The Ontario Rivers Alliance …

The Ontario Rivers Alliance (ORA) is a Not-for-Profit grassroots organization acting as a voice for several stewardships, organizations, individuals and Indigenous members who have come together to protect, conserve and restore healthy river ecosystems.

For the substantive reasons set out below, ORA is strongly opposed to Schedule 10 of Bill 66 in its entirety, as well as the associated Environmental Registry postings as listed above.

This ill-conceived Bill, and associated Environmental Registry postings, proposes to enable municipalities to attract large-scale economic development by passing “open-for-business planning by-laws” under the Planning Act. If enacted, these municipal by-laws would require the prior approval of the Minister of Municipal Affairs and Housing but would not be subject to public notice, comment or appeal provisions which are currently mandatory under the Planning Act. In addition, these by-laws would exempt application of key parts of several important provincial laws, plans and policies, including the:
• Clean Water Act, 2006
• Great Lakes Protection Act, 2015
• Greenbelt Act, 2005
• Lake Simcoe Protection Act, 2008
• Ontario Planning and Development Act, 1994
• Places to Grow Act, 2005, and
• Oak Ridges Moraine Conservation Act, 2003.

When tabling Bill 66, the Minister of Economic Development, Job Creation and Trade indicated that Bill 66 was aimed at eliminating “red tape” and “burdensome regulations” in order to promote business growth and create employment.

However, by any objective standard, the provincial laws, policies or plans excluded by Schedule 10 are neither “red tape” nor “burdensome regulations.” To the contrary, the legislative framework being ousted by Schedule 10 was carefully developed by the province with considerable input from Ontarians, non-government organizations and other stakeholders. In addition, the various components of this framework have been in place for years (and, in some cases, decades) in order to safeguard public and private interests throughout Ontario.

The proposed open-for-business by-law would prioritize economic goals and objectives to the exclusion of environmental, social and other goals and objectives. This is inconsistent with holistic and sustainable development. The proposed framework to formulate and approve an open-for-business by-law is inconsistent with an open, transparent and inclusive approach to community engagement and public consultation. Moreover, Schedule 10 permits such bylaws to evade or sidestep the substantive protections that currently exist in law to safeguard residents, communities, agricultural lands and natural heritage features and functions all across the province.

We must have both sustainable development and a healthy environment. We all want safe, healthy and resilient communities, so it is important that we protect our freshwater and groundwater resources, our farmland and the environment.

In closing, risky development decisions made in one or more jurisdictions could have significant negative cumulative impacts on our air, land and/or water, as well as the Great Lakes and many other highly valued ecosystems. Being “Open-for-Business” is a good thing, unless it is at the expense of public health and safety or the environment. Do we really want to risk another Walkerton or Grassy Narrows disaster? That is precisely what the province is fostering with Bill 66.

Accordingly, ORA submits that Schedule 10 is a regressive, unwarranted and potentially risky proposal that is inconsistent with the public interest and does not adequately safeguard the health and safety of Ontarians.

Accordingly, ORA respectfully requests that Schedule 10 be completely removed from Bill 66.

Thank you for this opportunity to comment!