On behalf of all members of…

On behalf of all members of our family who live in Ontario, I am responding to ERO #019-4219 “Moving to a project list approach under the Environmental Assessment Act.” This proposal recommends that a significant number of projects be moved to a “streamlined EA process” (Class Environmental Assessments or Class EAs) -- including transportation such as highway and rail “of any length” and electricity transmissions.
While the Minister of the Environment, Conservation and Parks claims that these changes will still “ensure environmental oversight and robust consultation”, there is nothing in the proposal to describe the safeguards for the environment under the new process. There is a section on “Environmental screening processes”, but nowhere could we find descriptions of what kinds of potential environment damage would trigger closer scrutiny. Should not the primary goal of any EA (streamlined or otherwise) be to ensure that every effort is made to PROTECT important and established ecosystems – especially those important in provincial and federal commitments to address climate change and limit greenhouse gas emissions? Efforts to replace or restore are fraught and almost always there is a significant time delay in restoration, even if it is feasible. “Replacing” an established forest or wetland or peat bog with a “new” one requires considerable time – not even counting the costs and inevitable delays.
Although we agree that Ontarians need affordable housing, urban or suburban growth (including related infrastructure projects) into sensitive habitats actually hurts BOTH important goals -- increasing affordable housing AND safeguarding Ontario’s sensitive ecosystems. A number of reports indicate that existing urban boundaries still contain much space that could be developed for affordable homes. This approach would have less of an impact, and which would be closer to existing transit. Roads fragment greenspaces, and harm biodiversity by isolating populations of flora and fauna from successfully migrating and breeding. Building new homes outside of city boundaries requires new vast investments to build new infrastructure, including roads, transmission lines, and new transit to connect to urban areas. The majority of these costs are born by the taxpayers of Ontario, not by the companies or individuals who benefit the most from them. The government states that moving towards a Class EA process will leave a “robust” framework for environmental protection. What is this robust framework and where is it described?
Class EAs likely will speed up the approval process for new projects, and we agree that some stream-lining is needed to reduce the approval times. However, without an overall plan that details the priorities for environmental protection, these changes risk “fast-tracking” projects that are deemed “routine” even though such projects may have major impacts on the environment. The size or type of development does not necessarily mean the amount of damage to a sensitive ecosystem will be minimal. Indeed, there is some well-deserved criticism for Class EAs. In real practice, the use Class EAs seems to mean that new projects are almost never rejected, and higher impact environmental projects have been inappropriately been approved under Class EAs. What is the evidence that Class EAs can be effective at providing adequate protection for the environment?
Also, under a Class EA if this amendment is to pass, how can the public or local governments have access to a genuine democratic process to determine how land is developed, and whether a valuable habitat in question warrants enough care to refuse the project altogether?
The federal government committed to meeting the Sustainable Development Goals (SDGs) by 2030 as put forth by United Nations, and again to the COP15 goals for Biodiversity. These actions of our provincial government go directly against multiple goals in these commitments (Goal 11: Sustainable cities and communities; Goal 13: Climate Action; Goal 15: Life on Land - protect, restore and promote sustainable use of terrestrial ecosystems, sustainably manage forests…halt and reverse land degradation and halt biodiversity loss).

In conclusion, ERO #019-4219 further erodes an environmental assessment process that already has at times been incredibly ineffective at protecting nature at both local and international levels. EA processes need to be strengthened and clarified, as well as streamlined. In addition, the movement towards Class EAs under the guise of securing affordable housing is doublespeak and provides no evidence it will do as such.
To meet climate and biodiversity goals in the decades ahead, we should be strengthening environmental protection and safeguarding all possible sensitive habitats from further human activity.