-All land in Ontario is…

ERO number

019-0279

Comment ID

35304

Commenting on behalf of

Shared Value Solutions

Comment status

Comment approved More about comment statuses

Comment

-All land in Ontario is Indigenous territory. Simply posting the proposed changes on the ERO cannot be considered consultation with any Indigenous Nation, in accordance with Aboriginal rights reaffirmed by Section 35 of the Constitution Act, 1982. Ontario must engage in direct, meaningful engagement and accommodation with Indigenous Nations on this review prior to approving the changes.
-The policy change to Section 1.2.2 requiring “Planning authorities shall engage with Indigenous communities and coordinate on land use planning matters” is a welcomed change but will cause serious implications for implementation. It will inundate Indigenous Nations with consultation requests who may not be ready to engage. Simply forcing this relationship upon Indigenous Nations without adequate funding, training, staffing and capacity is setting them up for failure. Ontario must work with Indigenous Nations to develop a plan so they can adequately engage with municipalities on projects within their territory
-The PPS must recognize Indigenous Nations have interests beyond just archaeology and cultural heritage (Section 2.6.5). Similar policies should be added to ensure Indigenous Nations are engaged on other major planning themes including natural heritage, water, climate change, agriculture, minerals and petroleum, mineral aggregate resources and natural hazards.
-We disagree with the changes that prioritize industry/economic development over the environment. The proposed changes reflect a significant imbalance on the economy – environment continuum. We fear this approach and the proposed changes will achieve a streamlined process that benefits industry/economic priorities without recognizing the rights and interests of Indigenous Nations or impacts to the environment, public health and safety.
-There is an opportunity for Ontario, through the PPS, to learn from the experiences and approaches of Indigenous Nations land management.

Supporting documents