Commentaire
While I support the minimization of duplication and the increase in alignment between different levels of government on environmental assessments, this should not be taken as an opportunity to in any way relax the scope of assessments on medium or high-risk projects. Building a monument on the lawn of Queen's Park is one thing, but adding more than a few kilometres to a highway (far less than 75 km) or building a subway line are projects that produce significant disruption of the environment, if only locally, and must be assessed.
I'm not conversant with the details of environmental assessments or the legal obligations of the government to conduct them, so I want to make my comments general in nature.
The Ford government's record on looking after its citizens is, unfortunately, not good, as the scrapping of minimum wage hikes and their recent (multiple) actions regarding long-term care facilities indicate. Given that their motto is 'Open for business,' I don't believe that I am being suspicious in believing that attempts to modify the regulations on environmental assessments are intended primarily to benefit businesses rather than protect the environment and, as such, are further examples of this government's prioritization of money over people.
I stand against any regulations that encourage the expansion of extractive industries and land 'development' without appropriate assessments. Regulations should act to minimize, rather than enable, environmental damage and the acceleration of climate change, all of which will need to be paid for down the road. In addition, they should hold corporations and their officers financially and, if necessary, criminally responsible for environmental damage. In particular, companies should not be able to abandon responsibility simply by disbanding. It's time to be more responsible, not less.
The first sentence of the 'Proposal details', "The Ontario government continues to generate economic activity through local infrastructure projects that will not only create good quality jobs but help improve our quality of life," strikes me as an example of certain politicians' habit of naming something the opposite of what it actually is. Quality of life is not measured solely by material things, but also by the environment in which we live. Having two cars, a pension and a RRSP isn't worth much if you die of cancer or lung disease due to pollution.
'Reducing red tape' should mean 'making the FORMS easier to fill out and submit' and/or streamlining the approval process, not 'abolishing safety & environmental considerations.' To be facetious, I hope nobody would seriously suggest removing the requirement for detailed engineering specs for a 40-storey office building in downtown Toronto just to 'reduce red tape.' I doubt MPs would seriously wish to consider removing their pensions in order to make government leaner and reduce the burden on taxpayers!
Environmental assessments shouldn't necessarily be based on 'who' is doing the work, but on the nature and scope of it as well as the potential for environmental harm. Part of this is recognizing that, just because the chance of something bad happening is small, it doesn't mean it shouldn't be guarded against. There are plenty of examples of 'unlikely' events occurring with significant negative human and environmental consequences.
Speaking generally,
* All significant resource extraction/purification-related projects should be assessed. This includes mines themselves and any major mine-related infrastructure (e.g. smelters, tailings ponds, waste treatment/disposal, etc.), especially open-pit mines, should be subject to comprehensive environmental assessment. This is due to their enormous size, the potential risks to the environment and to human health, the liabilities associated with the long-term management and storage of mining waste, and the inevitable environmental consequences.
* Energy-related projects (power plants, fracking, nuclear waste storage) should similarly be assessed.
* Any significant water-diversion project, mainly dams but also including ports and any project that potentially damages/destroys wetlands (which are well known to moderate flooding and to filter water)
* Any waste treatment/processing/storage facility for chemical or nuclear products, or for landfill, especially if within a few kilometres of a lake or river.
The Environmental Assessment Act should be automatically applied to all major public and private sector undertakings and the public should be able to have a say in all environmentally-significant projects, whether public or private.
Any project being undertaken on the traditional territory of an Indigenous nation should require free, prior, and informed consent from both the elected and traditional councils, as both are voices for the community. Parenthetically, I insist that the Government of Ontario should immediately and concretely address the concerns of the Indigenous groups protesting development in the lands of the Haldimand Tract by forbidding such development and cease their use of police violence against those protesting the pviolation of their treaty rights.
In the context of the 'Modernizing Ontario’s Environmental Assessment Program' document, I note that HOV lanes are mentioned in passing. I would like to go on record as opposing any licencing scheme or opportunity to purchase 'access' or 'permission' to use HOV lanes. Such lanes, where they exist, should be dedicated to buses and similar vehicles, not to rich people who want to drive expensive cars faster than everyone else.
Processes that ensure environmental safety and Indigenous rights are not red tape and should not be neglected. I want to live in a province that has robust, clear, predictable, participatory environmental assessment processes that take context and complexity into consideration!
Soumis le 10 novembre 2020 11:17 AM
Commentaire sur
Liste de projets proposée pour des évaluations environnementales exhaustives en vertu de la Loi sur les évaluations environnementales
Numéro du REO
019-2377
Identifiant (ID) du commentaire
49509
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