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.
In ORA’s view, MNRF has been streamlined and restricted to the point where it becomes very challenging to effectively monitor and enforce any Bait Management Policy. It is also imperative that penalties are a sufficient deterrent and that funding is in place for sufficient staffing to effectively monitor and enforce the policy.
While abandoning the historically thoughtful context of a normal PPS review is ill-advised at any time, it is irresponsible to tilt the PPS toward an excessive empowerment of development-as-usual at a time of a changing climate, threats to biodiversity, regional ecological integrity, and the gathering momentum of the sixth mass extinction.