I have addressed the AMPs…

I have addressed the AMPs and Pesticides Schedules of the bill under those headings. Those comments will be briefly summarized at the close of Schedules 16 and 14.

I was unable to locate comment boxes for the Aggregate Extraction (Schedule 16) and Workplace Hazardous materials (Schedule 14) sections. They will be addressed below. I will conclude with a general statement about the bill, the review process, and the content.

AGGREGATE EXTRACTION (Schedule 16)

a) It is unacceptable to remove municipal rights to restrict depth of excavation in order to protect t groundwater. Water supply and quality are central to maintaining safe residences, communities, farm stock and wildlife. As well, quality and amount of groundwater is critical to community expansion in the future.

b) It is unacceptable to remove municipal rights to restrict aggregate excavation expansion of boundaries into neighbouring road allowances. The municipalities have the right to determine how aggregate extraction can proceed in a manner commensurate with their environmental and community planning.

c) Under no circumstances should aggregate companies be allowed to self-file changes to site plans without Ministerial approval. We have long since learned that self-regulation in industry pits the public good against private profit, and simply does not work. Intermediary oversight is necessary.

d) I note that the Public consultation for changes to Aggregate legislation closed in early November, with apparently no impact on the resultant recommendations to Bill 132. I find that both cynical and certainly dismissive of valid concerns of the public and of municipal stakeholders.

e) I call on the government of Ontario to withdraw Schedule 16 from Bill 132. It is environmentally irresponsible, threatens public health and safety, and overrides Municipal rights to self-governance.

OCCUPATIONAL HEALTH AND SAFETY (Schedule 14)

a) It is unconscionable to remove government notice of hazardous materials in the workplace. Workers are often exposed to toxic and dangerous elements, and depend on the Provincial government to ensure that there is oversight of this exposure, to ensure their health and safety. CEPA has not addressed occupational exposure in its risk assessment.

b) I call on the Ontario government to absolutely remove Schedule 14 from Bill 132.

SUMMARIES SCHEDULE 9 WATER POLLUTION AMPS AND PESTICIDES

Water Pollution AMPs:

1) I call upon the government of Ontario to remove Schedule 9.

2) Reverse Onus is vital to retain, as it acts and both deterrent and an efficient mechanism for addressing contamination quickly and efficiently.

3) Per diem AMP rates should certainly continue as both deterrent and remedy. A per contravention AMP is absolutely unacceptable.

4) There can never be a "cap" on AMP rates. There is no cap on the damage resulting from contamination. It is dangerous to human health, dangerous to our environment both plant and wildlife, and an open ticket for serious and repeated contamination of our water, source and waterways

Pesticides:

1) I call on the Government of Ontario to remove Schedule 9 from Bill 132.

2) It is critically important to maintain an arm's length review committee for pesticide classification and monitoring. OPAC absolutely should be retained.

3) Harmonization of Ontario pesticide standards with PMRA is absolutely unacceptable. There are many questions about the federal pesticide review process. There is no independent review of pesticides, company data are used plus post-release evaluation. We cannot take those risks with our health and with our environment.

4) Under no circumstances should pesticide permissions reside with one person, "the government-appointed Director." That clearly enables ignorance, corruption, and absolutely unacceptable risk.

5) Agricultural pesticides must continually be re-evaluated and the product suppliers accountable to the government and the public. Neonics and glyphosate are classic examples of post release evaluation and ongoing environmental and health risks that must have strengthened accountability, not weakened.

BILL 132 OVERVIEW

1) The overall impression of the bill is one of dismissal of two sectors of society: the people who live in Ontario, and the environment: water, plants and wildlife.

2) The issues that can be impacted by the bill are environmentally huge. There is no way one month is long enough to consider the full ramifications of the elements of this omnibus bill.

3) Those with knowledge and experience in the areas being considered have not been consulted, nor have stakeholders been brought to the table. Cursory consultations do not count.

4) Schedules 9, 14 and 16 are particularly complex and/or unethical. They should be removed for further consideration and extensive consultation.

5) We all sit at an environmental crossroad in the future of our earth. This bill gives every impression of placing profit above all other considerations.We live in a time when, if we want a future for life on this planet, including our own families, we must use a very different filter when we plan. I look forward to greater knowledge, understanding, and reflection in Bill 132, Take Two.