To the Environmental…

To the Environmental Registry of Ontario RE: ERO #019-4219 under the Environmental Assessment Act

ERO #019-4219 under the Environmental Assessment Act proposes that transportation, including highway and rail “of any length”, and electricity transmissions be moved to a “streamlined EA process”. It can be inferred that the Minister intends to include transportation into the existing streamlined classification for environmental assessments, Class Environmental Assessments (Class EAs). The Minister claims that these changes are important for “affordable housing”, and will remain “a comprehensive environmental assessment…while continuing to ensure environmental oversight and robust consultation”.

Is Urban Sprawl Necessary for Affordable Housing? What Evidence Has the Provincial Government Found For Taking this Strategy?

While Ontarians need affordable housing, it is a trojan horse to equate urban sprawl into sensitive habitats as necessary, or even supportive, to reach affordable housing goals. In fact, organizations such as Canada Mortgage and Housing Corporation, Toronto Region Board of Trade, and World Trade Centre Toronto all cite the importance of infill, building out the “missing middle”, and rezoning areas of extremely low density to permit multiple unit dwellings. Expansion actually harms both our social goals towards affordable housing and environmental protection.

Building new homes outside of city boundaries requires new infrastructure, which includes roads, services, transmission lines, and new transit to connect to these new urban areas. This sort of development also pulls away much needed construction labour that should be focused towards building affordable homes within existing urban boundaries that already have transit in place, thereby encouraging a lifestyle that is not dependent on cars.

Will the Changes Under ERO #019-4219 Leave Us a “Comprehensive Environmental Assessment”?

The Minister states that our environmental assessment process is “comprehensive” and “robust”, but this could not be farther from the truth. Instead, this proposed amendment further erodes a process that is already mostly smoke and mirrors, and a checklist rather than any meaningful consultation.

The changes under ERO #019-4219 would add transportation (highways and railway) into Class EAs. Class EAs are a fast-track for environmental assessments where projects are deemed somewhat routine and with minimal impact to the environment. However, there is much well-deserved criticism for class EAs used in real practice. In practice, class EAs are essentially pre-approved projects that are never rejected (Lindgren and Dunn, 284), and higher impact environmental projects have been inappropriately slipped under class EAs (Lindgren and Dunn, 296). Since 1993, 90% of all EAs have been obtained through class EAs.

Furthermore, ERO #019-4219 states that the only valid reason for asking for the Minister to escalate further action is it is made on the grounds of aboriginal treaty rights. So in effect, if this amendment is to pass, the public could have no real democratic process to determine how land is developed, and whether a valuable habitat in question warrants enough care to refuse the project altogether.

ERO #019-4219 Opens Up Fast Development Into Floodplains and Environmentally Sensitive Areas

Our green spaces matter on a very real level, and yet our current Premier has deregulated and disempowered conservation authorities tasked to protect our historic watersheds directly linked to plant and animal survival, as well as human health. He has asked conservation authorities to give up their land for development, most recently the existing sensitive ravine ecosystems located in the current Ontario Science Centre, which is also located in a floodplain. Should ERO #019-4219 be accepted, new roads could be fast-tracked into these spaces without any real ability to contest the decision.
One acceptable compromise might be to allow class EAs only within existing urban boundaries that are fixed .All expansion into natural habitats should bring about a full, in depth environmental assessment with non-partisan experts and public consultation.

A road is not just a road; a road connects hubs of human activity that are inherently damaging to plant and animal lives. And while one could argue that the road still leaves much space for wildlife to coexist, this does not take into consideration that wild species need continuous and un-fragmented spaces to breed and migrate effectively. When sensitive habitats are fragmented, this adversely affects biodiversity and inevitably our own species’ ability to thrive. The loss of biodiversity is occurring at an alarming rate, and directly affects our access and security to food, medicine, climate regulation, water purification, culture, and resilience to new zoonotic disease outbreaks, like covid-19. Biodiversity is crucial to our survival, and while it is not too late to bring back biodiversity, ERO #019-4219 supports activities that go in the opposite direction.

ERO #019-4219 Goes Against International Commitments to the United Nations

Finally, the federal government committed to meeting the Sustainable Development Goals (SDGs) by 2030 as put forth by United Nations, and these actions of our provincial government go directly against multiple goals:
- Goal 11: Sustainable cities and communities - make cities and human settlements inclusive, safe, resilient and sustainable. By 2030 ensure access to safe and affordable housing.
- Goal 13: Climate Action - integrate climate change measures into national policies, strategies and planning.
- Goal 15: Life on land - protect, restore and promote sustainable use of terrestrial ecosystems, sustainably manage forests…halt and reverse land degradation and halt biodiversity loss

In conclusion, ERO #019-4219 further erodes an environmental assessment process that is incredibly ineffective at both local and international levels. The movement towards Class EAs operates under the guise of securing affordable housing, while providing no evidence it will do as such. To meet SDGs by 2023, we should be strengthening environmental protection, and safeguarding our sensitive habitats from further human activity.

RESOURCES
JOURNAL ARTICLE
Lindgren, Richard D., and Burgandy Dunn. “Assessment in Ontario: Rhetoric vs. Reality.” he Journal of Environmental Law and Practice, 2010, https://cela.ca/wp-content/uploads/2019/08/766.LindgrenDunnFinal.pdf.
REPORT
Toronto Region Board of Trade, and World Trade Centre Toronto. Meeting in the Middle: A Plan to End Exclusionary Zoning and Tackle Ontario’s Housing Crisis. December 2021, https://bot.com/Resources/Resource-Library/Meeting-in-the-Middle.
ONLINE MAGAZINE
Carranco, S. (2023, May 1). Greenbelt Status Update. The Grind Magazine, 1(04), 8. https://www.dropbox.com/s/e0zo5kkya4hcdo9/THEGRIND_ISSUE4_FINAL_MAYJUNE…