Tag: road severance

Where you put a railway

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

Where you put a railway decides almost everything else

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

Chapter 5 · The HPR Research Report · September 2026

−15 Mt

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

+15 Mt

Carbon added over the same period by the greenfield route

29 v 65

Community friction scores, brownfield against greenfield

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

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

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

1. Carbon: the two routes have opposite signs

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

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

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

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

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

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

Why the freight credit matters so much

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

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

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

2. Habitat: a new barrier in the wrong place

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

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

The Frontenac Arch

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

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

The Napanee Limestone Plain

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

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

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

3. Construction: where the trucks go

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

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

The honest size of the carbon saving

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

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

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

4. Communities: friction is priced into the cost

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

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

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

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

One thing that cuts the other way

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

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

5. What the corridor could give back

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

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

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

Being clear about the numbers

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

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

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

How to read the numbers on this page

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

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

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

Read the full chapter

Chapter 5 — Environmental and Community Impact (PDF)

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

Sources and notes

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

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

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

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

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

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

September 5, 2026

Counting the crossings

Counting the Crossings

ALTO says it will not wall off communities, and points to France and Spain. Those countries did something else as well, and the letter leaves it out.

ALTO HSR Citizen Research Initiative · Analytical Brief · Published August 2026

⚠ What ALTO Told Kingston Readers

On 14 August 2026, a letter in the Kingston Whig-Standard from ALTO’s Chief Project Management Officer and Cadence’s Project Director told corridor residents the railway “will not create a wall between communities”, nor a barrier to wildlife or water. As proof it can be done, the letter offered two numbers: France has built more than 4,000 structures across roughly 2,700 km of high-speed line, and Spain more than 900 across roughly 750 km.

The letter does not mention Kingston, the route, where stations would go, what any of it costs, or expropriation. It does say preserving access has been a key principle from the beginning. ALTO’s own Preserving Access and Movement page carries a last-modified date of 7 May 2026 — after the consultation closed on 24 April.

The Short Version

Take ALTO’s own figures and divide them through. France works out to about one structure every 675 metres. Spain, about one every 833 metres. Those are the rates being offered as reassurance.

The trouble is that a count of structures built tells you nothing about how many crossings were closed. A railway can put in 900 bridges and still cut off 3,000 field entrances, farm lanes and township roads. The letter gives the top half of the fraction and leaves out the bottom.

Kingstonians already have ALTO’s own answer to this. In February 2026, ALTO’s Vice-President of Systems Engineering told Kingston City Council that crossings would be consolidated to bring costs down, and that the company would try to limit how many overpasses get built. That was six months before the letter, to the same city, on the same subject.

There is a larger omission. France did not solve farm severance with bridges. It has a legal procedure that lets the state reorganise the surrounding farmland so that a farm cut in two can be put back into a workable shape, paid for by the project. On one French high-speed line, 3,700 hectares of land were bought up in advance so that farmers could be compensated in land rather than only in cash. Ontario has nothing of the kind.

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Counting the Crossings — Full Brief (PDF)

The arithmetic behind ALTO’s France and Spain comparison, and the land instrument the letter leaves out

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The Arithmetic

What ALTO’s own numbers work out to

Neither figure in the letter is disputed here. They are simply divided through. A structure count only becomes meaningful once you know how far apart the structures are, and how far apart the things they are meant to replace used to be.

~675 m

average gap between structures on the French network, using ALTO’s figures

4,000 structures over 2,700 km

~833 m

average gap on the Spanish line ALTO cites

900 structures over 750 km

1.25–2 km

typical spacing of public roads across eastern Ontario’s concession grid

before counting farm lanes and driveways

There is a third number the letter does not offer, and it cuts the other way. HS2 in Britain is the most recent comparable project of this kind: a brand-new high-speed line built through peri-urban and rural England. Its first phase runs about 225 km and will carry more than 500 bridging structures, including over 50 major viaducts — roughly one structure every 450 m. That is about half again the French rate, through country a good deal more built up than eastern Ontario. The most recent comparable project provided more, not fewer, than the average ALTO offers as reassurance.

The spread between the three is itself worth noticing. A fifty per cent difference between two European networks tells you that these totals are governed by terrain, by how much of a route sits in tunnel or on viaduct, and by what each project counts as a structure. About nine tenths of HS2’s first phase runs in tunnel, in cutting or on structures, so a large share of those 500 exist to carry the railway over the landscape rather than to carry a community across the railway. A structure count is a construction statistic, not a standard of community access.

Eastern Ontario was surveyed on a grid. Roads run at regular intervals, and between them sit farm lanes, private driveways and municipal drains. Whether a European average is enough for that grid is exactly the question people along the corridor are asking. Quoting the French figure does not answer it. It assumes the answer.

There is a comparison closer to home that nobody has yet made. Highway 416 is a modern, fully grade-separated corridor built through the same survey grid, the same farmland and several of the same municipalities. How many crossings Ontario provided on that road is not something this brief has established, but it is the obvious yardstick, and it ought to be established before a French average is relied on.

The Missing Number

How many roads are we talking about?

The denominator is not actually a mystery. Canada’s own transport department has published it.

In a briefing note prepared for a Parliamentary committee in March 2023, Transport Canada set out what a full high-speed line between Québec City and Toronto would require: a fully enclosed and fenced corridor, a straighter alignment, double tracking throughout, and complete grade separation on a route that currently carries more than 1,000 public and private crossings.

That figure described the northern route, through comparatively empty country — Canadian Shield, wetlands, big rural lots. The southern corridor now being prioritised runs through some of the most intensively farmed land in eastern Ontario, where the concession grid is tightest. On the southern option, 1,000 is more likely a floor than a ceiling.

The Initiative’s own road severance analysis puts the proportion of crossings permanently closed rather than bridged on rural high-speed corridors at somewhere between 30 and 60 per cent. Applied to a floor of 1,000, that is 300 to 600 roads dead-ended — our estimate, not a figure ALTO or Transport Canada has published.

1,000+

public and private crossings on the alignment

Transport Canada, March 2023

300–600

roads likely closed, on the Initiative’s estimate

30 to 60 per cent of crossings

$3.2–8.4B

Initiative’s estimated cost of the crossings that would be built

never shown as a separate line

That last figure matters for a different reason. Grade separation is one of the most expensive parts of any high-speed corridor, and a sum of that size has never appeared as its own line in ALTO’s published capital estimate. Neither has any methodology explaining how many crossings will be built, or to what standard, or how it will be decided which roads are simply stopped up.

The reassurance in the August letter is offered in the absence of the one document that could support it. Further detail is set out in the Initiative’s technical analysis of road severances.

On the Record

What ALTO told Kingston in February

Six months before this letter appeared in Kingston’s paper, ALTO’s Vice-President of Systems Engineering and Interface sat before Kingston City Council and was asked about exactly this. The transcript is the fullest account ALTO has given in public of how it approaches road crossings, and it does not read the way the letter does.

The reassurance

Asked by a councillor whether there would be a standard distance between crossings, he described a working assumption that every road would get some form of duct or overpass, since the roads belong to municipalities or road authorities and cannot be cut unilaterally.

The qualification, in the same answer

He went on to say that in reality some crossings would be looked at for consolidation, to lower costs and improve construction, subject to discussion with the road authority.

The objective

Pressed by the Deputy Mayor, he set it out plainly: grade separations would vary by area, would be settled during route selection, and ALTO would “try and limit the number of overpasses that we’ll need to get created”.

And the fencing

He confirmed that modern high-speed rail must be completely segregated and fully fenced anywhere level access is possible, whether the line runs at 200 or 300 km/h.

Read together: a starting assumption that is subject to cost-driven consolidation, an explicit goal of building as few overpasses as possible, and continuous fencing between whatever crossings survive.

The councillor’s actual question — is there a standard distance between crossings — was not answered, and no standard has been published since. February’s statements and August’s letter were addressed to the same city.

Three Problems

Why the structure count does not settle it

You are being shown half a fraction

The number that answers the severance question is a ratio: structures built, divided by accesses cut off. The letter supplies only the first. Every complaint recorded by French and Spanish farmers over the last forty years is perfectly compatible with the figures quoted.

Not every structure reconnects anything

“Engineering structures” and “viaducts” include everything the railway needs to build itself: bridges over rivers, crossings of existing motorways and railways, tunnels through hills. A viaduct over a river gorge restores nobody’s access to their back field. How many of the 4,000 exist to reconnect a severed local road or laneway is not stated, and is certainly a much smaller number.

A different landscape

The French network largely runs through consolidated farming country. Eastern Ontario is a survey grid of concession roads, side roads, long farm lots and dead ends. The same rate of crossings produces a very different result depending on how much there was to cross in the first place.

The Missing Piece

What France also built

The most important thing missing from the letter is not a number. It is a law.

Two of the countries with the longest high-speed rail experience did not leave farm access to be worked out project by project. They legislated it. France did so through its rural code; Germany passed a federal land consolidation statute in 1953 that covers exactly this situation. In both, farmers sit on the body that decides, that body can compulsorily redraw the farms and the farm tracks together, the proponent pays, and there is a right of appeal to the courts.

France has a statutory procedure called aménagement foncier agricole et forestier — land reorganisation, formerly known as remembrement. Its stated purpose includes repairing the damage that major linear projects, high-speed railways among them, do to rural land. Where a line slices a farm in half, the surrounding parcels can be legally reorganised so that holdings are handed back in a shape a farmer can actually work. Local commissions run it under departmental authority, and the project pays for it.

Land is also bought up ahead of time. A national rural land agency, SAFER, holds first refusal on farmland coming up for sale, so that displaced farmers can be given land instead of only a cheque. Spain has its own version of the same idea.

This matters for who gets a say. In Canada there is no seat and no statutory role. On 4 June 2026 the five organisations representing effectively the whole farm sector in Ontario and Quebec concluded that ALTO’s proposed collaboration agreement was not in their members’ interests to sign. In France they would not have had to negotiate for a place at the table. They would already have had one, in law.

This is not a minor administrative detail. On the Le Mans to Rennes high-speed line, roughly 3,700 hectares were placed in reserve, with agricultural land bought up as it came to market within three kilometres of the future route. In Ille-et-Vilaine alone, 48.5 km of new railway took about 480 hectares of crops and pasture — and against that, 720 hectares of land reserve were assembled and parcels across some 1,200 hectares either side of the track were reorganised, affecting more than 4,400 landowners, financed by the project and delivered through intercommunal commissions.

In France and Germany	In Ontario
A legal procedure to reorganise farmland around a new line, whose express purpose includes repairing damage done by major linear infrastructure.	No equivalent. There is no statutory land reorganisation for farms severed by infrastructure.
Farmers hold seats on the deciding body, and decisions can be appealed to the courts.	No seat and no statutory role. Five farm organisations declined ALTO’s collaboration agreement in June 2026 rather than accept its terms.
A rural land agency with first refusal on farmland coming to market, used to assemble land reserves years ahead of construction.	No equivalent agency and no statutory land reserve mechanism.
Local commissions empowered to redraw parcel boundaries, operating under departmental authority.	No equivalent body. No one can redraw the neighbours’ boundaries to make a severed farm whole again.
Compensation in land is possible: a farmer who loses acreage can be given workable acreage back.	Compensation in money only, for what is physically taken. Expropriation and negotiated purchase are the available tools.

So the comparison in the letter is accurate and, at the same time, does not carry over. The French result rests partly on a legal instrument Canada does not have. A letter that cites France’s bridge count while saying nothing about France’s land reorganisation is describing half of how the problem was solved.

Cadence’s Project Director is quoted in French farming trade coverage of that same Le Mans to Rennes project, explaining that the land reserve had to account for the right-of-way, the land reorganisation and the environmental compensation together.

That gap is a problem in Canadian law rather than a failing of the project sponsor. It is still a gap, and it has to be closed before European results can reasonably be promised here. Closing it is not something ALTO can do on its own.

Not Just How Many

A structure is not automatically an answer

Even where a crossing is built, two questions decide whether it is any use, and ALTO has published nothing on either.

Size

A livestock crossing and a machinery crossing are not the same structure. A standard cattle underpass runs about 2.1 metres high. A modern combine or grain cart needs 4 metres or more. A structure built to the wrong dimension is a closure as far as the equipment is concerned. No minimum dimensions have been published, and no spacing standard.

Upkeep

Nobody has decided who maintains these crossings over the decades that follow. ALTO describes its approach as still being developed. France took roughly a decade of litigation and legislation to settle the same question. Municipalities along the corridor have a direct interest in the answer.

What closure pushes onto the road

When a farm crossing is extinguished, the equipment does not disappear. It goes onto the public road. By the Ontario Federation of Agriculture’s own figure, slow-moving farm vehicles are 3.8 to 4.8 times more likely to be involved in a fatal collision per kilometre travelled. Severance is therefore also a road-safety question, and one that has not been assessed.

The Initiative has examined the two halves of this problem separately: road severances and wildlife crossings.

The Wall

One claim that cannot be tested as written

A railway running at over 300 km/h is fully grade-separated and fenced along its entire length. That is what grade separation means. The structure is a continuous barrier by engineering necessity. The real question is where the openings are and how many there are, not whether the barrier exists.

What ALTO could reasonably promise is that severance will be mitigated at designed crossings, to a stated standard, at a stated spacing. A flat undertaking that no wall will be created is not something anyone can test — and it is a sentence that will be read back to ALTO by every landowner and every township that later finds an access closed.

The same applies to wildlife. Continuous fencing is a barrier to animals except where crossings are designed in, and how well those crossings get used varies a great deal by species — a question examined at length in the Initiative’s work on wildlife crossings.

An early study along a Spanish high-speed line, monitoring fifteen underpasses and two overpasses over two years, recorded no deer or wild boar crossings at all. That was 1996, and crossing design has moved on a great deal since; it should not be read as the last word. But the more recent evidence does not settle the question the other way either. A systematic review of crossing structures across roads and railways found that animals did cross them in almost every study examined — and yet a decline in wildlife movement after construction was prevented in fewer than 40 per cent of cases, with many structures poorly built or poorly monitored.

On Spain’s network the best-documented harm is to birds. Camera monitoring from on board trains estimated 60.5 bird collisions per kilometre per year on a stretch carrying 53 trains a day, and 26.1 on a stretch carrying 25. Later work found the surrounding bird community changing species by species, and uncapped catenary poles acting as pitfall traps for birds that nest in cavities. Anti-birdstrike screens are routinely fitted to viaducts, and how well they work is still being studied.

None of this says the corridor cannot be crossed by wildlife. It says that whether it can depends on design decisions and monitoring commitments not yet made, and that a flat undertaking given before them is not one a reader can test. Of the three promises, the one about natural water flows is the most straightforward to deliver.

What Can Be Asked Now

Six questions ALTO can answer today

The letter makes commitments specific enough to be checked. None of the following requires a finalised route.

The ratio

Against Transport Canada’s figure of more than 1,000 crossings, how many are assumed to get a structure, and how many will be closed?

Composition

Of the French and Spanish structures cited, how many exist to reconnect a severed local access, as opposed to carrying the line over a river, motorway or railway?

Ontario benchmark

What crossing rate is assumed for the Ontario segments, and how was it arrived at? A comparison with Highway 416 through similar country would be useful to communities along the route.

Criteria

What method decides whether a road is bridged or dead-ended, and what detour distance is treated as acceptable in the countryside?

Cost

What provision for grade separation sits inside the capital estimate, and why has it never been shown as a separate line?

Dimensions

What minimum height and width will agricultural crossings meet, and what spacing standard applies? Will structures be sized for machinery or only for livestock?

Maintenance

Who owns and maintains each crossing structure over its life, and who carries that cost — ALTO, Cadence, or the municipality?

Detours

Where an access will not be reinstated, how much further will people have to drive to reach the nearest crossing, and what work supports that figure?

Emergency access

Which paramedic services and municipal fire departments have been consulted about response routes, on what dates, and what did they find?

Severed farms

Is any land reorganisation or land reserve contemplated for farms cut in two, and under what legal authority would it operate?

The letter is right that decades of international experience exist and should be drawn on. The difficulty is that it draws on one half of that experience and leaves out the other. France built more than four thousand structures. France also rebuilt the farms. The second of those depended on machinery Ontario does not have, and no number of overpasses substitutes for it. Meanwhile the company’s own engineering executive has told this city’s council that the aim is to build as few overpasses as it can.

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Counting the Crossings (PDF)

Full analysis for municipal councils, farm organisations, MPs and residents along the corridor — with the per-kilometre working, the French statutory provisions and the complete source list

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How to read the numbers on this page

The French and Spanish structure counts are as given in the 14 August letter and used here as stated. The Transport Canada crossing count, the HS2 figures, the Kingston council statements, the French statutory provisions, the HS2 petition figures, the emergency-response research and the wildlife findings are all quoted from the sources listed below and can be checked there.

Everything else is our own calculation or estimate, and is marked as such where it appears: the per-kilometre and spacing rates, the 30 to 60 per cent closure proportion and the 300 to 600 closures that follow from it, the $3.2 to $8.4 billion grade-separation range, and the detour arithmetic. Where ALTO or Transport Canada has not published a figure, we say so rather than inferring one, and we make no claim about what anyone knew or intended.

Sources

Primary documents and statements

Maria Luisa Dominguez and Loïc Dorbec, “Building on decades of high-speed rail experience,” letter to the editor, Kingston Whig-Standard, 14 August 2026. Structure and length figures for France and Spain are as stated in that letter and are used here as given; the per-kilometre rates are the Initiative’s arithmetic.

Chambres d’agriculture France, on aménagement foncier agricole et forestier and its role in repairing disruption caused to rural land by the route of major linear works, high-speed railways included. chambres-agriculture.fr

Département d’Ille-et-Vilaine, on the LGV Bretagne–Pays de la Loire land reorganisation and land reserve programme: 48.5 km of new line, 480 ha absorbed, 720 ha of reserve constituted, 1,200 ha of parcels reorganised, more than 4,400 landowners affected, financed by the project owner. cg35.fr

WikiAgri, on the land reserves assembled through SAFER for the Le Mans–Rennes high-speed line: approximately 3,700 ha placed in reserve, with agricultural land pre-empted within three kilometres of the future alignment. Contains the quoted remarks of Cadence’s Project Director on the composition of that reserve. wikiagri.fr

Transport Canada, TRAN Committee Appearance Binder, Item 15: High Frequency Rail, 7 March 2023 — source of the figure of more than 1,000 public and private crossings on the alignment.

City of Kingston, Council meeting of 17 February 2026, closed-captioning transcript — remarks of ALTO’s Vice-President of Systems Engineering and Interface on crossing consolidation, overpass numbers and corridor fencing.

HS2 Phase 1 structure count: more than 500 bridging structures including over 50 major viaducts, per HS2 Ltd’s head of civils structures, reported in New Civil Engineer, 15 June 2022, and repeated on the Institution of Civil Engineers project page. Route length taken as approximately 225 km; some sources give 208 route km, which would raise the per-kilometre rate rather than lower it.

Wildlife. Rodríguez, Crema and Delibes (1996), on underpass and overpass use along Spanish high-speed line. Rytwinski and others, systematic review and meta-analysis of crossing-structure effectiveness, for the finding on movement decline. Barrientos and Borda-de-Água, “Railways as Barriers for Wildlife: Current Knowledge,” in Railway Ecology (Springer, 2017). García de la Morena and others (2017) for the on-board camera collision estimates; Malo and others (2017) on bird response and catenary-pole mortality; and work on high-speed rail and bird-community change published in PLOS One (2024).

Erin Durant, “Alto: Which farm roads stay open and who pays?” 16 August 2026 — source for the German Flurbereinigungsgesetz parallel, the seats-and-appeal structure of the French and German commissions, crossing dimensions for livestock versus machinery, the unresolved maintenance question, the OFA slow-moving-vehicle collision figure, and the last-modified metadata on ALTO’s agricultural pages.

10.

Joint statement of the Ontario Federation of Agriculture, l’Union des producteurs agricoles, National Farmers Union (Ontario), Christian Farmers Federation of Ontario and Union des cultivateurs franco-ontariens, 16 June 2026, following their 4 June meeting on ALTO’s proposed collaboration agreement.

11.

ALTO HSR Citizen Research Initiative, Road severances (technical analysis, March 2026 — source of the closure proportions and grade separation cost range) and Wildlife crossings.

12.

Ontario road spacing reflects the concession survey pattern across the corridor study area. Highway 416 is proposed here as a benchmark for comparison; no crossing-provision figure for that corridor has been established for this brief.

September 5, 2026