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.

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.

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.

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.

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.

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.

Why the structure count does not settle it

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.

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.

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.

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

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.

Six questions ALTO can answer today

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

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.

Primary documents and statements