West Credit River. Photo by Steve Noakes
Three things change, and each one should be stated plainly. First, the requirement would no longer come from an Act of the Legislature. It would come from a policy document written by the ministry that applies it. Second, the other ministry would step out. MECP states that it “would not administer the Class EA-RSFD,” and that “Class EA reviews and annual reports would no longer be required, reducing burden on both ministries.”2 Those annual reports are the record of how MNR has applied the process, and there would be no equivalent under the PEP. Third, MNR could change the policy itself. The proposal states that administrative amendments “could be completed by the MNR,” and that amendments changing the purpose, scope or content of the PEP “may require consultation and posting on the Environmental Registry of Ontario prior to finalization.”1 The word is “may”, not “must”.