Proposed regulations for how…

Proposed regulations for how the Environmental Assessment process will apply to four priority transit projects in the Greater Toronto and Hamilton Area | Environmental Registry of Ontario

The proposal to permit early works to proceed to construction before the completion of the draft Environmental Impact Assessment Report, (i.e., before lawful Ministerial approval of the undertaking), seems to invite, if not guarantee, financial liabilities for the Ontario government and provincial and City of Toronto taxpayers.

Recent government communications have suggested that there would be private for profit developments and operations at stations on the Ontario Line. The regulatory amendment proposal seems to imply that certain of these stations could be among the "early works" referred to; particularly, those intersecting major transit lines. Logistically, this may make good sense, but financially and fiscally it does not; unless government contracts with the private developers, operators, investors, creditors and insurers of the early works, protect taxpayers and the governments from lawsuits arising due to refusal or delay of Minister's final approval of the Environmental Assessment of the Ontario Line, or due to delayed completion of any other component designated as early work.

I object to the proposal, as presented, as a fiscally reckless act. Perhaps disclosure of contract terms with private interests, during public consultations immediately prior to approval of early works, could improve public confidence regarding potential liabilities.

EARLY WORKS:

https://ero.ontario.ca/notice/019-0614

Ontario Line are expected to be ready for construction earlier than other parts of the line.

To provide flexibility, the proposed regulation will have a process to permit early works to proceed to construction before the completion of the draft Environmental Impact Assessment Report, subject to:

requirements for consultation
identification of impacts and mitigation measures
issues resolution
Preliminary activities could include:

station modifications
bridge replacement and/or expansions
rail corridor expansion
utility relocations
Metrolinx will be able to prepare and complete an Early Works report for public comment at any point prior to completion of the draft Environmental Impact Assessment report.

The process for public and Indigenous community consultation, posting of studies and issues resolution is proposed to be the same as for the Environmental Impact Assessment report.