As a preamble to my comments…

As a preamble to my comments on the current posting, I would like to make the following three observations:

1. I try to review various postings to the Environmental Registry of Ontario, but I must say the blizzard of changes, amendments and repeals to various pieces of legislation, and the speed with which departments are merged, sometimes eliminated, is making it impossible to keep up with all the changes, which have occurred over the past year.

2. I have to ask myself how all past legislation, often based upon cumulative reviews by expert panels, consultants and government staff over a number of years, could be changed so radically within one year of a new government taking office. There is a ‘shotgun’ aspect to all these changes that concerns me greatly as a citizen of Ontario.

3. I can’t help but wonder who exactly is behind all these very rapid changes. Where are the precise measurements and background data upon which all these sudden changes are based? Who are the teams of qualified experts, and how were they chosen to conduct such onerous reviews in such a short period?

Now, regarding the current “Updating the Ministry of Energy, Northern Development and Mines’ Statement of Environmental Values”, I want to focus on one contradictory statement. If this update is aimed at a set of cohesive environmental values to govern mines and energy in terms of sustainability, then why is “an understanding of the ecological, physical, social, cultural, and economic impacts of development” only being done “on a project-by-project basis”?

Such projects should not be assessed, using a piecemeal approach. What about contiguous or nearby developments that may have already imposed specific stresses on the area? Projects need to be reviewed within the overall landscape using natural boundaries associated with watershed planning.
This posting also states “the environmentally sustainable development of Ontario’s mineral resources” requires “sound environmental planning that recognizes mining as a temporary land use, replaced in the long-term with alternative natural, recreational or commercial land use.” I would add the ‘temporary land use of FINITE resources” to emphasize that once the minerals are removed, they will not ‘re-grow’, so the mine ‘shrinks and dies’ as each unit of mineral deposit is removed.

As I understand the phrase “sustainable development”, the planned activity should only proceed if it does not compromise the resource or the environment for use by future generations. As such, I don’t really see how this ‘temporary land use’ can be “replaced in the long term with recreational or commercial land use” as an alternative. Who knows what future generations might like to do with this land? I would suggest trying to maintain the area in its natural state by limiting current demands with an eye to providing natural resources for future generations.

I don’t know if Ontario has bothered to look around the world to see what other modern developed nations are doing as far as ‘sustainable development’ goes, so I will provide a summary for the definition, as practised in the United Kingdom and the European Union.

The UK government uses fifteen “Quality of Life” headline indicators (out of a set of 150 core indicators of sustainable development), and these have been reported annually since 2008. If an indicator is declining, action is required.

These indicators were identified and defined because each is “potentially sensitive to a number of different drivers and pressures in the environment (ones we perceive now and potentially unforeseen emerging issues). The overall purpose was for each indicator to act as a barometer of environmental change in Europe and as a surrogate of changes in nature.” First started in the U.K., this system of Quality of Life indicators was adopted across Europe.

A wealth of data regarding the U.K.’s Quality of Life Indicators, relevant to Sustainable Development, is collected each year. The data for 2018 was posted in May 2019, and it can be viewed at https://jncc.gov.uk/our-work/ukbi-overview-of-trends/ A user can click on any of the state indicators, or sub-groups.

I don’t know if the UK and EU governments are ‘living up’ to these Quality of Life Indicators, but they certainly do collect all the right information. As Canada’s most populous province, Ontario could collect similar data to inform its “environmental values’ as they pertain to ‘sustainable development’. Since Ontario is writing a set of Environmental Values, what are its specific measures for ensuring these values are attained?

Setting values associated with planning for future sustainable development is very important, but we have to remember how easily plans can go awry if proper measurements and expert observations are not recorded carefully and collected regularly.

Consider a sage observation once made by former U.S. President Dwight D. Eisenhower on the value of planning: “I heard long ago in the Army that plans are worthless, but planning is everything. There is a very great distinction because, when you are planning for an emergency you must start with this one thing: the very definition of ‘emergency’ is that it is unexpected, therefore it is not going to happen the way you are planning.”

Does Ontario really know what it is planning for … aside from more revenues from resource development?

Has Ontario included a ‘comfort factor’ to allow for the ‘unforeseeable’ and ‘emergencies’, such as the effects of climate change, or potential irreparable harm that may be done to waterways, aquifers, and native species of plants and animals by over-zealous mining or energy development? Who will monitor the activity because if it is a matter of ‘voluntary compliance with environmental values’ by industry, then it may not work as planned.

Is Ontario really leaving an undiminished liveable landscape for future generations?