Thank you again for your invitation to meet. We very much welcome the opportunity to discuss our concerns with you and your representatives. Prior to scheduling our meeting, it would be more productive if you could address the questions below in writing. Our expectation is that your answers to the questions below will provide a framework for our meeting. Details of our concerns are outlined in the updated “Briefing Notes”- attached.
The questions that follow do not represent all our questions and concerns; however, we would appreciate detailed answers to the following:
Immediate action on plastics is necessary. The government’s Science Assessment on Plastic Pollution, referenced in the Regulatory Impact Assessment Statement, confirmed that plastic pollution is widespread in Canada, causing a range of adverse effects on wildlife and ecosystems. Furthermore, there is strong public support for federal action. Recent polling found that 95 per cent of Canadians are concerned about plastic pollution and 86 per cent support a federal ban on single-use plastics. Every day Canada fails to act, another 7,900 tonnes of plastic waste end up in our landfills and environment.
A highly controversial environmental assessment study under the Ontario Environmental Assessment Act was completed 23 years ago. It concluded that the project would cause adverse effects to fish habitat including severe stormwater and groundwater impacts. The environmental assessment did not evaluate the impacts on species at risk, migratory birds or climate change. This study has not been updated.
The provincial regulatory process is grossly inadequate.
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.
Our concerns are well documented in the attached Briefing Notes report, which has been prepared by our Coalition in the process of requesting a federal review under the Impact Assessment Act.
The ORA favours conservation of Ontario’s natural resources, and most especially as it relates to fish and their habitat. ORA agrees that the Ministry should apply existing federal government guidance for fines and increase the use of contravention tickets for more types of offences. It makes sense to issue tickets rather than using the federal court process.
Overall, the material presented makes clear that the Fund mechanism will make it easier for habitat destruction to occur at the hands of industry and developers. Indeed, according to the proposal the main purpose of the Fund is to give operators a quicker and less cumbersome alternative to completing actions to provide an overall benefit for the species negatively impacted by their activities. The Fund is a part of a package of damaging amendments to the Endangered Species Act, 2007 (ESA), passed in June 2019 that, taken together, represent a gross weakening of the ability of the Act to fulfill its purpose to recover Ontario’s at-risk species. Our primary concerns with the Fund are outlined below.
The Trout Lake River has since time before memory been out travel route to and from Lac Seul and other places south. That river system is still a travel route. The river is full of wild rice fields, medicines, and other relations who thrive in the interdependence of this water system. The Trout Lake River meets with the Chukuni River and both then flow into the English River. Downstream of the English River are two communities, Grassy Narrows First Nation and Wabaseemoong First Nation. These two communities have already been devastated by the presence of methyl-mercury in the water and in their local food sources. I am sure that you are aware of their ongoing efforts to have the river cleaned up and for their people to be given proper medical care for having been poisoned by this polluted river.
You will find all the submissions made by ORA and our members here.
Bill 229 is just the most recent in a long list of omnibus bills containing devastating amendments, exemptions and streamlining of key environmental policy and legislation designed to protect our environment and communities and provide the public and stakeholders with meaningful input. These government actions have created a deep erosion of public trust and confidence. It is unacceptable that it would mislead its citizens and bypass the norms by taking advantage of a world-wide health emergency to aggressively push their destructive agenda through.
ORA submits that the MECP’s priority must be the pursuit of its Statement of Environmental Values (SEV), and its vision and mandate of “an Ontario with clean and safe air, land and water that contributes to healthy communities, ecological protection, and environmentally sustainable development for present and future generations”[i]. There is nothing in the MECP’s SEV that promises to “remove the regulatory burden” from industry or “provide some cost savings for dam owners and operators”. It is not the MECP’s duty to save dam owners and operators money or ease their regulatory burden. Its duty is to fulfill its Mandate to protect the environment and to follow its promise of environmentally sustainable development for our present and future generations. Certainly, MECP’s priority should not be to cut regulatory burden at the expense of our air, land and water. It is a tragedy that today’s cost savings for dam owners and operators will be borne on the backs of our children and grandchildren.