ORA strongly supports the following:
- The new section to the Act, 14.1, to restore the Greenbelt Plan to the 15 areas of land that were removed or redesignated in 2022, while maintaining the 2022 lands that were added.
- The re-enactment and enhancement of section 2 of the Oak Ridges Moraine Conservation Act, 2001, to repeal the authority of the Lieutenant Governor in Council to add/remove lands from the Greenbelt.
- Lastly, ORA supports the new section of the Act, 26, to restore the designation of land that was redesignated in 2022.
In response to the proposal to return lands to the Greenbelt, the ORA offers our strong support for all lands that were removed from the Greenbelt on 14 December 2022 being immediately returned to the Greenbelt, as per the proposed Amendments to the Greenbelt Plan and the Greenbelt Area Boundary Regulation O.Reg 59/05.
ORA also recommends that all lands this government added to the Greenbelt land to compensate for the December 2022 removal of Greenbelt lands remain within the Greenbelt under the protection of the Greenbelt Act, 2005, and Greenbelt Plan.
Once the land is returned to the Greenbelt, it must remain designated as Greenbelt with all the relevant land use restrictions, and any future removal must be made extremely onerous through protective amendments to the appropriate legislation.
Actually, this government does not deserve the trust of its constituents because it has eroded all of our environmental protections and public engagement and consultation in related policy and legislation over the last 5 years. Therefore, when it claims that “the intention is not to fundamentally change the underlying rules but rather to clarify their source and application”, it is unbelievable – no longer credible – trust has been lost. Especially since this proposal and the entire Build More Mines Act, 2023 was a total gutting of the Mining Act.
While streamlining mining legislation and policies can bring about certain benefits such as increased efficiency and reduced bureaucracy if done correctly; excessive streamlining without adequate safeguards can impact the environment, communities and even the long-term sustainability of the mining industry. It will also lead to environmental degradation, community displacement and conflicts, social and economic imbalances, and undermine public trust with the lack of transparency and accountability.
To avoid these negative consequences, it is essential to strike a balance between streamlining mining regulations for efficiency and ensuring that there are robust environmental, social and legal safeguards in place. Proper consultation with local communities, adherence to international best practices and strict enforcement of responsible mining standards are crucial for achieving sustainable and responsible mining practices. This is not the case with any of these amendments.
Consequently, ORA rejects this proposal to streamline the Regulation.
This government has been systematically removing public consultation opportunities for projects and issues of strong public interest, which goes against the spirit and intent of section 35 of the Environmental Bill of Rights (EBR).
Provincial parks and conservation areas must not be exempt from the Environmental Assessment Act as there will be no legal requirement to consider:
- Potential environmental effects;
- Mitigation measures;
- Alternative ways of carrying out the undertaking, and
- Alternatives to the undertaking.
There is also no decision-making mechanism which considers the environmental advantages/disadvantages of the undertaking.
The ORA will never be in favour of streamlining the regulatory, approvals and permitting processes as they were put in place to protect our natural environment and communities, and have already been significantly undermined.
Instead, we need strong and rigorous environmental assessment and robust public, Indigenous and stakeholder consultation if we are to build climate resilience into our air, land and freshwater resources.
I will briefly address my rationale and the dangers of streamlining the regulatory regime of hydroelectric facilities in particular, as it is commonly claimed by governments and industry to be ‘clean’, ‘green’ and ‘non-emitting. However, this is misleading the public at a pivotal time when we should be following the science.
For the reasons set out below, CELA and other aligned organizations and First Nations conclude that the various environmental assessment (EA) proposals set out in these Registry notices are highly problematic, unsupported by persuasive evidence, and contrary to the public interest purpose of the Environmental Assessment Act (EAA), namely the betterment of Ontarians by providing for the protection, conservation, and wise management of the environment.
Accordingly, we collectively recommend that these current proposals should be withdrawn and re-considered by the Ontario government.
Re: Bill 71
ERO-019-6715 – Proposed Building More Mines Act, 2023
ERO-019-6749 – Consequential administrative amendments under the Mining Act
ERO-019-6750 – Proposed regulatory amendments to closure plan and rehabilitation
A very disturbing reality has been revealed, that this government is clearly moving away from evidence-based decision-making that is grounded in science and, instead, is moving fully into a total lack of regard for environmental and stakeholder protections, and Indigenous treaty rights. This government is going too far in its efforts to cut red tape and deregulate environmental protections in Ontario.
ORA collaborated with Engineers Without Borders (UW Chapter) to host a youth engagement workshop for 35 grade 11 students in St. Aloysius Gonzaga Secondary School on March 31st. The group included students from the STEM Club and from the Environment Specialist High Skills Major (SHSM) Red Seal Program. ORA offered the students a Sector-Partnered Experience (SPE) focusing on real-world environmental issues to be solved. Continue reading
The province claims that “Ontario needs more housing, and we need it now. That’s why the Ontario government is taking bold and transformative action to get 1.5 million homes built over the next 10 years.” This Environmental Registry of Ontario (ERO) posting is only one component of a large series of other interconnected ERO postings relating to Bill 23. Due to the short comment period at this busiest time of year for such a complex, vague, poorly considered, and destructive policy and legislative “streamlining”, it is impossible to fully understand the full scope or depth of resulting effects to provide any kind of meaningful input. It is crucial that all ERO postings are well planned, concisely written and defined in clear policy language so the public fully understands what is being proposed and its potential positive and negative effects.
The Ontario government, through Bill 23 and its multitude of complex and interconnected legislation and policy amendments, has:
- Removed municipal jurisdiction from upper-tier municipalities to make policy decisions on land use planning matters that are based on local community interests.
- Removed a significant financial source (permits/building fees) in which to help pay for water and wastewater services, sewers, transportation infrastructure, and community parks needed to service 1.5 million additional homes.
- Prohibited Conservation Authorities all across Ontario from providing practical advice to municipalities, their ability to issue permits, or provide input into environmental concerns.
- Failed to provide adequate public and Indigenous consultation relating to Bill 23 matters.
- Is proposing to streamline the qualifications program for Building Practitioners (ERO-019-6433).
One prime example of ecosystem services is our fisheries which depend on strong and healthy ecosystems. In 2015 the Ontario Government launched a Provincial Fish Strategy – Fish for the Future, which indicated that Ontario’s recreational fisheries support robust sport fishing and tourism, which are a mainstay for many of the northern communities. It also reported that 1.5 million anglers spend $1.75 billion dollars in the province each year, supporting approximately 1,600 resource-based tourism businesses each and every year.[i] These are just a fraction of the ecosystem services that must be weighed against the full life cycle costs and benefits derived from any project that will impact our wetlands, wildlife, air, land or water.