The ORA is in full agreement that Low Impact Development (LID) must be a priority in development planning guidance for stormwater management practices and should include innovative green infrastructure such as rain harvesting, rain gardens, green roofs, urban trees and forests, permeable surfaces, ditches, swales, stormwater catchments, and must emphasize the protection of wetlands.
The ORA is very supportive of policy and legislation that provides an ecosystem approach for planning at a watershed and subwatershed scale. It is essential that we ensure a healthy environment, with clean and abundant freshwater resources, that helps to provide resilience to the extremes of climate change. We are appreciative of the information webinar on the Subwatershed Planning Guide, and the 45-day comment period.
Overall, we are generally supportive of the draft guidelines as they seem broad ranging and comprehensive. We are especially pleased to see the partnership approach with Indigenous peoples included in the Guide and agree that this approach will lead to a much more comprehensive subwatershed plan.
The ORA offers strong support for polluters being held accountable; however, that isn’t what’s happening here. Rather than strengthening enforcement tools that hold polluters accountable, this government is systematically and persistently dismantling, weakening or bypassing all environmental policy and legislation that was designed to protect the environment and deter those industries, corporations or individuals who would pollute and/or destroy the environment.
These ERO postings consistently mislead the public, especially in the top several paragraphs and titles, which contain misleading introductions to the proposed policy the government is proposing. In fact, you can always count on these “modernization” policy changes to be a further attack on environmental policy and legislation. It is even more despicable that these attacks have largely been carried out during the government’s declared COVID Emergency, where no public consultation is required, and what consultation that does take place is meaningless when the main objective is to cut red tape and remove any roadblocks to development and pollution, in spite of the public’s strong recommendations to protect the environment.
We, the 120 undersigned organizations, strongly oppose Schedule 3 of Bill 257, Supporting Broadband and Infrastructure Expansion Act, 2021, which proposes to amend the Planning Act so that both existing and future Minister’s Zoning Orders (MZOs) would no longer have to be consistent with the Provincial Policy Statement (PPS). We request that you remove this schedule from Bill 257.
The PPS sets the policy foundation for comprehensive, integrated, long-term land use planning in Ontario. It “provides for appropriate development while protecting resources of provincial interest, public health and safety, and the quality of the natural and built environment” (PPS Preamble). Regularly revised and updated though extensive public consultations with experts, stakeholders and Indigenous rights-holders, the PPS is meant to provide balanced, relevant and widely supported policy direction on planning matters. The Planning Act requirement (section 3) that all decisions affecting planning matters “shall be consistent with” the PPS ensures certainty, fairness, consistency and substantive merit in planning decisions across the province. A development that can only be authorized by exempting it from the PPS is a development that ought not to be authorized at all.
We, the 70 undersigned organizations, are deeply concerned about both the “sharp increase” in the use of Minister’s Zoning Orders (MZOs) over the past year and the enhanced powers granted to the Minister of Municipal Affairs and Housing through amendments to the Planning Act, without public consultation, through Schedule 17 of Bill 197.
The Government of Ontario is proposing Bill 66, Restoring Ontario’s Competitiveness Act, 2018. It is unacceptable that key environmental protection and legislation that protects the public is under attack.
Schedule 5 of Bill 66 would repeal the Toxics Reduction Act and two regulations. The purpose of the TRA is to prevent pollution and protect human health and the environment by reducing the use and creation of toxic substances and informing Ontarians about toxic substances.
Schedule 10 of this Bill would enable municipalities to simply pass an “open-for-business planning by-law” under the Planning Act, to exempt local development from the application of key components of several important provincial laws, plans and policies, including the:
• Clean Water Act, 2006, Section 39
• Great Lakes Protection Act, 2015, Section 20
• Greenbelt Act, 2005, Section 7
• Lake Simcoe Protection Act, 2008, Section 6, and
• Oak Ridges Moraine Conservation Act, 2003, Section 7