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SPR Associates Inc. | , | www.spr.ca Research Press Release and 2021 Update - June 29, 2021: A Critique of MTO's Response to SPR's Truck Parking Study ______

Background: In May 2018, SPR Associates of Toronto submitted a report to The Ontario Ministry of Transportation (MTO) on long-haul truck parking and rest areas along Highways. The $280,000 study involved a major review of truck parking in Southern Ontario and was led by Dr. Ted Harvey of SPR, with a U.S. and Canadian advisory panel of engineers and transportation and safety specialists. This state-of-the-art project was the most thorough study of this issue ever conducted in , with new highway engineering simulations based on 45,000 truck trips, and on-line surveys of over 2,000 Canadian and US truck drivers. Several hundred trucking companies were also surveyed. The goal of the study was to assess the extent to which there is a shortage of truck parking and rest areas in Ontario and make recommendations to address this issue.

The study focused on truck parking mainly along the highway 401 corridor from Detroit-Windsor to the Quebec border. This corridor, which is used by some 40,000 trucks per day, is a vital part of the supply chain for the as well as the rest of Ontario. The surveys yielded detailed estimates of the need for parking on 25 Ontario highway segments and for 70+ existing truck stops. Drivers provided 60,000+ ratings of the difficulty of finding parking at all these locations. We also examined the history of implementation of Hours of Service (HOS) and Electronic Logging Device regulations which limit driving hours to ensure rest -- HOS drives the parking shortage and has been neglected by MTO for the past 15 years. On January 7, 2021, MTO issued a press release describing their proposed remedies to the parking shortage.

SPR's Findings: SPR's study confirmed that the longstanding truck parking shortage is a major issue for Ontario, resulting in extremely negative impacts on drivers and the trucking industry in general. The study demonstrated that driver fatigue from not being able to find a safe place to park to rest or sleep results in a higher risk of collisions and risks to public safety. More broadly, the shortage of parking has extraordinary economic costs. Key findings were:  There is a current shortage of between 1,200 and 2,600 truck parking spaces in Southern Ontario (with an estimated 3,900 parking spots currently available).  The most severe shortage of parking is in Central Ontario and the GTA, with a lesser but still noteworthy shortage of parking within other zones surrounding highway 401 and other highways.  MTO's efforts to create truck parking at ONroute centres in the three years preceding the study are regarded as ineffective by truck drivers and trucking companies. Improvements to ONroute parking areas were seen as mostly aesthetic, creating prettier parking, with no real increase in truck parking spots.  Nearly all drivers reported that they regularly had trouble finding parking. The study showed that resulting fatigue was a major risk factor for collisions and public safety. Drivers also reported negative impacts on their overall health due to a lack of parking and resulting fatigue.  The search for adequate parking costs drivers an estimated $15,000 per year for full-time drivers. (Estimated using the US Trucker Path cost model). Overall, SPR estimates these costs to trucking companies and independent drivers total hundreds of millions of dollars per year.

Significance to Ontario and the Trucking Industry: The parking shortage impacts the economy, infrastructure, the supply chain, food insecurity, and the health of the trucking industry. Drivers are most immediately impacted. When drivers cannot find legal parking, they must, resort to illegal catch-as-catch-can parking on the sides of highways, on municipal streets, or at "big box" store parking lots. This exposes drivers to long searches for parking, fines from the OPP or others, harassment, crime, and violence. See Trucks, Aug. 2, 2016, Truck Parking Shortage Exposes Drivers to Crime, Other Danger. The most egregious example of crime is a US one--a driver, Jason Rivenburg, who in 2009 sought to park beside the highway, was robbed of $7 and murdered. (Led to the widely noted US "Jason's Law").

Key SPR Recommendations: (1) the creation of 350+ new parking spots each year; (2) provincial leadership of stakeholders, including municipalities and others to address the truck parking issue, (3) public safety (driver fatigue = collisions), (4) land banking (Ontario holds thousands of acres which was expropriated in the 1970s for the never-built Pickering airport; over 18,000 acres of land are also held in Pickering by the Federal Government); (5) use of other available land for emergency parking; and (6) creation of an industry panel (including drivers) to advise MTO. A Critique of MTO's Response: It is easy to criticize, and harder to create solutions. However, after three years, MTO's response to SPR's report must be regarded as token or symbolic only, and insufficient, given the importance of this issue to the economy and public safety. This weak response might be attributed to the tendency of the MTO to focus more on its engineering and planning studies, as it has under Liberal governments (2003-2018) and the current Government. MTO staff merit praise for some temporary improvements under COVID. But this is not the more dramatic remedy needed to provide parking in central Ontario. Rather, SPR argues that:  New parking is needed now! Noting that no new truck parking has been created in the three years since SPR's report was submitted, there needs to be new parking created in Central Ontario. (To-date, MTO has presented a plan which focuses on creating parking mainly in which is also much needed, but also Southwestern and , which have more modest needs for added truck parking).  Most immediately, new emergency parking should be developed using available land, particularly in the GTA. (SPR's report recommended creating an inventory of potential sites.) Potential sites were not identified by SPR's 2018 report, but could include areas near the GTA, such as: certain parts of the CNE during the off-season, some land at Downsview airport, the Toronto harbour and out-of-date railway lands. (SPR notes: MTO has made some emergency parking available at commuter lots during the pandemic, but we understand this is ending now).  Longer-term (more costly) sites are the most essential need, calling for significant investment, due to the high cost of land in Central Ontario. Such solutions would show the issue as a priority for Ontario and could emerge from MTO-municipal partnerships (or actions led by an independent commissioner or a new provincial agency).  Innovative strategies are needed to mobilize partners and develop a range of solutions:  Involve municipalities as partners in the overall process. During the study, municipalities, particularly major municipalities in the GTA, expressed a great deal of interest in improving the availability of truck parking to aid the supply chain and goods distribution. They know where the vacant land is!  Utilize portions of the vast acreages currently held by Ontario in Pickering (and adjacent Federal lands).  Create a credible plan for improving parking at existing ONroute sites, ideally as part of an independent review of the 55-year contract with ONroute. (MTO advised SPR of this 55-year contract term in 2018.)  Systematically address the creation of an inventory of available land for parking.  Embed MTO plans within a Central Ontario strategy, as well as within a rural strategy.  Identify more positive roles for the OPP to play in HOS (e.g. assisting drivers to find parking, when needed).  Develop a trucking sector process (typical of modern government-industry collaborations) to improve company approaches to help ensure parking for drivers and to encourage related improvements in HR policies. (Today, some companies provide extensive supports for drivers, most of whom are independent operators, but most companies do very little -- most drivers are left on their own).  Create an industry advisory committee (including drivers) to aid in resolving the parking shortage.

Remedying a History of Inattention: Overall, MTO's response to the findings from the truck parking study is consistent with more than a decade of inaction in preparation for the HOS regulations which came into effect on June 12, 2021. MTO needs to recognize and fully support the essential services that truck drivers provide. The Need to Focus on Central Ontario: The 28 locations recently identified by MTO for the redevelopment of parking are mostly located in remote areas where land values are low, with existing tourist stops. These will help in the North, East and Southwest, but do not fix the urgent shortages in Central Ontario. Action is needed in Central Ontario.

A Need for Transparency: Since January 2021, MTO has repeatedly declined to share information on the process underlying MTO's current search for solutions to the truck parking crisis. This includes not providing details on consultations with stakeholders and a lack of detail on how much parking will be developed and where.

Need for More Serious Action! MTO's response to-date on the parking shortage is insufficient to solve the problem, ignores driver needs and the important issue of public safety as seen in risk of collisions. Drivers and other stakeholders in Ontario, across Canada, and the US who use Southern Ontario highways are urged to press the government for real action. Provincial action now will help reduce economic losses and avoid catastrophic collisions.

What Can You Do? Express your concerns to the Minister of MTO, Hon. Caroline Mulroney ([email protected]) and Ontario Premier Doug Ford ([email protected]). (Please also copy [email protected] )