Subject: Proposed revisions…

Subject: Proposed revisions by the Ontario Government to the Environmental Protection Act RSO 1990 – References Notice 019-6951, Water Taking: 019-6853 & Storm Water: 019-6928

ERSA – Environmental Activity and Sector Registry

The Ontario Public witnessed the tragic result of less frequent inspections in Long Term care facilities when faced with the Pandemic of Covid 19. ERSA introduces the possibility of reducing or eliminating current inspections by MNRF (Ministry of Natural Resources & Forestry) and MECP (Ministry of Environment, Conservation & Parks) and may result in increased funding for loss of potable water, erosion of wetland habitats, and permanent damage to the Public Domain. Many questions remain to be answered. How long has the 400,000 litre limit of groundwater removal been in place? What criteria was used to establish the limit? What has changed to warrant revision? What criteria was established to address complex areas of waterways, forests or wetlands? The flat grassland agricultural areas bordering the GTA (Greater Toronto Area) Greenbelt cannot be compared to all areas that include varying critical ecosystems in Ontario such as those found in Lanark Highlands.

Aggregate extraction is the barest describable form of ‘Mining’ and should therefore be immediately excluded from EASR. These revisions must not allow aggregate licensing permitting applicants (proponents) the ability to provide supporting documentation without independent oversight by MNRF, MECP, County, Municipal, and the Public. It would be like, in lay mans terms , “The Fox Guarding the Hen House”. Individuals and/or agencies at all levels of government tasked with assessing the merits of aggregate applications must be qualified, have an open and arms length from the applicant proponents and must possess the means to communicate openly on all pending decisions and projecting facts contained in complex technical data in lay mans terms for the public.

With the advent of social media, all new Regulations, Revisions, or Aggregate extraction applications will quickly become public knowledge. The opportunity to avoid public protests, embarrassing situations at the provincial level, or any level of government would be to provide resources to do the required consultations & assessments. With vast lands available in the province of Ontario, no new or revised licensing of aggregate development should put the public, wildlife sanctuaries, wetlands or forests at risk. Local governments at the county & municipal levels have had the assistance of Conservation Authorities to assess & review aggregate licensing impacts on water resources and complex environmental sensitive areas, waterways, forests and wetlands. Streamlining the process cannot include by-passing the tax paying public. Recent pull-back by the government is proof enough.

Our First Nations have fought long and painful years to have a ‘seat at the table’ and voice in responsible land use. Millions continue to be spent in efforts to cleanup contaminated water due to indiscriminate resource development. The students of Queen Elizabeth Elementary School have championed a project: Clean Water Matters. This based on their discovery the quality of drinking water on Indigenous Reserves. These elementary school children are concerned and taking action. Unfortunately their concerns lead them to the cleanup stage after the water has deteriorated to contaminated levels. What will our children think of our actions in their future?

Democracies hold election campaigns to allow candidates to express their values, consult the public, and to voice platforms if elected. All important issues of the day are highlighted, examined, discussed, and promises and platforms outlined. This allows the public to fully assess issues and assist individuals in ‘their vote’ in elections. It seems the Ontario public is losing opportunities to assess ‘emerging’ issues after election results. When elected officials introduce legislation to ‘muzzle the public’; democracy becomes a sham. ‘Streamlining the development process’ should not include reducing or omitting public consultation from legislative regulation revisions or introduction that directly or indirectly affect the public domain.