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Accordingly, we collectively recommend that these current proposals should be withdrawn and re-considered by the Ontario government.
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).
We, the 78 undersigned organizations, are strongly opposed to the Ontario Government’s proposal to remove 7,400 acres of land from the Greenbelt. Opening these lands to development would destroy vital wildlife corridors, negatively impact woodlands, wetlands and watercourses, and result in the loss of over 5,000 acres of farmland. The government’s rationale – that these lands are needed for housing – is unfounded and untrue. We urge you not to proceed with this proposal for the reasons outlined below…
The Ontario government’s own 2020 report, “Protecting People and Property: Ontario’s Flooding Strategy,” which resulted from the 2019 flooding disaster, states very clearly that “Flood risk management is achieved through multiple provincial acts, regulations, policies and technical guides and a wide range of provincial programs and services. Successful implementation relies on partnerships between provincial ministries, municipalities, Indigenous communities, conservation authorities, stakeholder organizations and the federal government.” 1
Instead, this proposal seeks to do the very opposite. It proposes to exempt the CAs from their authority under ten crucial Acts and their associated regulations; it blocks the CA partnership with municipalities and stakeholders and takes the authority of CAs away from permitting so they cannot properly fulfill the recommendations of this report that was commissioned by the Ontario government only a few short years ago. Now, where is the wisdom in that?
The ORA is concerned that Bill 23 will have far-reaching negative effects on the environment and communities. This major streamlining of development is irresponsible and a recipe for disaster. Bill 23 works against sustainability and the watershed approach at a time when Government decision-making should be focused on protecting the environment and building climate resilience into Ontario’s communities and infrastructure.
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 Coalition for the West Credit River, of which the Belfountain Community Organization is a member, wish to inform Mayor Alan Alls and Council (the “Town”) that the questions asked in our 18 February 2021 correspondence were either not addressed at all or not satisfactorily addressed in the final Environmental Study Report (ESR) for the proposed Erin Wastewater Treatment Plant (Erin WWTP).
The Coalition reached out in good faith to the Mayor, in the hopes that he would answer our questions, and perhaps resolve some of our concerns and make it unnecessary to take this matter to the federal level for a review under the IAA. However, it has become crystal clear that the Mayor was not acting in good faith when we were informed by the Town’s lawyer, Quinto Annibale, in his 10 March 2021 email to me, that “all of the questions and issues which were raised and answered during the Part 2 Order request made to the Minister of the Environment Conservation and Parks pursuant to the Environmental Assessment Act. As you know the Minister considered each of these issues and refused to grant the Order. Since you participated in the Part 2 order request, my client sees very little useful purpose in answering the same questions again and therefore will not be responding to the detailed questions contained in your February 18, 2021 correspondence”.
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:
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.
Victoria, Albert and Chaudière Islands are sacred lands of the Anishinaabe people, and of high spiritual significance. ORA is requesting that this area remain a natural park space where First Nations and the public can gather now and into the future. Chaudière Falls is located on unceded Algonquin land, and the Algonquins of Ontario must provide informed consent before any plans are considered. Continue reading