The proposed Project…

The proposed Project Evaluation Policy should not be approved. It is stated in the proposal details that this policy is the result of making “several changes” to the previously proposed Environmental Impact Assessment Policy. This is a gross understatement.

MECP needs to explain to the public why substantial changes were made to the previous version. Were they a result of comments received during the first consultation? A summary of the comments received, and how they were (or were not) considered, should be included in this new proposal.

The proposed Project Evaluation Policy is an incomplete policy and does not include enough detail for this consultation to be considered fair or valid. The public is not being given the chance to comment on the process(es) that will be followed to evaluate the potential environmental effects of projects, because the document contains almost no details or process.

Section 1 of the proposed policy states that the policy provides an evaluation process. The “Evaluation" section is 10 lines long. How can those 10 lines of text and an overly simple "template" be sufficient for Ontario Parks to evaluate the environmental impacts of projects? The document states that “accompanying procedures may be developed to provide detailed direction regarding evaluation and consultation, emergency provisions, mitigation and monitoring and administrative practices and procedures”. These need to be developed, and they need to be included as part of the policy before you consult with the public. If this policy is approved as-is, Ontario Parks' environmental assessment process (which won't even have the word environmental in it anymore) will be far less stringent than those of MNRF, MTO and MINES.

A key feature of the Provincial Parks and Conservation Reserves Act is that the planning and management of parks will include opportunities for consultation. Not only is a meaningful opportunity not being provided on this policy, but if this policy is approved, the public will have considerably fewer opportunities to provide input on projects in parks. Of the list of "minor projects", almost 30 of them currently require public consultation on both the Environmental Registry and as part of an environmental assessment; under the new policy they would have no environmental assessment or consultation requirements. Another 20 projects on the list won't have environmental assessment or consultation requirements if the project is identified in a management plan.

Why are so many projects exempt from environmental assessment requirements as long as they're mentioned in a management plan? Management plans are high-level. It doesn’t make sense that just because a project is mentioned in a management plan that there is no need to evaluate the potential environmental effects of that project once the specifics are known.

A significant change made since the policy was proposed in 2020 is that the following activities (with some limitations) now have much more lenient, or no evaluation and consultation requirements:

- Develop new campground
- Develop new day use area
- Develop new boat launch
- Develop new road, water crossing or parking area
- Develop new recreational trail or bridge for motorized use

What has happened since the policy was proposed in 2020 that would warrant such considerable changes? Why are these projects suddenly minor?

I hope you consider comments and withdraw this version of the policy.