Re: Statement of…

Re: Statement of Environmental Values: Ministry of Energy, Northern Development and Mines
Draft: June 17, 2019

Comment

The SEV does not reflect the purposes of the EBR Act with respect to
"protection, conservation and restoration of the natural environment"
"provide sustainability of the environment"
"protect the right to healthful environment"

There is not a strong commitment to the environment reflected in the SEV.

The SEV do not reflect how (specific criteria and measures) for the purpose of the EBR will be applied when the environment might be significantly affected/impacted. For example - as per the purposes of the Act - the environment will always be given first priority in decisions making with respect to the EBR purposes, no known risk will be taken with the environment.

Further there is a "significant" amount of leeway and opportunity for the ENMS's interpretation and sole/unilateral decision making given the excessive use of words and phrases such as
"when required"
"when appropriate"
"features of provincial significance"
"significantly affect the environment"
Again none of these give confidence or state clearly that the environment will be priority in decision making as it appears the Act purposes state.

How significant is significant?
Who makes the decision that it is "required, appropriate or significant"
Many decisions, it would appear, could go undocumented, or have public consultation with this wording.

How will "social environmental planning" for mining be accomplished when Ontario does not have mandatory environmental impact assessments.

This SEV gives concern to us given the McBride project proposed in our cottage area. How would these SEV's be applied to this proposal? Our reading the purposes of the Act, would not allow this project (read Mining Watch report 2018). But our reading of the SEV's, as it is, does not given us this confidence.

Thought the SEV was to reflect the Act.

respectfully submitted