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).
Five years ago, in March 2016, 110 groups submitted an application under the Great Lakes Water Quality Agreement (GLWQA) to designate radionuclides as Chemicals of Mutual Concern (CMCs) under Annex 3 of that Agreement. We submitted our nomination in reply to Environment and Climate Change Canada’s (ECCC) and the U.S. Environmental Protection Agency’s (EPA) call for nominations from the public.
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.
On behalf of the 23 undersigned organizations, we are writing concerning work on per- and polyfluoroalkyl substances (PFAS) under Annex 3 of the Great Lakes Water Quality Agreement. We urge the U.S. and Canadian Governments to work together in developing a joint binational strategy to address these chemicals in the Great Lakes region.
As you know, under Annex 3 of the Great Lakes Water Quality Agreement (GLWQA), the Canadian and U.S. Governments (the Parties) have designated two individual PFAS and their isomers (perfluorooctanoic acid, or PFOA, and perfluorooctane sulfonic acid, or PFOS) and one category (long-chain perfluoroalkyl carboxylic acids, or LC-PFCAs) as chemicals of mutual concern (CMCs).
The draft Strategy should include stricter fish consumption advisory that will protect the health of people in the Great Lakes basin to reflect stringent levels of PFOS concentration in fish adopted by the Great Lakes Consortium for Fish Consumption Advisories Best Practice for PFOS Guidelines.
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.
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
The proposed binational strategy on PBDEs outlines limited actions to address PBDEs levels in the Great Lakes beyond the measures that have already been committed on PBDEs by each country. It is also important that U.S. and Canada outline expected reduction targets for PBDEs in contrast to the current approach to outline intended measures. Without targets the ability to indicate successful and effective actions on PBDEs would be difficult to achieve.
The undersigned applaud the Ontario Ministry of Environment and Climate Change (MOECC) for its initiative in developing runoff volume control targets to reduce urban stormwater runoff and associated water pollution. We look forward to working with the Ministry on both the development and implementation of a Low Impact Development Stormwater Management Guidance Manual (which the above-noted Registry notice indicates will be drafted and consulted upon at a later date) and the further evolution of rainwater management policy and practice (both urban and rural) in Ontario. Our comments are directed only at the consultant reports attached to the Registry notice.
The undersigned members of the Alliance are commenting on the proposed Partnering in Phosphorus Control: Achieving Phosphorus Reductions in Lake Erie from Canadian Sources (“Draft Action Plan”) to reduce phosphorus loading in Lake Erie, in order to achieve the 40 per cent phosphorus reduction target. The Draft Action Plan, once finalized, will deliver on a number of nutrient commitments made by the federal and/or provincial governments including: