I fully support the Canadian…

I fully support the Canadian Environmental Laws Association's (CELA) comments presented in the attached letter. As indicated in CELA's letter I too: "urge the Ministry to immediately withdraw and substantially revise the proposed project list to ensure that it fully implements the stated purpose of the EAA, namely, the betterment of the people of Ontario by providing for the protection, conservation and wise management of the environment."

I continue to be alarmed and dismayed by the Provinces continual attack on Ontario's environmental legislation. It is extremely concerning that once again the current government is giving discretionary decision making powers to elected officials. I am not confident that elected officials guided by 'Ministry Expertise' are able to adequately assess and rank projects that should be identified through regulation and therefore subject to a Comprehensive Environmental Assessment. I do not feel the government has made reasonable efforts to consult with subject matter experts to ensure the project list is inclusive and flexible enough to take into account that local impacts differ significantly across Ontario. There is insufficient consultation materials to justify the ranking of projects as having low, medium or high environmental impacts. This is an extremely broad approach that assumes all projects have equal impacts, this is not scientific, transparent or evaluation based; it is subjective and simply untrue. The extent of local environmental and human health impacts is not project specific, the location and the project must be known to understand the magnitude (or lack thereof) of potential impacts.

Removal of low and medium projects from the requirement to have a Comprehensive EA risks that projects will be approved that should have been screened out if an EA had occurred. It also risks that projects considered low or medium impact will proceed without a full assessment of alternatives and measures to reduce and mitigate environmental impacts. This is an unacceptable outcome and one that does not support any of the governments proposed actions to protect Ontario's environment and achieve actions to combat Climate Change.

Justification for such changes are under the guise of reducing duplication of process, red tape reduction or to create jobs and promote economic recovery from COVID-19. The government has not provided a single example of a process that is duplication or red tape. Nor have they provided any analysis of how the proposed changes will create 'quality jobs'. As per CELA's letter attached: "the Auditor General of Ontario has correctly pointed out that “while many other regulatory approvals for private-sector projects – such as mines, quarries, manufacturing plants and refineries – consider the natural environment, they do not include all key elements of an environmental assessment.” "

Natural Resources Canada's 2019 Canada's Changing Climate Report states: "In the future, anthropogenic climate change will continue to affect aspects of climate important for agriculture, forestry, engineering, urban planning, public health, and water management, and the preparation of guidance and standards." This would suggest that we should not be reducing the type and number of projects that require an EA but increasing the level of study and modelling required to understand how these projects will impact Ontario's environment and public health in the context of a changing climate; the environmental and public health impacts will be amplified.

The proposed changes to Ontario's Environmental Assessment Act narrows it's application when it is needed most. We are facing a Climate Crisis and Biodiversity Crisis. To limit the application of such an important piece of legislation is worse than inaction it is complete and utter negligence by elected officials to act in a manner that is proportionate to the impacts that will threaten Ontario's citizens and environment. It is willful disregard for the future health and safety of Ontario.