Lambton Public Health…

Lambton Public Health respectfully does not support the passing of Bill 66, Restoring Ontario's Competiveness Act, 2018, as it will have potential adverse effects to public and environmental health in Ontario. Please accept the following comments regarding our concerns with this Bill.

Schedule 5: Ministry of the Environment, Conservation and Parks

Although there may be some overlap between the provincial Ontario's Toxic Reduction Plan and the federal Chemical Management Plan in toxic reductions, it appears that the provincial legislation was more advanced in its mandate. Concerns with repelling of the Toxic Reduction Act and its Regulations include:
• There would no longer be new or reviewed plans for toxic substances reduction planners to provide necessary recommendations.
• There would be an exemption for certain facilities from all future planning and reporting obligations for certain substances.
• There would be less emphasis on reducing the use and the creation of prescribed toxic substances.
• Public transparency would be lost. The Toxic Reduction Act had a more in depth reporting mechanism.

Schedule 10: Ministry of Municipal Affairs and Housing

The "open-for-business planning bylaw" will:

• Allow different types of developments within previously protected areas, such as Source Water Protection Areas, which could threaten ground water and surface water resources.
• Allow developments, such as industry, in or near sensitive land use areas (such as residential developments), which could have a negative impact on air quality.
• Have a negative impact on the natural and built environment.
• Decrease the preservation of greenspaces.

The Ministry of Health and Long-Term Care published the Healthy Environments and Climate Change Guidelines under the Ontario Public Health Standards. This Guideline "is intended to assist boards of health to develop approaches for promoting healthy built and natural environments to enhance population health and mitigate environmental health risks". The proposed changes to Planning Act and the introduction of the "Open-for Business" by-law would hinder or make it more difficult for Public Health Units to collaborate with local municipalities in developing effective strategies to reduce exposure to health hazards and promote healthy built and natural environments when they are developing/reviewing their plans for infrastructure, zoning, land-use, etc.

Prior to amending the Planning Act, please consider what the health benefits of a well-designed community based on provincial policies which are:
• Better air quality;
• Protected drinking water supplies;
• Availability of locally grown foods (food security);
• Reduced urban heat island; etc.

Thank you for the opportunity to provide comment and your consideration of our feedback.
Please consider the impacts on the public health and safety of residents of Ontario prior to Bill 66 proceeding through the legislative process.

Lambton Public Health