Submission to the Canada Transportation Act Review Panel November 2000.1. Introduction The Business Council of British Columbia is pleased to present this submission to the Canada Transportation Act Review Panel. By way of background, the Business Council is an industry association representing 165 large and mid-sized employers with a significant presence in British Columbia. Our members are drawn from all major sectors comprising the provincial economy, including forestry, tourism, transportation, telecommunications, engineering, mining, retail, construction, agri-food, oil and gas, pipelines, telecommunications, advanced technology, financial services, education, health care and the professions. Taken together, the Council’s member companies and affiliated industry associations account for one-quarter of all jobs in the province. This submission deals primarily with two of the matters identified as falling within the CTA Review Panel’s terms of reference: •the adequacy of the national transportation policy set out in Section 5 of the Canada Transportation Act (the Act); •the effectiveness of the existing legislative and regulatory framework in sustaining the high levels of transportation capital investment required to enhance productivity and promote competitiveness and innovation. As an initial introductory comment, the Business Council of British Columbia wishes to indicate that we are in general agreement with the positions taken by the Greater Vancouver Gateway Council, which has also submitted a brief to the Panel. Most of the organizations that belong to the GVGC are also members of the Business Council. More.Page 2 Submission to the Canada Transportation Act Review Panel importantly, the Business Council shares the GVGC’s vision of making the Vancouver region the “Gateway of choice for North America”. Achieving this vision depends on establishing a fair competitive framework with U.S. gateways. It also requires that British Columbia – and indeed all of Western Canada – have a modern, efficient and competitive transportation system. In such a system, transportation carriers will earn rates of return sufficient to allow them to re-invest in maintaining and enhancing infrastructure and operations; shippers will have competitive choices wherever this is practicable; intrusive, command-and-control government regulation will be kept to the minimum necessary to ensure a safe, efficient and up-to-date transportation network; and fiscal and regulatory policy frameworks will explicitly recognize commercial and competitive realities while seeking to facilitate necessary investments in transportation services and infrastructure. 2. Broader Context for the CTA Review The CTA review comes at a time of significant change in the economic and business environment facing Canadian carriers and shippers. Among the many trends relevant to transportation policy and planning in Canada, the following stand out: 1) Continuing growth in both intra-North American and trans-oceanic trade. 2) The increasing importance of international trade to the Canadian economy, particularly since the advent of NAFTA (see below). 3) The implementation, in the United States, of a major program to expand and modernize transportation infrastructure (including highways and ports), a development that will intensify the competitive pressures on Canadian ports, marine terminals and other components of the transportation system. 4) A rise in the proportion of goods being shipped by truck rather than rail. 5) The movement of larger volumes of high-valued goods by air..Submission to the Canada Transportation Act Review Panel Page 3 6) The adoption and refinement of new information and communication technologies that are affecting transportation services, supply chain management, and other business systems. 7) Declining real communications and transportation costs, a trend that has accelerated with de-regulation. 8) More mergers and acquisitions across a range of leading industrial sectors, including transportation. 9) Strong growth in tourism – by some measures, it now ranks as the world’s biggest industry. 10) Containerization of cargo coupled with greater use of intermodal transportation services. 11) Increasing concern by different levels of government about air pollution, greenhouse gas emissions, and the impact of road congestion in urban centers. From a transportation policy perspective, perhaps the most important of the above trends is the Canadian economy’s growing dependence on extra-provincial trade – that is, exports and imports among provinces within Canada and with other countries. In what follows the focus is on merchandise trade; however, it is worth noting that global trade in services is also increasing rapidly. Figures 1 and 2 depict merchandise trade flows within Canada and with other countries as a percentage of Canada’s gross domestic product (GDP). As the 1990s progressed, trade in goods accounted for a rising proportion of GDP. Trade with other countries – especially the United States – has expanded much faster than internal trade, but the.Page 4 Submission to the Canada Transportation Act Review Panel volume of interprovincial trade is still impressive: in 1999, interprovincial exports of goods were valued at $189 billion, equivalent to one-fifth of the country’s GDP.1 Figure 1 reveals that for Canada as a whole, interprovincial plus international exports of goods now amount to close to half of GDP, up from one-third in 1991. The increase is wholly attributable to international merchandise exports, which have soared from 22% to almost 38% of GDP over the period. Extra-provincial imports of goods similarly have risen strongly (Figure 2), reaching 45% of GDP in 1999, compared to less than a third at the beginning of the decade. Again, growing international imports explain this pattern, as interprovincial imports have remained more or less constant as a proportion of Canadian GDP. Figure 3 provides some additional detail specific to Western Canada. It shows that extra-provincial exports – that is, exports of goods from a province to other parts of Canada as well as to other countries – rose as a share of the collective GDP of the four western provinces by 1 Note that by definition, interprovincial imports of goods equal interprovincial exports both in dollar terms and as a percentage of GDP. Figure 1 The Growing Economic Importance of Trade: EXPORTS (international and interprovincial merchandise exports as a share of GDP) 0% 10% 20% 30% 40% 50% 1991 1992 1993 1994 1995 1996 1997 1998 1999 Interprovincial International International + Interprovincial Source: Statistics Canada, Provincial Economic Accounts, Annual Estimates, 1999, catalogue 13-213PIB, Table 2. Figure 2 The Growing Economic Importance of Trade: IMPORTS (international and interprovincial merchandise imports as a share of GDP) 0% 10% 20% 30% 40% 50% 1991 1992 1993 1994 1995 1996 1997 1998 1999 Interprovincial* International International + Interprovincial * Note that by definition, interprovincial imports equal interprovincial exports in Figure 1. Source: Statistics Canada, Provincial Economic Accounts, Annual Estimates, 1999, catalogue 13-213PIB, Table 2..Submission to the Canada Transportation Act Review Panel Page 5 approximately ten percentage points during the 1990s. Once again, this is mainly due to the expansion of international rather than internal Canadian trade. The increase in the ratio of extra-provincial exports to GDP for the western provinces has been somewhat smaller than that for Canada. This largely reflects the dramatic growth of automobile-related exports to the United States out of Ontario. The implication of the story told by these three Figures is straightforward: as the value of trade in goods has increased relative to GDP, the transportation system has become an ever-more important determinant of economic performance for all parts of Canada, including the western provinces. Extra-provincial merchandise exports represent 41.5% of GDP in Western Canada, and an even larger proportion in some other provinces. Virtually all of these goods are moved to market by rail, truck, ship, or air – or some combination thereof. It is a notable feature of modern economies that they are able to move goods between markets at a lower real cost, and have more means at their disposal to meet foreign demand more flexibly, than in previous decades. As trade in goods with external markets continues to drive a larger fraction of economic activity in all of the provinces, access to efficient, high quality transportation networks will become more vital to their competitive success. 3. National Transportation Policy In Canada, government policy has paid scant attention to transportation’s role as an enabler of economic activity, including cross-border and other forms of international trade. Instead, Canadian governments have tended to treat transportation above all as a reliable source of tax revenues. A different philosophy has emerged in the United States, Figure 3 The Growing Economic Importance of Trade: WESTERN CANADA EXPORTS (international and interprovincial merchandise imports as a share of the collective GDP of the four western provinces*) 0% 10% 20% 30% 40% 50% 1991 1992 1993 1994 1995 1996 1997 1998 1999 Interprovincial International International + Interprovincial * The reported figures are derived by adding merchandise exports from Manitoba, Saskatchewan, Alberta and British Columbia and then dividing this by the collective GDP of these four provinces. Source: Statistics Canada, Provincial Economic Accounts, Annual Estimates, 1999, catalogue 13-213PIB, Table 2..Page 6 Submission to the Canada Transportation Act Review Panel especially in the past decade. There, policy-makers have come to understand that an efficient, world-class transportation system generates substantial economic dividends for the country as a whole. That is why the US government has committed more than $200 billion of incremental funding to expand and improve transportation infrastructure – notably highways and ports – and why the tax burden on American transportation service providers has been kept well below the levels prevailing in Canada. At present, the Canada Transportation Act emphasizes the policy objective of fostering “a safe, economic, efficient and adequate” transportation system for shippers and travelers. We believe there is a need to include another policy objective, namely, ensuring that the transportation system enhances Canada’s ability to compete and succeed in North American and wider global markets. With international exports and imports together now equivalent to two-thirds of national GDP, and globalization continuing apace, incorporating such a provision in the Act is overdue. The Business Council therefore recommends that Section 5 be altered to state that a principal goal of federal transportation policy is to support the continued growth and strengthen the international competitiveness of the Canadian economy. More generally, we believe federal transportation policy should be re-framed to place a higher priority on promoting competitiveness and ensuring that transportation decisions are more closely integrated with international trade, industrial development and tourism policies. At the same time, the federal government should take the lead in working with other levels of government to broaden understanding of the pivotal role of the transportation system as a facilitator of economic activity and the well-being of Canadians. 4. Sustaining Adequate Levels of Capital Investment Without ongoing capital investment, the competitiveness and operational efficiency of rail lines, airports, marine terminals, ports, and the road system will deteriorate over time. Figure 4 summarizes the distribution of transportation-related investment as a percentage of the national total by province for 1998. In that year, just under 30% of transportation.Submission to the Canada Transportation Act Review Panel Page 7 investment took place in Western Canada.2 In recent years, overall transportation-related investment has reached $30 billion (current dollars) or more. Of this, some two-thirds involves the acquisition of equipment, including containers, locomotives, rail rolling stock, ships, aircraft, commercial trucks, and other vehicles. Approximately one-fifth is engineering construction activity such as roads, railway track, airport runways, bridges and tunnels. The remainder is classified as transport-related building construction – freight terminals and warehouses, railway shops, other equipment storage facilities, aircraft hangers, passenger terminals, and the like.3 Within the various categories of transport-related investment, arguably the need for additional capital spending is greatest in the areas of engineering and building construction. In most regions of Canada, including British Columbia, transportation investment, particularly by the public sector, has kept pace neither with an expanding economy, nor with the rapid growth of external trade. To address this situation, the Business Council advocates a number of new policy directions. First, the federal and provincial governments should encourage the development of new, innovative financing vehicles to spur investment in key components of the transportation system, including ports, airports and marine terminals. The tax-exempt bond financing presently used in the United States to build transportation infrastructure is a model that we believe could be successfully adopted in Canada. 2 See Transport Canada, Annual Report 1999, chapters 2 and 6. 3 Ibid., Appendix 2-2, p. 10. Figure 4 Transportation-Related Investment by Province, 1998 (percentage of the Canada-wide total) Ontario 46.6% Quebec 17.4% Alberta 12.8% BC 9.5% Manitoba 3.5% Sask 3 .1% NS 2.8% NB 1.6% Nfld 1.3% Other* 1.4% *PEI plus the Territories Source: Transport Canada, Annual Report 1999, p. 45..Page 8 Submission to the Canada Transportation Act Review Panel Second, we recommend that the federal government re-invest a specified portion of fuel taxes collected from the transportation sector in designated priority infrastructure improvements, including roads, border crossings and ports. The Greater Vancouver Gateway Council has identified a group of infrastructure projects that should have first call on any new federal funding made available to southwestern British Columbia.4 Third, the federal government should also take the lead in working with the provinces and local governments to identify and remove regulatory obstacles to transportation investment. At present, major transportation projects, both in BC and other provinces, typically encounter interminable delays due to protracted and complex regulatory review processes and jurisdictional overlaps between different levels of government. We are aware of examples of significant projects within the Greater Vancouver region that have not been pursued because of lengthy review processes and the high costs associated with the complex and confusing mix of legal and regulatory requirements imposed by different levels of government. A strong commitment by the federal government to shorten review times and expedite regulatory decisions around major transportation projects would help to break what has become a log-jam. Ideally, the Canada Transportation Act should be amended to give the Minister authority – or perhaps even to require the Minister – to take steps to expedite review processes in the case of capital investment projects deemed of particular importance to the transportation system. The Greater Vancouver Gateway Council has urged the establishment, in Vancouver, of an office of federal “project expediter” who would be charged with coordinating the fast-tracking of regulatory review for infrastructure projects important to the transportation system and competitiveness of the region. We believe this GVGC proposal deserves serious consideration. 4 Greater Vancouver Gateway Council, Vision for the Future (Summer 1999), pp. 14-15. The Greater Vancouver Gateway Council is engaged in ongoing discussions with all stakeholders in the gateway transportation system to further refine a major commercial transportation network based on this list. Decisions regarding project funding should not be made until consultation with area stakeholders..Submission to the Canada Transportation Act Review Panel Page 9 Apart from this, the Business Council recommends that the Minister of Transport commission a detailed review of impediments to new infrastructure projects in the Greater Vancouver area. The review should devote particular attention to the impact of present regulatory approval processes on project development, the extent and consequences of overlap and duplication between different government agencies and authorities, and whether local and provincial land use and transportation planning processes adequately consider issues related to the movement of goods. Although the federal government does not have jurisdiction over local land use planning or transportation decisions, it can and should seek to influence such decisions when larger public and economic interests are at stake – as is almost always the case with major transportation projects. Our experience is that local governments and agencies rarely consider the ramifications of their decisions for the transportation system as a whole, still less for the competitiveness of the export industries that are primary engines of wealth creation in British Columbia and the rest of Canada. A Balanced Approach to Taxation Tax policy is a factor that bears directly on investment in transportation and the competitiveness of the transportation system. At present in Canada, the fixed tax burden (i.e., profit-insensitive taxes) on transportation is too high. The biggest concerns relate to taxes on capital, property, fuel, and other business inputs. High fixed taxes are a particular problem for capital-intensive industries – a category that includes most components of the transportation sector. Municipal property taxes on Vancouver Gateway seaport operations are between two and ten times higher than in competing American gateways.5 A number of studies have shown that as a share of revenues, the business tax burden on both airports and railways is significantly higher in Canada than the United States. All of this results in a higher cost structure, which in turn encourages some Canadian shippers to use US transportation networks – at the cost of reduced economic activity and fewer jobs here in Canada. 5 Greater Vancouver Gateway Council, Vision for the Future (Summer 1999), p. 11..Page 10 Submission to the Canada Transportation Act Review Panel Without a competitive tax structure, transportation providers cannot afford the investments needed for Canada to succeed in world markets; nor can the transportation system itself properly perform the enabling role within the economy referred to earlier. In an era of sizable budget surpluses, the Business Council believes the federal government should be moving to equalize the tax burden on transportation with that in the United States. The main focus should be on reducing federal fuel and capital taxes, moving toward US-equivalent tax treatment of investment in capital equipment, and working to persuade other levels of government to lower property, capital, fuel and other input taxes within their own spheres of jurisdiction. 5. Other Issues From a British Columbia perspective, the shift from rail to road as a mode for the transport of goods raises a number of issues. Both nationally and in BC, trucking’s share of the freight transportation market has increased over time. On a tonnage basis, trucks account for about 40% of the Canadian surface transportation market, and for more than 60% of freight revenues.6 Land use pressures, ever-worsening traffic congestion, and concerns over local air quality as well as emissions of greenhouse gases all suggest that there would be benefits from increasing the proportion of freight shipped via rail. The growth of container shipping and ongoing efforts to integrate road/rail services are helping to further this goal. But more needs to be done. A lower fixed tax burden on railways, as recommended above, would help to facilitate greater use of this mode by lessening the relative tax-disadvantage under which railways in Canada currently operate. A specific transportation issue of great importance to British Columbia is the future of Vancouver International Airport (YVR). The growth of business at the airport has been a rare source of strength for a generally sluggish provincial economy in recent years. The number of passengers moved jumped from 10 million in 1992 to 16 million in 1999, while the number of carriers using the airport climbed from 26 to 50. Some $700 million 6 “The Economic Importance of Rail Transportation for Selected Industries in Canada,” Industry Canada web site (http://strategis.ic.gc.ca/SSG/ti00043e.html).Submission to the Canada Transportation Act Review Panel Page 11 in capital expenditures have been made to create a modern facility that recently was rated the best in North America by the International Air Transport Association. Looking ahead, the prospects for continued growth at YVR are favourable, but there are obstacles to overcome. One is the burden of high fixed taxes and fees mentioned earlier. This includes the impact of aviation fuel taxes on international flights – competing US west coast airports don’t have such taxes – and the $60 million the airport now pays the federal government in “ground rent” every year. Since devolution in 1992, Vancouver Airport has paid in excess of $400 million in rent to Ottawa, far in excess of the book value or historical cost of the facility. Although we recognize this is not an issue likely to be dealt with by the Review Panel, the Business Council of British Columbia urges the federal government to accede to the Vancouver International Airport Authority’s request to negotiate a new and more realistic rental arrangement. Another challenge is traffic congestion between the airport and the Port of Vancouver and other key lower mainland destinations. The Airport Authority is committed to expanding Vancouver’s air cargo business. In order to do so, however, it must be able to accommodate customer requirements for just-in-time delivery of high-value products. This requires improved inter-modal connectivity. There is also a need for better transit links between the airport and downtown. We are pleased that the federal government has decided to co-sponsor a study that will explore options for addressing this situation. 6. Conclusion The Business Council of British Columbia is grateful for the opportunity to make this submission to the Canada Transportation Act Review Panel. We would be pleased to discuss any of the matters raised in this submission with the Panel..130 rue Albert Street suite 616 Ot t awa (Ont ario)Canada K1P 5G4 613/236-0569 ! 613/236-6193 " info@acec.ca # www.acec.ca $ CANADA TRANSPORTATION ACT REVIEW PANEL BRIEF TO THE: Ottawa, March 2001 CANADA’S CONSULTING ENGINEERING INDUSTRY SUBMITTED BY:.ACEC Brief to the Canada Transportation Act Review Panel 1 The Association of Consulting Engineers of Canada makes this submission on behalf of its 600 member firms and their 48,000 employees working in communities across Canada and in markets around the world. Our industry’s business involves a vast array of engineering services related to the built and natural environment. Last year the consulting engineering industry generated $6.5 billion in revenues of which roughly 30% were earned internationally. We make this submission to the Canada Transportation Act (CTA) Review Panel based on our concern for the safety of passengers and vehicles and the economic consequences of travelling along Canada’s sub-standard National Highway System (NHS). As professional engineers obligated to protect the public’s health and safety we must add our voice to those of many other concerned Canadians who over the years have alerted the federal government to the state of our National Highway System. Having played a role in the planning, design and development of the NHS we feel that engineering firms are well placed to advise the government on its current state and the costs to society and to the Canadian economy of its degradation. The incidence of infrastructure failures and safety infractions increase when regular maintenance and repairs are not conducted and when the system is asked to perform beyond its original design requirements or life-cycle expectations. In the course of your work to date you have received submissions from among others the Canadian Automobile Association (CAA), the Coalition to Renew Canada’s Infrastructure (CRCI), the Canadian Trucking Alliance (CTA) and the Infrastructure Council of Manitoba (ICM). You might also be aware of the work of the Royal Commission on National Passenger Transportation (1992); the study of Transport Canada Policy Branch – Canada’s National Highway System: Description; the work of the Council of Ministers Responsible for Transportation and Highway Safety (1987 and 1997); and the efforts of the Transportation Association of Canada. You will be aware therefore of the state of play within Canada’s existing highway infrastructure and what many experts agree is required to fix the problems. All have underscored the need for dramatic improvements to the existing National Highway System through greater federal funding. Despite these studies and representations their collective impact on federal decision making is so far limited to the $600 million committed to the National Highway System in the February, 2000 Budget. This relatively small amount is to be spent over four years beginning in 2002-2003. This level of funding is clearly and sadly inadequate given the need to spend $17.2 billion to address the required rehabilitation and redevelopment of the existing infrastructure. We hope that the work of your review panel will not miss this opportunity to recommend substantive and structural changes to the way the National Highway System is managed, serviced and funded..ACEC Brief to the Canada Transportation Act Review Panel 2 Role of the Federal Government An important first step to this end is to recognize a formal role for the federal government with respect to the National Highway System in the Canada Transportation Act. It is remarkable that this critical transportation system, that carries 65% of Canada’s merchandise export trade to the United States, and 70% of all internal domestic shipments of manufactured goods is not considered important enough to be included in the federal government’s transportation legislation and regulations. National leadership, through the development of a National Highway Policy embodied within the authority of the Canada Transportation Act, needs to include common highway technical and safety standards across the country. The current patchwork quilt of standards is neither manageable nor responsible. It also needs to include a provision to establish a permanently funded program in order to serve the long-term needs of commerce and the travelling public. The greatest impediment to safer highways in Canada is the inability of government decision-makers to decide who is going to pay and by what means for the necessary capital, maintenance and operating costs. Toll roads are being used in some parts of the country but are not yet as publicly acceptable in Canada as they are in Europe. Public-private partnerships have begun to receive limited political favor in Canada but are clearly not the preferred option for most governments. Traditional funding mechanisms are slowed and weakened by federal-provincial negotiations and by conflicting funding priorities of all levels of government in Canada. The current highway funding mechanisms are not working and continued support for them will only further jeopardize the state of the national system. Economic Consequences of Inadequate Levels of Investment Canada has designated roughly 25,000 kilometers of its 900,000 kilometers of road as the National Highway System. Of this, only 7,300 kilometers are multi-lane divided highways. Much of Canada’s existing highway infrastructure was first built in the 1950’s and 1960’s for a population and an economy much smaller and much less demanding than today. No significant national highway redevelopment has taken place since the 1960’s in Canada. Today the NHS is carrying 72 billion Vehicle-kilometers per year. Studies have shown that 38% of the NHS is below minimum geometric design standard or below the 90 km/h minimum operating speed standard. Weight, speed, and road design standards vary across the country from one jurisdiction to another because there is no universal national highway standard. Over 20% of the NHS’s 3,500 bridges require major strengthening or rehabilitation. In spite of these recognized deficiencies in the quality and capacity of the NHS, the Federal government’s announced investment of $600 million over four years is the equivalent of $5 per capita per year. Compare this commitment to that of the United States. Their designated National Highway System comprises some 255,000 kilometers. The U.S. Federal Government is currently investing USD$171 billion in the nation’s highways over 6 years, or about USD$110 per capita per year (over 20 times the rate of investment by the Government of Canada ) ..ACEC Brief to the Canada Transportation Act Review Panel 3 For our highway transportation infrastructure to be competitive with the U.S., Canada will have to do better or risk losing commercial and tourist traffic to the safer more efficient southern routes. We ask the Review Panel to recommend that the federal government allocate a level of financial support to the maintenance, operation and improvement of the National Highway System including the Trans Canada Highway comparable to what is being invested in the United States. This would equate to CDN$3 billion per year. We recommend that these monies should come from the $4.7 billion gasoline excise tax currently collected by the federal government. This will bring Canada’s rate of capital investment in highways into the same range as that of other OECD members. You will have noted in their submission to this Review the Government of the Province of Nova Scotia states that between 1988 and 1996 the federal government contributed nothing of the $8.1 billion invested in highway capital expenditures by provincial and territorial governments. Today, the federal government is investing about 5% of the total amount of money invested annually in the National Highway System. Compare this to other OECD countries where national or federal governments are investing between 31% and 100% of total investments in their respective National Highway Systems. Studies predict that through a long-term program committed to eliminating the current $17.2 billion deficit there will be an annual operating cost savings of up to $4.4 billion to the traveling public. Better Roads means Better Safety While significant advances have been made over the past 30 years in improving highway safety in Canada, we still have 3,000 fatalities per year and 220,000 injuries on our roads. This progress has been largely made, through driver education, the enforcement of alcohol and seat belt legislation, and improved crash-resistant vehicles. Seat belt utilization in Canada now stands at 92%, suggesting that Canada is likely fast approaching the point where further safety improvements cannot be made solely through driver-behavioral modifications. Canada’s consulting engineering industry believes that it is time to consider the significant safety benefits to be achieved by building safer roads and highways, and by employing proven and emerging technologies - Intelligent Transportation Systems (ITS) - in our vehicles and on our roadways. Statistics compiled by OECD show that four lane divided highways have a far lower incidence rate for fatal accidents than do two lane highways. In the USA in 1997, for example, only 12% of the fatalities occurred on the four lane divided interstate and freeway system, which carried about 40% of the total vehicle-miles traveled. Other roads and highways had a fatality incident rate 4 times higher than the four lane divided highways. The 1997 Study by Canada’s Council of Ministers Responsible for Transportation and Highway Safety concluded that 247 lives could be saved and thousands of injuries avoided each year in Canada by carrying out the recommended $17.2 billion improvement program for the National Highway System. They also estimated benefits of up to $30 billion would accrue if the improvement program were implemented..ACEC Brief to the Canada Transportation Act Review Panel 4 Recommendations Canada’s National Highway System is in a serious state of disrepair due in part to a lack of adequate capital investment by the federal government. Deterioration of the country’s highway infrastructure in the face of rising use by Canada’s exporters and the traveling public will put Canada at an economic disadvantage with respect to international and inter-provincial trade, and is exposing the traveling public to unnecessary risk. By continuing to ignore the warnings of numerous citizen groups and the recommendations of the Council of Transportation Ministers, the federal government is not fulfilling the mandate of the Canada Transport Act to provide a…“safe, economic, efficient and adequate network of viable and effective transportation services”… that…“meets the highest practicable safety standards”. We therefore recommend: 1) That the National Highway System be covered under the Canada Transportation Act; 2) That the federal government show leadership towards the National Highway System by developing a national highway policy to include mandated national technical and safety standards (in effect in every other OECD country except Canada); 3) That $3 billion per year be committed by the federal government for highway maintenance, repair and development to bring the existing system up to modern day standards; 4) That the requisite funding come from the gasoline excise tax collected by the federal government ($4.7 billion collected annually by the federal government); and, 5) That the federal government recognize the National Highway System as critical to Canada’s economic competitiveness, national unity and quality of life. Respectfully submitted The Association of Consulting Engineers of Canada March, 2001.