Comments on EBR item 019…

Comments on EBR item 019-2377
Proposed Project List for comprehensive environmental assessments under the
Environmental Assessment Act

The Concerned Citizens Committee of Tyendinaga and Environs (CCCTE) has serious concerns with the implementation of those aspects of Bill 197 which impact Environmental Assessments (EA). For example, there was no meaningful public consultation on the bill itself even though it proposes significant changes to EAs.

We provide the following comments on EBR 019-2377:

CCCTE agrees that the EA process should apply to any project with potential impact – not just those in the public sector.

The approach being proposed of listing project types to be subject to EA (and not listing of others) will not ensure that the correct undertakings are assessed effectively. To give a single example, a parking lot in an urban environment might have minimal environmental impact while the same project in a more environmentally sensitive location could be devastating.

Standardized and limited or “scoped” terms of reference will certainly prevent essential investigations needed to understand the full environmental impact of many projects. The “need” or “justification” for the project and consideration of legitimate alternatives must be evaluated to confirm that the overall benefits outweigh the environmental costs.

CCCTE agrees that aboriginal communities should have the right to request an elevation of projects to require comprehensive EA but believe this right should also be extended to the non-aboriginal citizens and communities in Ontario. Also, to eliminate any perception of political bias, it would be more appropriate to have such elevation requests reviewed and decided by the ERT.

Mining and quarry projects should be required to undergo an EA because they have proven over the decades to represent very significant environmental and human health risks.

Limiting the application of EA requirements to projects with a simplistic numeric measurement (e.g. length of a road or volume of a landfill) does not ensure that the highest risk activities are being studied. It is clear to the CCCTE that the location of a project is at least as important as its size.

Overall, Ontario must take a precautionary approach to these matters. Excluding any project from Environmental Assessment requirements should ONLY happen when it can be demonstrated that the impact of that project (regardless of its nature or size) would be minimal based on the precautionary principle and the application of the Statement of Environmental Values.

Ian Munro
Chair
Concerned Citizens Committee of Tyendinaga and Environs
5 Carscallen Drive
Napanee, Ontario
K7R 3H6

(613) 354-1828