Review of the Development of…

Review of the Development of a Project Evaluation Policy under the Provincial Parks and Conservation Reserves Act

ERO 019-7356

3.4 Duty to Consult:
When reading through the changes made to this policy it becomes clear that your proposed changes diminish the responsibility and engagement of the Ministry in the duty to consult obligations.
Having participated in land-use planning consultations that have been delegated to third parties, I can speak firsthand to the detrimental outcomes that arise when third party consultants lack critical training in the social sciences, especially related to epistemic biases that view land primarily as a ‘resource’ and to be treated as property. There is an unacceptable level of risk that can enter these critically important consultations by externalizing the process.

The Office of the High Commission for Human Rights (OHCHR) further states that the lack cultural sensitivity and applicability to complex environmental problems specific to diverse local communities and Indigenous populations; with a recurring emphasis on GDP-focused growth, undermine Indigenous peoples’ holistic development approaches, ecological sustainability practices, and other such rights to self-determination as are asserted in the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP).

Ministry staff need to be trained accordingly to fulfil their obligations to consult on behalf of the Crown. These changes need to be rescinded and the Ministry needs to take responsibility for the power they exercise. Please revert to the Duty to Consult guidelines as outlined in the Environmental Impact Assessment Policy - ERO 019-1804 https://ero.ontario.ca/notice/019-1804

3.5 Coordination with Management Planning:
You have removed any concrete language that commits the Ministry to a requirement for determining whether new projects need additional management planning.
Your Project Evaluation Policy states: “When the Ministry is contemplating a project that is not consistent with the management plan, the Ministry can amend the management plan in order to implement the proposed project. The following can be considered before determining whether to amend a management plan”

Please revert this to the guidelines in the Environmental Impact Assessment Policy - ERO 019-1804 that contains firm and committal language, stating: “However, a project may be proposed that was not consulted on during management planning. When this happens, the Ministry must determine whether site-specific policy must be developed prior to implementing the proposed project. The following criteria are considered when determining whether a proposed project requires additional management planning”

4.1 Evaluation:
The revisions proposed here negate a rigorous and systematic process for evaluations. The removal of detailed project categories from ERO 019-1804 (“Considerations for Assigning Proposed Projects to Categories” and “Evaluation and Consultation Requirements for Projects by Category”), and their replacement by an empty table “template”, where projects will be evaluated “if” the Minister determines, is indefensible.

UN Decade on Ecosystem Restoration, the UN Sustainable Development Goals, and the Rio Conventions detail climate resiliency strategies that rely on urgent conservation of terrestrial aquatic ecosystems. Long-term ecosystem stability and its relation to social stability is assessed and monitored by the UN Framework for Ecosystem Restoration Monitoring; it is imperative that science-policy advisors be consulted, who are aware of these frameworks and their implementation in government planning. Fact-based decisions must be properly brought to bear, and so that scientific, social, and political perspectives support societal and ecological resilience in the face of climate change.

In Conclusion:
The UN Global Sustainable Development Report 2019—The Future is Now: Science for Achieving Sustainable Development—concluded that, despite initial efforts, we are not on track for achieving most of the SDG targets. This year marks the halfway mark to meet implementation of the SDGs as set forth in the 2030 Agenda, but a dire report from the Global Assessment Report On Disaster Risk Reduction (GAR) reads: “despite commitments to build resilience, tackle climate change and create sustainable development pathways, current societal, political and economic choices are doing the reverse”.

Following these examples, I cannot endorse ERO 019-7356 in any manner. The level of detail and policy guidance that has been removed is deplorable. I strongly assert that the Development of a Project Evaluation Policy under the Provincial Parks and Conservation Reserves Act ERO 019-7356 be revoked and that the Ministry of the Environment, Conservation and Parks approve and apply the previously proposed Environmental Impact Assessment Policy - ERO 019-1804.