Comments summary: The OFAH…

Comments summary:

The OFAH appreciates the need for regulatory modernization to reduce duplication and unnecessary processing time. However, much of the Project Evaluation Policy (PEP) goes beyond the scope of simple redundancies, with implications that may be detrimental to the ecological systems that Ontario’s parks and conservation reserves are intended to protect.

The PEP names very few circumstances where evaluations would be explicitly required, includes an extensive list of evaluation exemptions, and leaves the final decision on most items outside of this list up to the discretion of the minister. We are concerned that such an approach will produce results that are inconsistent with current scientific knowledge or conservation priorities.

The PEP exemptions list, which excuses certain activities from any evaluation requirements, is extensive and includes many activities previously deemed impactful enough to warrant evaluation. In fact, many of the projects/items the Ministry previously deemed “major” or otherwise warranting evaluation (in their original 2020 proposal) have now been recategorized as “minor” exemptions.

With a growing province, the OFAH appreciates that overzealous policy can sometimes hinder necessary change. However, the drive to improve, progress and, indeed, profit, must never take precedence over the health of Ontario’s natural resources, and nowhere is this more true than in our provincial parks and conservation reserves. Despite a stated prioritization of ecological integrity, the new Project Evaluation Policy would result in a marked reduction in environmental protection and accountability within these spaces, replacing more than 85 pages of thorough assessment criteria (the EAA), with a mere 15 pages. The natural systems in our parks and conservation reserves are irreplaceable and deserve a far more nuanced and conservative approach to management than is being proposed here.

As always, the OFAH is willing to work alongside the provincial government to find solutions that optimize both efficiency and conservation. We appreciate the opportunity to provide comment on this matter.