Purpose states that this…

Purpose states that this policy will “assist with:” considering PPCRA objectives, minimizing negative effects and maintaining ecological integrity. Various references are made to environmental protections under the PPCRA. The PPCRA is a high level document; what specific guidelines, procedures, policies and best practices will be used to provide guidance in evaluating proposed projects? Can you please provide a bibliography of documents and guidelines that will provide this guidance?

What is the status of the Class EA-PPCR upon the approval of this policy? No mention is made about how this new policy will rescind or replace the Class EA, or if to will still apply “to allow Ontario to focus on projects with higher potential environmental impact”… Will the PPCR-EA still be a tool used to focus on these projects? This new proposed policy is unclear in this regard.

This proposal is extremely opaque in describing adjustments to existing policy or newer proposals, such as the 2020 proposal notice 019-1804. The preamble in the Registry states “we have made several changes to the policy since we last consulted…” as well as a “name change”. The original Class EA—PPCR was 120 pages, including various detailed appendices and tables to offer additional insight for guidance. The 2020 proposal reduced such guidance to 35 pages. This latest proposal further reduces any “guidance” to 15 pages! How can this be described as “several changes”? Please provide more information to support this incredulous statement.

The ERO preamble states that the proposed policy will “provide a process for issue resolution” and also states “ Consultation is a key component of the policy development process”. Yet, in the proposed policy, there is no description of issue resolution, and consultation is at an absolute minimum. Section 4.2 states “if a consultation is required, staff will develop a mailing list…”. Please explain how “consultation is key”, yet section 4.2 is only one sentence long? Similarly, section 4.4 Request for Reconsideration is extremely narrow and limited in scope. End statement is that “the minister’s decision shall be final”. This does not describe any process for issue resolution. Can you please explain why the preamble speaks to issue resolution? There is much factual disagreement between the introductory preamble and the actual proposal. Can you please provide assurances that all documents in future will be properly and professionally checked to ensure accuracy? This work is well below any professional level expected from the Ontario government.

The “project Evaluation Policy” speaks of evaluation many times, and discusses the use of a “template” many times. Where is the “template”? Is the single line of sub-headings at the top of page 7 supposed to be a “template”? Is this the level of professional guidance we are going to rely on to ensure all considerations of the PPCRA are met? And this is supposed to be used to determine whether a project is of “potential higher impact”? Are we to understand that the minor projects in Appendix 1 may not even receive this basic level of scrutiny from this suboptimal “template”?

Appendix 1 lists a number of projects which may be considered minor or routine business in managing parks (if all applicable policies, procedures, guidelines and best practices are followed, but these are not even mentioned). Also included in this list are a number of significant campground and day use projects which may have high potential for impact to natural, cultural or recreational resources, yet these have been simply inserted as bullet points with no further description or guidance. Will there be any requirement for ecological studies, site plans or other detailed documents before these projects can commence? As they are lumped under “minor projects” are they to be authorized solely at the discretion of the Minister? Where is the option for further consultation or guidance from other sources? Please explain or describe the process; certainly neither the PPCRA , nor most management plans, can offer enough site-specific guidance to ensure these projects can be undertaken in an environmentally sound manner that will protect and maintain ecological integrity,

How will this new policy tie in with the current park management planning process? How will plan amendments be undertaken to enable these new “considerations”, especially if they are “new tourism development” or “major expansion of an existing facility”?

In summary, the new proposal strongly suggests that the Ontario government wishes to make the evaluation of new projects as opaque as possible, with little opportunity for public input, and no opportunity whatsoever for discussing issues and alternatives, nor any mechanism for issue resolution. Similarly there is absolutely no meaningful guidance provided to parks staff to describe or evaluate projects. The lack of a template to adequately collect and describe information is most concerning.

I look forward to discussing with your staff the questions and concerns I’ve raised, as it appears this will be the only opportunity to provide comment on a cornerstone of our PPCRA and park system. Thank you.