government of Canada, response to Order Paper Question Q-1191 (Scott Reid, Lanark–Frontenac), House of Commons, tabled June 17, 2026 — source for the statement that the project’s cost-benefit, net-present-value, and 30-year subsidy figures are “not finalized.”
    3.
    ALTO / Cadence, statements that a more precise corridor is to be unveiled in autumn 2026, referenced in the notice’s appendix and in prior public communications.

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

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

  • Sign first, see later

    Sign First, See Later

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

    ALTO HSR Citizen Research Initiative · Research Brief · Published June 2026
    The finding in brief

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

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

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

    What the documents show

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

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

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

    The Municipal Case

    What was actually requested

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

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

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

    “It tells you nothing about the route”

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

    On the public record

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

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

    A pattern, not an exception

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

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

    Why confidentiality changes the calculus

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

    Consent and Transparency

    The tension the precondition creates

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

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

    The Decision

    What the municipalities decided

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

    United Counties of SDG — the landowner

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

    North Glengarry — the host township

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

    Prescott-Russell — the neighbour

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

    Eastern Ontario Wardens’ Caucus

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

    What To Watch

    What happens next

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

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

    Anticipated Objection

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

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

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

    The bottom line

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

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

    Read the full brief offline or share it.

    Download the brief (PDF)

    Sources

    Primary documents and statements

    1.

    ALTO, Indigenous Consultation What We Heard Report (June 2026), incl. p. 14 — initial corridor maps shared only with communities that had signed a collaboration or non-disclosure agreement; ALTO describes the agreements as a means of sharing maps as early as possible. altotrain.ca
    2.

    ALTO, Public Consultation What We Heard Report (June 2026).
    3.

    United Counties of SDG council package, June 15, 2026 — CAO Key Information Report; ALTO presentation, May 5, 2026; Map of Impacted SDG Properties; and By-Law No. 5538.
    4.

    The SDG access vote and councillor statements as reported by the Morrisburg Leader, June 18, 2026.
    5.

    North Glengarry’s April 13, 2026 endorsement of the regional (EOWC) resolution, and its mayor’s continued public opposition — The Review, April 16, 2026, and Cornwall Seaway News.
    6.

    United Counties of Prescott and Russell, Regular Council Meeting, May 27, 2026 — council declined to sign a non-disclosure agreement and refused access for surveys. Meeting agendas and minutes
    7.

    Transport Canada announcement, Kingston, June 22, 2026.
    ALTO HSR Citizen Research Initiative  ·  citizenresearch.ca  ·  Research Brief  ·  June 2026
    Independent, non-partisan research on the proposed Toronto–Quebec City high-speed rail corridor.

  • What Alto told Parliament

    ALTO HSR · Budget Disclosure · June 2026

    What ALTO Told Parliament

    For the first time, ALTO has had to list its contractors by name. The picture is of a head office — not a railway.

    ALTO HSR Citizen Research Initiative · Source: Written Question Q-1087, House of Commons (Sessional Paper 8555-451-1087, tabled June 5, 2026)
    In plain terms

    A Member of Parliament asked the federal government, in writing, five basic questions about ALTO: how much public money it has received, what its budget is, how it is organized, how many people it employs, and every contract it has signed worth more than $10,000. The government’s written answer was tabled in the House of Commons on June 5, 2026.

    The answer is the most detailed look yet at where ALTO’s money has gone — and the first time its contracts have been disclosed by vendor. What it shows: after more than three years and roughly a quarter-billion dollars, the money has gone into building an organization — staff, software, advisers, and communications — and almost none of it into building a railway.

    ⬇ Download this brief as a PDFWhat_ALTO_Told_Parliament.pdf
    How this came to light

    What a written question is — and what this one asked

    In Canada’s Parliament, any MP can put a question to the government in writing. The government is then required to research it and table a formal written answer, which becomes part of the public record. It is one of the main tools MPs have for getting specific facts out of departments and Crown corporations that do not otherwise publish them.

    This question — numbered Q-1087 — was asked on April 20, 2026 by Michael Barrett, the MP for Leeds–Grenville–Thousand Islands–Rideau Lakes, and answered on June 5, 2026 on behalf of the Minister of Transport. It asked ALTO five things:

    • Total funding: how much money ALTO has received from the government since it was created.
    • Operating budget: ALTO’s yearly budget, broken down by type of spending.
    • Structure: how the corporation is organized.
    • Employees: how many people it employs, broken down by position.
    • Contracts: every contract over $10,000 — with the date, amount, vendor, what was bought, and the start and end dates.

    The full question and the government’s answer are on the House of Commons website (link at the foot of this page).

    The Answer

    Four numbers that tell the story

    $266M
    Received from the government since ALTO was created in November 2022 (precisely $265,976,355)
    ~11%
    Share of that money that appears as listed contracts (~$29.5M of ~200 contracts). The rest is mostly salaries and smaller spending
    216
    Employees — of whom 67 (about a third) are directors or above, and only 7 are managers
    1
    Engineering contract among nearly 200 — the rest is software, advisers, recruitment, and communications

    The first figure is the eye-catching one, but it needs care: receiving $266 million is not the same as wasting it. Most of that money pays the people who work at ALTO and covers spending too small to be listed. The point is what it is being spent on — and the contract list answers that plainly.

    Where the Contracts Go

    Software, advisers, and communications — not track

    ALTO listed close to 200 contracts over $10,000. Grouped by what they paid for, the pattern is clear. (The groupings below are ours; the figures are ALTO’s.)

    What the contract paid forShareIn plain terms
    Software & IT systems25%Software licences and one large $4.09M IT system build — the single biggest contract
    Strategic & management advice23%Outside consultants advising the corporation on how to run itself and the project
    Individual consultants13%Named and self-employed contractors
    Data & mapping7%Land-registry data and GIS mapping — growing sharply in 2025–26
    Communications, branding & polling6%PR firms, design agencies, video, and opinion surveys
    Executive recruitment6%Headhunting firms hired to build out the senior team
    Indigenous engagement4%Consultation and advisory work
    Engineering2.5%A single engineering consulting contract

    There are no contracts for civil works, track, signalling, or trains — the things a railway is made of.

    The most expensive single thing ALTO has bought is not a piece of railway. It is a computer system.

    What It Adds Up To

    An organization, not yet a railway

    The numbers describe a head office that is still hiring, buying software, and shaping its public image. For 216 people there are 23 executives — a CEO, 9 chiefs, and 13 vice-presidents — but only 7 managers. ALTO has spent far more telling its story and standing itself up than on the engineering a railway actually requires.

    This is the same pattern our earlier analysis found inside ALTO’s own corporate plan, where communications staff outnumbered environmental scientists 18 to 1. Q-1087 now confirms that pattern with named contracts. After more than three years and a quarter-billion dollars, ALTO is a fully-staffed, executive-heavy organization — and the railway it exists to plan is still entirely on paper.

    A Companion Disclosure

    What ALTO paid itself in bonuses

    A second written question — Q-1058, asked by Andrew Scheer and answered on June 1, 2026 — required every federal Crown corporation to report the bonuses it paid. ALTO’s answer is striking for an organization that has yet to lay a metre of track.

    $2.76M
    Paid in bonuses, for a short-term incentive covering roughly the first half of 2025
    100%
    Of ALTO staff — every executive and every non-executive employee — received a bonus
    ~30×
    ALTO’s bonus pool compared with VIA Rail’s in the same disclosure
    $1M+
    Potential annual compensation for ALTO’s chief executive

    ALTO reported paying $2,758,967.68 in bonuses to 134 people: all 18 of its executives and all 116 of its below-executive staff. The executives shared about $1.23 million (an average near $68,000 each); everyone else shared about $1.53 million (an average near $13,000 each). The payment covers January 1 to July 16, 2025, which ALTO describes as its most recent short-term incentive payment.

    The same parliamentary return lets us set ALTO beside the railway it is meant to complement.

    Crown corporationBonuses paidRecipientsTrains running?
    ALTO$2,758,968134 — 100% of staffNone — still in planning
    VIA Rail Canada$95,50010National network, ~3,500 staff

    VIA Rail’s bonus program reaches only a small group of managers; ALTO’s reaches its entire staff. ALTO, which runs no trains, paid out roughly thirty times what the operating national railway did.

    The pattern starts at the top. According to ALTO’s own business plan summary, reported in May 2025, chief executive Martin Imbleau’s base salary falls between roughly $562,000 and $661,000, with an incentive worth up to 65% of that base — a potential total above $1 million a year. ALTO’s six other top executives have base salaries of $170,000 to $330,000, with bonuses of up to 40%.

    ALTO’s chief executive can earn more than $1 million a year. The head of VIA Rail, who runs an actual national railway with some 3,500 employees, earns about $575,000.

    One Figure to Read Carefully

    The operating budget is almost certainly missing three zeros

    The answer reports ALTO’s 2026–27 operating budget as $710,158 — $549,754 for operating costs and $160,404 for capital. Read at face value, that is impossible: salaries alone for 216 employees run into the tens of millions of dollars a year.

    What almost certainly happened

    Government financial statements are routinely presented “in thousands of dollars.” Read that way, $710,158 becomes about $710 million — which closely matches the roughly $695 million that ALTO’s own corporate plan projects for 2026–27. The likeliest explanation is simply that the answer dropped the “in thousands” notation. The substance is the more important point: ALTO’s operating budget for a single pre-construction year, before any track is laid, is on the order of $700 million.

    Read More

    The fuller picture

    Q-1087 confirms, with named contracts, what ALTO’s own planning documents already implied. Our budget analysis sets out the full $3.9-billion pre-construction spending plan, the workforce breakdown, and the cost-estimate accuracy problem behind it.

    📊 Related analysisThe $3.9 Billion Before the First Shovel — the full budget breakdown, workforce analysis, cost-estimate accuracy, and how ALTO compares with every other project on the government’s nation-building list. → citizenresearch.ca/alto-budget

    Sources

    Written Question Q-1087, House of Commons of Canada — Sessional Paper 8555-451-1087, tabled June 5, 2026 (asked by Michael Barrett, MP; answered on behalf of the Minister of Transport). Funding received, workforce by position, and all contracts over $10,000. ourcommons.ca/written-questions/45-1/q-1087

    Written Question Q-1058, House of Commons of Canada — Sessional Paper 8555-451-1058, tabled June 1, 2026 (asked by Andrew Scheer, MP). Bonuses awarded at Crown corporations, 2025–26, including the ALTO and VIA Rail figures used above. ourcommons.ca/written-questions/45-1/q-1058

    Executive compensation ranges: ALTO (VIA TGF) business plan summary, as reported by Le Journal de Québec, May 26, 2025 — base-salary and incentive ranges for the chief executive and senior executives, and the VIA Rail chief-executive comparison.

  • Norway-review

    What a Norwegian-Style Review Would Ask of ALTO

    Norway has spent twenty-five years subjecting every major public investment to mandatory independent review at two decision gates. Measured against that standard, ALTO’s $75 billion figure has not yet cleared the first gate — and the conceptual choice between the corridor alternatives has never been independently reviewed at all.

    ALTO HSR Citizen Research Initiative · International Precedent Brief · Published May 2026
    ⚠ What This Brief Examines

    Since 2000, Norway has run a mandatory two-gate external Quality Assurance scheme — QA1 on the choice of concept, QA2 on cost estimates before funding — under its Ministry of Finance, for every major public investment project.

    This brief sets out how the scheme works, what twenty-five years of evidence across roughly 160 reviewed projects shows about whether independent review improves cost discipline, and what that working institutional template implies for the ALTO corridor decision and for the High Performance Rail (HPR) alternative the Initiative has advocated.

    Headline Finding

    Twenty-five years of operating evidence shows that systematic external review materially improves cost discipline: roughly three-quarters of post-QA2 projects have been delivered within their parliamentary cost frame, against pre-QA cost overruns documented at 59 to 183 percent on Norwegian transport projects.

    ALTO’s published $75 billion cost figure is a concept-stage estimate that, by Norwegian standards, has been subjected to neither external concept-stage review (QA1) nor stochastic pre-budget cost validation (QA2). A federal investment of ALTO’s scale would unambiguously fall within mandatory independent review under any institutional design comparable to Norway’s.

    Download
    Norway’s Quality Assurance Scheme as Precedent — Full Research Note (PDF)
    Reference note for federal decision-makers, parliamentarians, journalists, and residents along the corridor
    Download Note
    Section 1 · Origin and Purpose

    A scheme built to filter flawed investments

    Norway’s Quality Assurance scheme — kvalitetssikringsordningen, rendered in English as QA1 and QA2 — was established in 2000 by the Ministry of Finance in response to a recurring pattern of cost overruns and weak strategic justification on megaprojects through the 1980s and 1990s. It was built with two objectives: to avoid budget overruns on projects already under construction, and to filter out flawed investment cases that should not have been started at all.

    In its initial form (2000–2005) the scheme was QA2 only — assurance of cost estimates immediately before parliamentary approval. From 2005, QA1 was added as an upstream gate covering the choice of conceptual solution itself, before a project enters preliminary design. The two-gate structure has been substantially unchanged since, with periodic recalibration through Ministry of Finance circulars; the current governing circular is R-108/23, superseded in part by R-108/25.

    The scheme is mandatory. It applies to all government investment projects above a threshold of roughly one billion Norwegian kroner — about CAD 130 million in 2026 terms — and about CAD 39 million for digitalisation projects. The petroleum sector is exempt; state enterprises such as Bane NOR, Nye veier and Statnett run parallel internal regimes that mirror the central scheme. Essentially every Norwegian federal infrastructure investment of comparable scale to ALTO would face mandatory external review at two decision points.

    2000
    Scheme established; QA1 concept gate added 2005
    ~$130M
    Mandatory threshold (CAD); ~$39M for digital projects
    2 gates
    QA1 on concept choice; QA2 on cost before funding
    Section 2 · The Two Review Gates

    One gate on the concept, one on the cost

    The scheme’s power lies in where it intervenes: once on whether the right concept has been chosen, and again on whether the cost presented to Parliament is honest. Each gate has a defined deliverable and a defined methodological standard.

    QA1 — Quality assurance of concept choice

    Performed before Cabinet decides to start a pre-project. The proponent must prepare a Conceptual Appraisal (KVU), and the external reviewer assesses whether the alternatives analysis is genuine — whether the do-nothing case and conceptually different options were evaluated rigorously, rather than treated as nominal foils to a predetermined preference. The recommendation goes to Cabinet on the public record.

    QA2 — Quality assurance of cost

    Performed before the project goes to Parliament for funding. Its core is stochastic cost estimation: not a single figure but a probability distribution, with the budgeted cost normally set at P85 and a P50 target committing the executing agency — because deterministic estimates are systematically skewed and under-assure against overrun.

    The KVU underlying a QA1 review must contain a defined set of elements, and the reviewer checks each:

    • A needs analysis identifying the underlying problem the project is intended to address.
    • A goals and objectives statement specifying the societal outcomes the project is meant to deliver.
    • A requirements analysis identifying functional and operational specifications.
    • An alternatives analysis covering at minimum the zero option (do nothing) plus at least two conceptually different alternatives.
    • A cost-benefit analysis covering each alternative.

    QA2 adds a forward-looking management challenge assessment of operational, procurement, scope and schedule risk, and produces a project-specific reduction list (kuttliste) — pre-identified scope items that can be removed during execution if costs trend toward the upper bound. This preserves flexibility within the parliamentary cost frame rather than requiring re-authorization for each overrun.

    Section 3 · Who Reviews, and How Independence Is Preserved

    The funding ministry picks the reviewer — not the proponent

    The reviewers are external private-sector consultants on a Ministry of Finance framework agreement. The current framework (September 2023) covers seven consortia — including Holte Consulting, Menon Economics, A-2 Norge, Dovre Group Consulting and the Institute of Transport Economics. Use of a pre-approved consortium is compulsory; ad hoc retention outside the framework is not permitted. Several features preserve independence:

    • The Ministry of Finance selects the reviewer — not the project-proposing ministry — removing the conflict that arises when a proponent can choose its own reviewer.
    • Pre-defined methodology. The reviewer follows requirements set in the Ministry circular and cannot redefine scope or renegotiate methodology with the proponent.
    • Conflict-of-interest restrictions. A consortium that did concept-stage advisory work on a project is generally precluded from reviewing the same project.
    • Public reporting. QA reports are public documents (with limited commercial redactions) and are catalogued by NTNU’s Concept Research Programme, which has tracked every review since 2000.

    The review itself is cheap relative to what it examines — typically a fraction of one percent of project capital cost — and is funded by the Ministry of Finance rather than charged against the project ministry.

    Section 4 · The Empirical Record

    Twenty-five years of evidence: review works

    NTNU’s Concept Research Programme has tracked the cost performance of every project subject to the scheme since 2000 — roughly 160 QA2 reviews and 60 QA1 reviews, a sample large enough to draw robust conclusions. The finding is consistent: post-QA2 Norwegian projects substantially out-perform international cost-overrun benchmarks.

    ~75%
    Of post-QA projects delivered within their parliamentary cost frame (Welde & Klakegg, 2022)
    59–183%
    Cost overruns on pre-QA Norwegian transport projects (Odeck, 2004)
    45%
    Mean rail cost overrun across 258 international projects (Flyvbjerg et al., 2003)

    A multi-country study of Scandinavian rail and road projects completed 2008–2022 (Love et al., 2025) concludes they are generally delivered “on cost, over time” — within approved budgets, though often behind schedule. The introduction of mandatory external QA materially compressed the cost-overrun distribution.

    The harder finding: front-end escalation persists

    The more nuanced result concerns the front-end — the period between QA1 and QA2. Even with mandatory concept review, average cost escalation between the two gates has run at about 40 percent (Welde & Odeck, 2017). As a project moves from concept to detailed pre-design, scope clarification reveals cost drivers the initial estimate missed; Norway’s Planning and Building Act, which gives municipalities significant influence over alignment and siting, is a documented contributor. In response, the Ministry introduced a continuous change-log requirement in 2019, tightened further in the 2025 circular.

    Implication for ALTO’s $75 billion

    ALTO’s published $75 billion is a pre-QA1-equivalent estimate. The Norwegian record predicts ~40 percent escalation through the equivalent pre-project phase — which alone would lift the figure to roughly $105 billion, before any of the further adjustments the Initiative’s reference-class analysis applies.

    Section 5 · Norway QA versus Canadian Practice

    The gap is structural, not incidental

    Set side by side with current Canadian federal practice, the differences are structural. The most consequential is at the concept gate: Canada has no equivalent of QA1 — no mandatory external review of conceptual alternatives before a project enters pre-design.

    FeatureNorway QA1 / QA2Canada (federal practice)
    Mandatory threshold≈ CAD 130M (NOK 1B); CAD 39M for ITNo threshold-triggered mandatory external QA
    Concept-stage external review (QA1)Required before Cabinet approves pre-projectInternal departmental review only; none mandatory
    Pre-funding external review (QA2)Required before Storting funding voteTreasury Board review; not external; not stochastic by default
    Cost basis for ParliamentP85 of probability distributionTypically a deterministic point estimate
    Reviewer selectionMinistry of Finance call-off against frameworkProposing department selects its own consultants
    Public availability of reportPublic document (with redactions)Generally not published; subject to ATIP
    Concept alternatives requiredZero option plus ≥ 2 different alternativesVariable; not standardised
    Track record≈160 reviews; ~75% on budgetNo comparable institutional record

    ALTO is a paradigmatic example of the gap. The conceptual choice between high-speed rail (ALTO), high-frequency rail (HFR, the 2021 Joint Project Office concept), and high-performance rail (HPR, the Initiative’s alternative) has never been the subject of structured external review. Under Norwegian rules, that comparison would be the literal substantive content of QA1 — and Cabinet could not authorize a pre-project on any one concept without first having the comparison externally reviewed.

    Section 6 · Application to the ALTO Decision

    Five things a Norwegian review would find

    Applying the Norway framework as an analytical lens to ALTO yields five specific findings.

    1

    The cost figure would not be acceptable to a Norwegian Parliament

    QA2 requires the parliamentary cost frame to be set at P85 of a stochastic distribution. ALTO’s $75 billion is a deterministic point estimate — not acceptable as a funding basis by Norwegian standards, however rigorously derived internally. The Initiative’s reference-class range ($143B central; $264B P97.5) is a conservative analogue of what QA2 would produce.

    2

    The conceptual-alternatives requirement has not been met

    QA1 requires the zero option plus at least two conceptually different alternatives. The comparison among ALTO, HFR and HPR has not been structured, has not been externally reviewed, and is not in public ALTO documentation. A QA1 reviewer would not have approved corridor selection on the documentation produced to date.

    3

    ALTO is the kind of investment QA1 exists to filter

    The Initiative’s iso-BCR analysis finds a benefit-cost ratio of about 0.11 at central reference-class parameters — roughly eleven cents of benefit per dollar invested. That is the textbook profile of a flawed investment case, precisely what QA1 was built in 2000 to flag for substantive reconsideration.

    4

    The HPR alternative warrants concept-stage review

    HPR — electrified passenger service along the Highway 401 corridor with freight relocated onto a parallel dedicated corridor — is a substantively different concept, developed to a level comparable to proponent-stage QA1 documentation. The next institutional step is an independent concept-stage review of all three alternatives before any final corridor selection.

    5

    An adapted Canadian framework is feasible and proven

    Norway is not unique — comparable schemes operate in the UK, the Netherlands and at the European Investment Bank. The absence of a Canadian equivalent is a gap in institutional design, not a settled choice, and the design work is substantially complete in the English-language academic literature.

    Section 7 · Recommendations

    Three steps, project-specific to institutional

    Three recommendations follow, ordered from immediately applicable to the ALTO decision through to broader federal investment governance.

    1. Independent concept-stage review of the three corridor alternatives. Before any final corridor selection, the Department of Finance should commission an external review of ALTO, HFR and HPR modelled on QA1 — conducted by a consortium not previously engaged on any of the three, against pre-defined methodology, with a public report tabled before the Cabinet decision on the preferred concept.
    2. Stochastic cost framing for any preferred concept. Whichever concept is chosen, the Treasury Board submission should rest on a probabilistic cost distribution, not a point estimate — with the parliamentary frame at P85, a P50 target committing the agency, and a documented reduction list. This is the QA2 standard and the minimum-acceptable framing for an investment of this scale.
    3. A Canadian QA scheme. Canada lacks a federal equivalent of QA1/QA2, and the absence is structural. The 2021 JPO Business Case for HFR — still unreleased, with the Initiative’s Access to Information request pending — would under Norwegian design have been a public QA1 deliverable. Establishing a Canadian analogue would address a weakness documented across multiple Auditor General reports.
    Where Things Stand

    A working template, and an unreviewed decision

    Norway has demonstrated, over twenty-five years and 160-odd projects, that mandatory independent review at the concept and cost gates materially improves how major public investments perform. Canada has no equivalent — and ALTO, a federal investment of paradigmatic scale and policy importance, is advancing toward corridor selection without its conceptual choice having been independently reviewed, and on a deterministic cost figure that by Norwegian standards could not anchor a funding vote. The template exists; the decision has not yet been tested against it.

    Download Full Note
    Norway’s Quality Assurance Scheme as Precedent (PDF)
    Reference note for federal decision-makers, parliamentarians, journalists, and residents along the corridor
    Download Note
    Sources

    Sources and supporting documents

    1.
    Norwegian Ministry of Finance. Circular R-108/23 (English translation R-108/25), “The State Project Model: Quality Assurance of Major Public Projects.” The current governing circular for the QA scheme.
    2.
    NTNU Concept Research Programme. “The QA Scheme — QA1 and QA2.” ntnu.edu/concept. Has tracked every QA review since the scheme’s inception in 2000.
    3.
    Samset, K., Volden, G.H., Olsson, N., & Kvalheim, E.V. (2015). “Governance Schemes for Major Public Investment Projects.” Concept Research Programme Report No. 47, NTNU.
    4.
    Welde, M., & Odeck, J. (2017). “Cost escalations in the front-end of projects — empirical evidence from Norwegian road projects.” Transport Reviews 37(5).
    5.
    Odeck, J., Welde, M., & Volden, G.H. (2015). “The impact of external quality assurance of cost estimates on cost overruns.” European Journal of Transport and Infrastructure Research 15(3).
    6.
    Welde, M., & Klakegg, O.J. (2022). “Cost performance in major public investment projects after external quality assurance.” Concept Research Programme. Source of the ~75% on-budget finding.
    7.
    Love, P.E.D., Ahiaga-Dagbui, D., et al. (2025). “On cost, over time: How Scandinavian transport infrastructure challenges conventional understanding of project delivery performance.” International Journal of Project Management.
    8.
    Christensen, T. (2011). “The Norwegian front-end governance regime of major public projects.” International Journal of Managing Projects in Business 4(2).
    9.
    Flyvbjerg, B., Skamris Holm, M.K., & Buhl, S.L. (2003). “How common and how large are cost overruns in transport infrastructure projects?” Transport Reviews 23(1), 71–88.
    10.
    Odeck, J. (2004). “Cost overruns in road construction — what are their sizes and determinants?” Transport Policy 11(1), 43–53.
    11.
    Initiative supporting documents: ALTO NPV Research Report (full NPV methodology and JPO 2021 comparison); ALTO Iso-BCR Research Note (the parameter space within which BCR = 1 is achievable); and ALTO NPV Analysis v3 (Excel model with iso-BCR sheets, discount-rate comparison, and Monte Carlo).
    ALTO HSR Citizen Research Initiative  ·  citizenresearch.ca  ·  International Precedent Brief  ·  May 2026
    Independent, non-partisan research on the proposed Toronto–Quebec City high-speed rail corridor.

  • 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.

    Download
    Reading Lovegrove — Full Brief (PDF)
    Detailed analysis of the Lovegrove Review’s findings and their direct application to ALTO’s current trajectory
    Download PDF
    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.

    YearPhase 1 cost estimate (£bn, 2019 prices)
    201220.5
    201326.8
    202044.6
    202354
    202466
    202682.2

    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.

    Download Full Brief
    Reading Lovegrove (PDF)
    Complete analysis for parliamentarians, the Parliamentary Budget Officer, the Auditor General, and constituents tracking ALTO’s governance and procurement
    Download PDF
    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.

  • Alto accountability

    What We Know About ALTO’s Reporting and Accountability

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

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

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

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

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    ALTO’s Accountability Architecture — Full Brief (PDF)
    Comprehensive analysis of ALTO’s governance, reporting obligations, contractual opacity, and the gaps documented in Senate testimony
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    The Structure

    Three structural facts

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

    $60–90B
    public cost estimate, characterized by ALTO’s CEO as a working assumption
    Imbleau, May 2 interview
    0
    enabling Acts of Parliament establishing ALTO’s mandate, powers, or accountability
    created by Order-in-Council, 2022
    Same
    parliamentary reporting regime as Canada Post applies to ALTO
    FAA Part X, by deemed designation

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

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

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

    The Reporting Architecture

    What Parliament actually receives

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

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

    Two Officials, One Framework

    What senior officials have told the Senate

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

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

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

    Currently Outside Public View

    What is not in the public domain

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

    The ALTO–Cadence agreement

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

    The financing structure

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

    The ALTO corporate plan

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

    The operational governance instruments

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

    Two Clarifications from the February Hearing

    Corrections to the public record

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

    ALTO is not designated under Bill C-5

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

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

    The federal declaration is designed to displace provincial environmental assessment

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

    Why This Matters

    Expropriation powers without proportionate oversight

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

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

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

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

    What the Initiative Is Calling For

    Four steps that would close most of the gap

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

    Within Parliament’s authority now

    Enabling legislation for ALTO An Act of Parliament establishing ALTO’s mandate, powers, and reporting obligations, replacing the Order-in-Council foundation. This brings ALTO into line with other parent Crown corporations of comparable scale and provides Parliament with a statutory anchor for future oversight.
    Public release of the ALTO–Cadence contract With redactions only for genuinely commercial-sensitive information, on the model of routine federal procurement disclosure. The contract that the government has identified as the project’s first layer of accountability cannot serve that function while it remains sealed.

    Standing committee actions

    A Parliamentary Budget Officer review of the project’s economic case, including the benefit–cost ratio, the cost-estimate methodology, and the public-private financing assumptions. A senator has already raised this question with the Minister of Transport at the Transport and Communications Committee, where the Minister confirmed that the PBO is available to senators.
    A standing committee study of the project’s governance and procurement architecture, addressing the gaps documented in the February hearing. Such a study can be initiated under existing Senate or House committee mandates without requiring legislative change.
    Sources

    Primary documents and proceedings

    1.
    Standing Senate Committee on National Finance, Evidence, February 4, 2026 — subject-matter study of Bill C-15. Witnesses from Transport Canada High-Speed Rail Initiative. sencanada.ca
    2.
    Standing Senate Committee on Transport and Communications, Evidence, December 2025 — testimony of the Minister of Transport on the High-Speed Rail Initiative. sencanada.ca/committees/trcm
    3.
    Bill C-15, Budget Implementation Act, 2025, No. 1 — the High-Speed Rail Network Act is contained in Division 1 of Part 5. parl.ca
    4.
    Financial Administration Act, R.S.C. 1985, c. F-11, Part X (Crown corporations). laws-lois.justice.gc.ca
    5.
    Andrew Pinsent, “High-Speed Rail in Eastern Ontario: Rural Backlash, Land Expropriation and Next Steps,” CFRA / Substack, May 2, 2026 — carrying the Imbleau interview confirming acquisition footprint and working-assumption status of the cost figure. Substack
    6.
    Order-in-Council establishing VIA TGF (now ALTO) as a wholly-owned subsidiary of VIA Rail, 2022. Order-in-Council records available through the Privy Council Office. orders-in-council.canada.ca
    7.
    VIA HFR – VIA TGF Inc. (Alto), Corporate Plan Summary 2025–26 to 2029–30. Tabled summary of the corporation’s corporate plan under Part X of the Financial Administration Act. Source for the board appointment mechanism, the C-5 active-representation language, the expropriation legislative-streamlining language, and the three named operational accountability instruments. altotrain.ca
    ALTO HSR Citizen Research Initiative  ·  citizenresearch.ca  ·  Governance Brief  ·  May 7, 2026
    Independent, non-partisan research on the proposed Toronto–Quebec City high-speed rail corridor.