I have a number of concerns…

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019-9265

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114011

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I have a number of concerns with this proposal.
1. It does not clearly identify an actual problem that: a) isn’t already addressed through existing legislation b) that would require a *legislated* response vs. other approaches e.g. project management, collaboration, negotiation. If anything the proposal appears to be a misuse of law to avoid said other approaches.

2. municipalities are extremely important for understanding and serving local populations and constituencies. It appears that a key purpose of the proposal is to undermine municipal authority and autonomy of decision-making. The key question on this point has to be “why?”; surely the province doesn’t want to have the responsibility for fulfilling the role of municipalities themselves. However, using legislation to automatically over-ride municipal input/concerns etc. also means undermining the voices of all Ontario residents. So while the proposal promises to “Save You Time” it also promises to do so by “Making You Silent”.

3. The Environmental Protection Act and the associated processes of assessment exist to protect the public interest. I understand that there may be room for improvement in these processes, especially between Federal and Provincial governments. And the ‘other approaches’ listed in point 1. could be exercised to great effect. The proposal appears to suggest that ‘priority projects’ would be exempt from environmental assessment and protection, or subject only to minimal requirements. This is not acceptable.

It is not acceptable, under any circumstances, to sacrifice public interest and the long term sustainability of provincial farmland, food security, water tables and water quality, air quality and natural habitats, migration routes etc. for something that *may* only serve a small fraction of the population. And, this is assuming that there is a case for new highway development.

4. It is unclear why the “priority projects” have been selected at all, never mind made priority. There are many options for transportation. Highways are one. What about all the others?

If there was an argument for having new legislation, it might be to support a comprehensive, integrated, multi-use provincial transportation plan, developed in collaboration with municipalities and the Federal government.