I previously submitted a…

ERO number

025-0391

Comment ID

142814

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

I previously submitted a comment (Comment ID: 142192) in which i included my personal information. I am re-posting the comment here anonymously so that it might be published.

I have grave concerns about the proposed bill 5.  The very idea of fast tracking development without proper process is flawed, and the specific ways this bill details doing that are extremely worrisome.
I understand that this bill is being proposed so that the Ontario government might move forward more quickly on its work to see more industry here at home in Ontario, and also to allow for faster development, ostensibly of projects related to health, education, housing, and other social infrastructure.  However, what the bill proposes, in each of its sections, is to disregard existing laws and processes that are in place in order to protect environmental health, workers rights, workers safety, relations with Indigenous people, Indigenous constitutional rights, species at risk, and more. 

In fact, the proposed bill 5 proposes that once an area is identified as a "special economic zone", ANY municipal or provincial law could be ignored by offering an exemption.  This idea is reckless, and irresponsible, given the long history that has put existing laws in place.  The idea is also anti-democratic, as it would give to the Hon. Doug Ford and his Cabinet Ministers far more power than they were ever elected to hold.  It would allow them to charge through on development projects and in fact any project they chose, anywhere they designate as a "special economic zone", without consulting scientific experts, Indigenous people, environmental surveys, or the public.  

I will detail below my specific concerns, but they all stem from the same place.  Our environment and our people are foundational to a healthy economy.  We can not fastrack projects in the name of a healthy economy if we are walking over existing laws and processes that are in place to protect environmental and social wellbeing.  This bill is anti- democratic and blind to the actual problems of today.   Please read on for some of my specific concerns.

Schedule 9 in Bill 5 would allow the Hon. Premier Doug Ford and his Cabinet to designate "special economic zones", and then to hand out exemptions to municipal and provincial laws in those zones.  This means “trusted proponents” will be given the authority to undertake projects without regard to provincial municipal laws and bylaws.

With all due respect to our Hon. Premier, writing these powers into law would be a fundamental breach of democracy.  Premier Ford was elected to guide us through making new laws and enacting the old ones, but he was not elected to carry the power of decision as to when, what, and if existing laws need be applied to areas of our province.  Exempting "trusted proponents" from laws opens the door to environmental abuse: there would no longer be public participation in the process of the Environmental Bill of Rights.  Laws governing responsible land use could be contoured.  These exemptions could also contour the duty to consult with Indigenous peoples, which would be a breach of a constitutionally defined responsibility.  An area of special economic interest has even more reason to be managed with wisdom, including regard for the ecosystems and people that make up that place.

Schedule 3, proposes to terminate comprehensive environmental assessments for two projects: 1) the proposed Eagle’s Nest mine as part of the proposed Ring of Fire in Northern Ontario and 2) the proposed Dresden Dump.

Stopping environmental assessments on these projects is reckless and irresponsible.  It robs us all of proper scientific research and data, it robs Indigenous people of their right to participate in the assessment, it robs us all of the wisdom that could be contributed through that consultation, and it opens the door to permanent and irreversible environmental damage, in the name of speeding up economic growth.  

Schedule 7, proposes to to exempt developments from archeological assessments if the Ontario government is of the opinion that an exemption “could potentially advance one or more of the following provincial priorities”: ● Transit; ● Housing; ● Health and Long-Term Care; ● Other infrastructure; and ● Such Other Priorities as May Be Prescribed.  I wholeheartedly understand that the priorities listed are important and indeed essential to Ontarians, and that we need to look for ways to bring them into a thriving and functional state.  But exempting developments from archeological assessments means admitting that we don't care to learn from the past.  It means literally moving ahead without considering our actions.  Furthermore, the last bullet point "such other priorities as may be prescribed" is much too vague, and opens the door to abuse, or to the province pushing ahead with projects without proper consultation.

Schedule 10  proposes to repeal our Species at Risk Act.  I understand Bill 5 will replace this with another Act (the Conservation Act), but by all accounts this is a regression in our set of laws to protect the species of this province most at risk.  Scaling back our protection of these species, at a time when biodiversity is at risk, and the very fate of human health is at risk in so many ways, is reckless, disrespectful, and irresponsible.  

Once more, the proposed bill 5 would open the door to gouging out the last of our protected spaces, to ignoring whichever municipal and provincial laws the current provincial government chose, and to contourning existing rights held by Indigenous people.  I wholeheartedly oppose this bill, and hope that due process will recognize the importance of stopping this bill from passing.