The ORA is opposed to this proposal that would gut the Environmental Assessment Act (EAA) and the Environmental Assessment (EA) program. Since the EAA was amended in 1996 there have been many official calls for an improved EAA and EA program, amongst those calls were the Environmental Commissioner for Ontario and the Auditor General of Ontario. Over this time, the EA program and EAA have become more and more streamlined, and this has led to increasing uncertainty for stakeholders and proponents.
We, the undersigned organizations, strongly oppose proposed changes to the Endangered Species Act, 2007 (ESA) put forward in Schedule 5 of Bill 108. The changes contained in Schedule 5 will strip Ontario’s most vulnerable plants and animals of crucial legal protection.
If enacted, the proposed changes will effectively gut the Act, result in the loss of biodiversity in the Province, eliminate most of the current protections for species at risk, and reduce the likelihood of their recovery. These draconian changes are clearly designed to restrict the number of species that are listed as at risk, to permit large-scale developers to harm species at risk and destroy their habitat, and to delay the implementation of any protection measures that remain under the Act.
The government’s claim that the proposed changes will improve outcomes for species at risk is grossly misleading.
We, the undersigned, are reaching out to all MPPs to urge you to uphold the spirit and intent of the ESA as well as its focus on demonstrable benefit to species, and to ensure that it is not weakened during the ongoing review.
We note, with deep concern, that environmental deregulation – making it easier for industry and development proponents to proceed with activities that harm species at risk and their habitats – appears to be the overall focus and intent of the options put forward for consideration. Reassuring statements that the review is intended to “improve protections,” “improve effectiveness” and provide “stringent protections” (p. 2) are misleading, in light of the actual proposed changes that MECP is inviting the public to consider. These include options that would undermine the very cornerstones of the law: science-based listing (including Indigenous Traditional Knowledge), mandatory habitat protection, and legislated timelines for planning and reporting.
It is difficult to place any trust in the promises of this Plan when this government’s recent actions are reflecting something very different. Key policy and legislation were recently proposed in Bills 57 and 66 that would remove the position of the Environmental Commissioner of Ontario, bypass the Clean Water Actand several other important Acts, repeal the Toxic Reduction Act,and streamline the Endangered Species Act to support its “Open for Business” mandate. How is the government doing its part to “help our urban and rural communities and landscapes become more sustainable and resilient” when at the same time key legislation is being repealed, streamlined or bypassed?
In closing, risky development decisions made in one or more jurisdictions could have significant negative cumulative impacts on our air, land and/or water, as well as the Great Lakes and many other highly valued ecosystems. Being “Open-for-Business” is a good thing, unless it is at the expense of public health and safety or the environment. Do we really want to risk another Walkerton or Grassy Narrows disaster? That is precisely what the province is fostering with Bill 66.
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
This disturbing proposal would allow the killing of 50 cormorants per day from March 15 until December 31 each year, which would potentially mean the killing of more than 14,000 birds per hunter, per killing season. Additionally, both members of a nesting pair are required for nesting success; therefore, the killing of either the male or female during the nesting season would result in their chicks starving to death. The government also proposes to amend the Fish and Wildlife Conservation Act to allow killed cormorants to be left to spoil, but suggests that if this proposal proceeds it may be accompanied by regulations to require retrieval and disposal of the carcasses. This entire proposal is unacceptable, irresponsible and unjustified, and presents an increased risk to cottagers and recreational boaters and fishermen.
It is important to first state that although the Cap and Trade program was not perfect, it brought significant revenue into the provincial coffers, and funded important innovation, efficiencies and low-carbon programs. The few cents added to our gas fill-up was hardly noticeable. That being said, this is a great opportunity for the Province to come up with an effective Greenhouse Gas reduction strategy that will not just reduce carbon and result in cleaner air, but at the same time create well-paying jobs.