For projects that are site…

For projects that are site specific (such as landfills, electricity generation, etc) it may be reasonable to give a fairly generous threshold, since the impacts are localized to a given area and there is far less spatial variation to consider in an environmental assessment. The projects that are assessed by length, however, seem to have troublingly high thresholds:

1) "We are proposing to make certain waterfront projects in the Great Lakes-St. Lawrence River System subject to comprehensive EA requirements. These projects would involve establishing “works” (e.g. berm, marina, channel, island, beach, pier, wall or riprap), which meet both of the proposed criteria below: alter at least 1 km of shoreline, and require at least 4 ha of lakebed or riverbed to be filled"

These are generous thresholds and it doesn't make sense to tie them together since they are often relevant to different projects. It would take an exceptionally large marina to alter 1km of shoreline, and an exceptionally wide and deep wall or pier to alter that much lakebed. These should be considered individually of each other, where either one alone or a combination of both triggers a comprehensive EA.

2) "We are proposing to require a comprehensive EA for the following projects: establishing a new railway line (passenger or freight) of 50 km or more.

and

"to make new rail lines of 50 km or greater subject to comprehensive EA requirements as further summarized below."

50 km covers a widely variable area, it should be reduced to 25-30km. This is partly to account for increasing spatial variability but also to prevent projects that don't quite meet the threshold from slipping under the radar of a comprehensive EA (ie, a 49 km km rail line).

3) "We are proposing to require a comprehensive EA for: establishing new highways of 75 km or more in length meet specific criteria set out in regulation. Highway projects less than 75 km would be subject to the streamlined EA process set out in the Class EA for Provincial Transportation Facilities (MTO Class EA) which is proposed to be amended to apply to those projects. This represents a change from current requirements which requires the planning of all new freeways, namely 400 series, irrespective of length, to complete a comprehensive EA."

Highways are highly environmentally intensive, and cover long distances which encompass a huge amount of spatial/environmental variation. This means that a project expected to impact such a huge area will likely need to consider the subtleties and nuances of different regions and the specific environments it runs through. With the potential to impact such a large area, a comprehensive investigation is necessary. With respect to the federal government, they usually have higher thresholds anyway to cover projects that are too large for the scope of lower level assessments, so making the provincial rules "in line" with the federal government does not make sense. Furthermore, this makes even less sense when the proposal for new rail lines is 50 km, even though rail lines are less, not more environmentally intensive to build. Why make the project with the higher impact have a higher threshold to trigger a comprehensive EA?

The current requirements are correct to require any 400 series highways to have a comprehensive environmental assessment and should be kept.

The 75km threshold is suspiciously high, given that the current government is trying to push through two new highways below this length, which are expected to impact highly sensitive ecosystems, farmland, and water sources along the routes.