The Voice ALTO Has Already Heard From
Transport Action Canada and Transport Action Ontario — the country’s principal pro-rail civil-society voice — have made detailed substantive recommendations about ALTO. What they asked for. What the record shows ALTO has so far addressed. What their voice contributes that nothing else in the public record does.
On March 16, 2026, Transport Action Canada and Transport Action Ontario submitted an 18-recommendation written response to ALTO at the close of the January–March 2026 consultation period. The organizations also published an open letter setting out what they believe the substantive questions about the project are, and what credible alternatives have been studied previously.
They are explicitly pro-rail. They are not opposed to high-speed rail in principle. Their concerns are technical, financial, and service-continuity concerns, and they are asking for the same documents and analyses that Parliament’s own Transport Committee asked for in September 2024 — and that have not been produced.
The questions about ALTO’s cost, ridership, document release, and VIA-service impact are not coming only from project-affected landowners, from anti-rail critics, or from research initiatives. They are coming from the country’s principal pro-rail civil-society voice, in March 2026, on the public record, having formally engaged with ALTO through ALTO’s own consultation process.
The brief sets out what Transport Action asked for, what the record shows ALTO has addressed, and what credible alternatives they have publicly identified.
Who Transport Action is
Transport Action Canada describes itself as “Canada’s citizen advocacy organization for public transportation,” with members who have “discussed and debated the subject over the past five decades, including of course High Speed Rail and possible alternatives.” It and its provincial affiliates — including Transport Action Ontario, jointly authoring the consultation letter analysed here — are the principal national civil-society voice on Canadian intercity rail policy.
Their position on ALTO is unambiguous. The open letter opens by welcoming “serious discussion of all options to improve passenger rail.” The consultation letter opens by describing the organizations as “a knowledgeable, passenger-focussed NGO that is very supportive of intercity passenger rail.” They explicitly recognize the underlying problem ALTO is intended to address — that VIA Rail’s constrained access to CN’s Kingston Subdivision “has long been recognized as untenable, which prompted the development and launch of VIA’s High Frequency Rail proposal in 2015.”
They acknowledge the limits of incremental improvement: “just improving the CN route in isolation while continuing to operate alongside freight would not come close to the quintupling of capacity and slashing of travel times possible with some kind of dedicated track.” They are, in plain terms, an organization that wants more passenger rail in Canada and is substantively critical of how this particular HSR project is being delivered.
The March 2026 consultation response
Transport Action’s March 16, 2026 letter to ALTO’s Government and Stakeholder Relations office contains eighteen specific recommendations across seven sections. The four recommendations that most directly overlap with the existing CRI evidence base are set out below.
“There is considerable skepticism from the public and stakeholders about the business case for HSR… It is urgent that a detailed Business Case be completed as soon as possible, including preferred corridor, capital cost, detailed ridership, fares, revenue and methods of calculation.”
This is, in substance, the same request as Recommendation 4 of TRAN Report 18 (September 2024), which asked the Minister to require an HFR-versus-HSR cost analysis within six months. As CRI’s brief The Report That Vanished documents, that analysis was never produced. Transport Action is asking, eighteen months later, for the same kind of cost-and-business-case work.
“No details are provided on the ridership model, population assumptions, network assumptions, demand per segment, fares, cost of gasoline etc. Although the ridership assumption may be reasonable when lifted from European ridership, there is skepticism that this would be replicated in central Canada, due to lower fuel prices, absence of road tolls etc.”
This maps directly onto Claim 3 in Reading the Answer — the government’s 43-million-by-2084 ridership figure in Q-923. Transport Action specifically raises the central-Canadian fuel-price and road-toll conditions that distinguish the corridor from the European benchmarks, and quantifies the Ontario provincial subsidy to personal car use at $2.5 billion per year as a “politically tilted playing field” that any credible ridership model must account for.
“We urge you to release a full unredacted version of the JPO report, plus any other reports that were in the ‘data room’ made available to the three bidders. At this time, with the tender process completed, there should be nothing in these reports that is business-confidential.”
This is — almost word for word — the same request as Recommendation 6 of TRAN Report 18. Transport Action makes an additional point that the procurement-completion rationale for non-disclosure no longer applies: with the bidder data-room phase concluded, there is no remaining commercial confidentiality argument. The reports have still not been released.
“Recent media reports from Kingston regarding possible diminution of current VIA Rail services when ALTO is operational must be heeded… It is important that ALTO and VIA Rail jointly issue a statement promptly about plans for services at these cities. Otherwise, local elected officials and residents will continue to impede ALTO’s progress.”
This maps directly onto Recommendations 8 and 10 of TRAN Report 18 — the VIA-impact analysis and the no-service-reduction commitment, both unanswered since September 2024. The Senate TRCM raised the same concern in February 2026. The question has now been asked across two parliamentary chambers and one substantial stakeholder consultation submission; it has not been substantively answered.
Transport Action’s remaining fourteen recommendations cover downtown and shoulder station design, affordable fares, intercommunity bus access for towns currently outside the rail network, emergency-management cooperation with rural fire and EMS, wildlife crossings, sufficient road and trail bridges, recognition of Ontario’s 1834 Drainage Act, First Nations contingency planning for archaeological discovery, sensitive-agricultural-use mapping (sugar bushes, vineyards, certified organic land), and compensation frameworks for intensive agricultural operations that would need to be relocated. Several bear directly on issues documented in CRI’s Five Hundred Farms brief.
What pro-rail technical analysis says is possible
A question CRI has not previously had answered by a technically literate pro-rail body: were credible alternatives to ALTO actually studied, and what did the studies show? Transport Action’s open letter identifies three.
Targeted CN-route improvements
“Further investments to improve passenger and freight fluidity, like the third track between Belleville and Napanee and station improvements… would make a big difference to reliability at modest cost.”
Transport Action concedes this alone is insufficient to deliver the “quintupling of capacity and slashing of travel times” possible with a dedicated track — but lays out a complementary package of known modest cost.
The freight grand bargain
“Moves most CN freight over to the CPKC route through Perth… The existing CN route could then be upgraded to support more passenger services at up to 170 km/h, with travel times of around 4 hours between Toronto and Montreal or Ottawa.”
This is the High Performance Rail framework substantially as CRI has documented it, here independently advocated by Transport Action as a technically credible option.
HFR on the original Havelock alignment
“A dedicated track that takes a more direct route between Toronto and Ottawa, with the advantage of reconnecting Peterborough to the railway network, was VIA Rail’s preferred option, while also preserving service on the existing route through Kingston.”
This is the project the Joint Project Office was funded in 2017 to study, the project the Transport Committee studied in 2023–24, and the project the federal government redesignated in late 2024.
Why earlier HSR-along-the-lakeshore studies did not proceed
Of independent technical interest is Transport Action’s observation about why HSR following the Lake Ontario lakeshore has been studied multiple times without proceeding:
High Speed Rail following a lakeshore from Toronto through Kingston has also been studied before, more than once, by both the federal and provincial governments, without proceeding. For safety reasons, and to achieve 7 km+ minimum radii for higher speeds, such a dedicated track could not be placed too close to the existing alignment nor right alongside Highway 401. It would thus require significant expropriation, and the number of homes and businesses close to CN’s tracks and the 401 has only grown since the last such study in 2011. The chances are that communities like Port Hope and Trenton would be bypassed entirely, and route from Kingston to Ottawa would also then also go through the same sensitive Frontenac Arch region and many of the communities expressing most concern about Alto’s southern study corridor.
This is the route-geometry argument set out by a pro-rail body with the technical standing to make it — the same observation about HSR’s 7-km curve-radius requirement that CRI’s engineering research has documented, here presented as a published critique by an established advocacy organization.
A fifth source category, otherwise absent
The Citizen Research Initiative’s briefs to date have drawn on four categories of source. Each has its own evidentiary weight; each has its own limitations. Transport Action contributes a fifth that has been substantively absent until now.
Order Paper questions, Transport Committee reports, Senate committee testimony, the High-Speed Rail Network Act. Authoritative but procedurally bounded.
The McGill Transportation Research and Munk School Global Economic Policy Lab analyses. Methodologically rigorous but bounded by funding and study scope.
The Canadian Press and Globe and Mail reporting; CBC News; Globe coverage of the NFU response. Documentary but episodic.
OFA, UPA, CFA, BFO, NFU. Authentic to affected communities but advocating for their members’ specific interests.
Transport Action Canada and Transport Action Ontario. A credible, technically literate, pro-rail civil-society voice with no opposition to the project in principle, no economic interest in its outcome, and a fifty-year record of engagement with Canadian intercity passenger rail policy.
This matters in two specific ways. First, it forecloses the response that the questions about ALTO’s cost, ridership, document release, and VIA-service impact are coming only from project-affected landowners or from anti-rail critics. They are coming from the country’s principal pro-rail civil-society voice, on the public record, having formally engaged with ALTO through ALTO’s own consultation process. Second, it puts the alternatives that have been considered — including the HPR framework the Initiative has been documenting — into the technical vocabulary of an organization that has the standing to describe them.
What still has not been produced
As of May 2026, the public record shows that:
None of these are partisan demands. None of them is hostile to the project. All of them are recommendations from an established pro-rail advocacy organization, made through ALTO’s own consultation process, asking the same things that Parliament’s own committee was asking. Their continued non-fulfilment is procedural, not substantive — and procedurally, as The Report That Vanished sets out in detail, the questions remain available to be revived by parliamentary or stakeholder action.