It is extremely problematic…

It is extremely problematic that under BOTH the Greenbelt Plan and the Growth Plan existing, expanding or new infrastructure under the Environmental Assessment Act is permitted if it serves significant growth and economic development. Although under both locating infrastructure in the NHS, key natural heritage features, key hydrologic features and key hydrologic areas is discouraged, it is not prohibited. In this circumstance, I think it is not appropriate for the province to use the Environmental Assessment Act as the fall-back for these types of decisions. Given the changes to the Environmental Assessment Act with Bill C-38 that have been heavily criticized and put under revision, using it to permit expansion WITHIN the Greenbelt is not appropriate and completely undermines the amount of protection the Greenbelt is said to be providing. Under the Environmental Assessment Act, after its revision in 2012, the amount of protection it provides for water sources and fish habitat is little if any at all. If the Greenbelt is largely seeking to protect wetlands and hydrologic features and resources, this is not an appropriate measure to use. Under the newer set of regulations, there was a reduction or a complete elimination of consideration for fish habitat, a focus only on fish that belong to a fishery activity and temporary harm is no longer prohibited. Previously, EA had to consider the significance of environmental and cumulative effects, but after the implementation of C-38 the EA no longer needs to consider if a project is “needed” or if there is an alternative, that perpetuates less environmental harm. Therefore, under EA, The Growth Plan and the Greenbelt Plan, expanding or new infrastructure only needs to prove it serves significant growth and economic development, and will not have to answer to the potential for environmental damage to the important wetland amenities within the Greenbelt, as outline in the consultation document. This level of protection is not appropriate given what the Greenbelt claims to represent, complete protection of the areas it encompasses. The province needs to review its criteria for expanding or new infrastructure and base the approval of such projects on the Greenbelt plan ideals, not on the economic development stemming from it. This creates a need to analyse the “economic worth” of the ecosystems and services in questions. Although this could be a difficult task, it would be of grave important when looking at the cost-benefit analysis of developments in or near the Greenbelt. My main question is why there is so much consideration being made over the technicalities of the Greenbelt Plan and the Growth Plan if their fallback is Environmental Assessment, which seeks to protect very little?

[Original Comment ID: 212307]