Hon. Rod Phillips Ministry…

Hon. Rod Phillips
Ministry of the Environment, Conservation and Parks
College Park 5th Flr, 777 Bay St,
Toronto, ON M7A 2J3

May 31, 2019

Re: Excess soil regulatory proposal and amendments to Record of Site Condition (Brownfields) Regulation, ERO submission

Dear Hon. Minister Rod Phillips:

Thank you for the opportunity to comment on brownfield regulations in Ontario.

Access to housing has become a critical issue in many parts of Ontario. With home prices soaring, people are being locked out of both home ownership and the rental market.
I see this first-hand in my riding of Guelph, where mandated population growth will make things even more challenging. Therefore, I understand how urgent it is for us to find housing solutions that work for everyone now.
However, many aspects of your government’s housing plans thus far, including Bill 108 and the revised Growth Plan, give me great concern. It is short-sighted to pave over farmland, run roughshod over wildlife, and destroy the places we love when this is not needed to increase housing supply.
Moreover, we already have enough land designated for development to meet our housing needs without encroaching on greenspace.

This is why I am happy to hear that your government is also exploring options to make brownfield redevelopment a more achievable reality for municipalities and developers in Ontario.
Brownfield redevelopment has been a longstanding part of the Green Party of Ontario’s housing plan and is a great place to start.

When speaking with city staff in Guelph, brownfield redevelopment constantly comes up as a necessary option for developing affordable housing supply, yet such projects can pose financial challenges for municipalities and developers.

This is why it is crucial that the province take the initiative to help cover remediation clean-up costs by reinstating the prematurely cancelled Brownfield Redevelopment Fund. Such a fund would help developers mitigate the risks and costs associated with brownfield redevelopment.

In developing these lands, it is also important that safety and sustainability not be sacrificed. We need to ensure that environmentally responsible, effective methods are used for remediation.

Phytoremediation is a cost-effective, plant-based approach to remediation that takes advantage of the ability of certain plants to degrade and render contaminants and other undesirable substances in the soil harmless. Where possible, this type of sustainable option should be utilised to repurpose land.

I do believe that brownfield remediation is essential to any responsible housing strategy, but I am concerned that your government is considering exemptions to important regulations in the Environmental Protection Act in your plans. This could pose a serious risk to public health, and thus, no such measures should be taken.

Environmental protections should be strengthened with respect to brownfield projects to ensure that we are developing safe residential communities with no remaining contaminants.

If done properly, remediating contaminated land comes with a variety of economic and social benefits. These lands are often located in areas that are already built up, which means that they are perfectly situated to take advantage of existing infrastructure, such as schools, libraries, and transit.

Brownfield redevelopment offers a substantial opportunity to create the housing we need and want. I appreciate the opportunity to comment on such an important topic. Please do not hesitate to reach out to me to discuss my submission in greater detail.

Thank you,

Mike Schreiner
Leader, Green Party of Ontario