The rules and regulations…

The rules and regulations that protect Ontarians and their future is not red tape. They are the result of years of experience, science and research, and policy reform. This does not mean that all Ontarians and especially developers will agree with them, but they exist for a reason. Schedule 10 must be removed from bill 66.

You are proposing sweeping changes without actually identifying how and what may be undertaken. The bill does not present guidelines for what the rules or thresholds for open for business bylaws may be or how they will be assessed. The process is not and will not be transparent and citizens will be left with no recourse to appeal. This is unacceptable. Detailed proposed rules for 'open for business bylaw' creation must be posted on the environmental registry for comment and legitimate consideration.

It appears as though nothing will be off limits, i.e., provincially significant wetland, species at risk habitat, significant fish and wildlife habitat. And individuals municipalities can use their discretion to exempt developers from rules and regulations with their word that jobs will be created. It appears that this mechanism can be used anywhere in the province despite the employment rate, the state and values of the local landscape, or the scale of the impacts. This is completely unacceptable and totally unjustified. Even if you are to enable such policies, there must be clear and transparent limits that consider and weigh these aspects.

There are already clear guidelines for developers. It is the cost of doing business to avoid impacts to the greater community. That is why our policies exist. It is evident from schedule 10 that the government is completely unaware of ecosystem services provided by natural heritage features, such as those protected under section 2.1 of the Provincial Policy Statement.

Southern Ontario hosts about a third of Canada's population, and is dominated by intensive agriculture. Some municipalities have almost no natural vegetated cover remaining. This is widely known to have direct impacts on human health, air and water quality, fish and wildlife populations, pollinators and food production, and climate change resilience. It is all connected, and it is already not enough. That's why we use appropriate planning practices that require these impacts to be taken into account, because these features pay us back in the end with the irreplaceable services they provide.

Despite the Environmental Commissioner being silenced, we already know that current planning policies have gaps, and we know schedule 10 would be a ludicrous step backwards by decades. We know we have continued to lose wetlands and have harmful algal blooms. We have continued to see species populations collapse, such as multiple species of bumblebees responsible for our crop production. We know we have to do better, and that the best way to do so is continuing to build strong legislation and policy to support responsible planning across the province.

Municipalities often do not have the capacity or expertise to make informed decisions related to natural heritage protection and planning. Moreover, their interest in increasing tax revenue through development is in direct conflict with these policies in many cases, which aim to deter development in sensitive natural heritage features because of the well established values they provide. We need them. And developers are already given the choice to avoid these features or to properly assess the potential effects and demonstrate that no negative impacts will result. Yes, it takes extra time and work to ensure our fish and wildlife, and wetlands and water sources are protected.

The proposed changes go in the opposite direction recommended by experts, both in Ontario and around the world, and as such it is obvious that no expertise from internal or external professionals was used to inform this proposal and assess its potential impacts, nor can we expect such comments to be taken into account. As a result, we will be putting the future of our communities at great risk.

How will municipalities and the open for business bylaws weigh the permanent loss of ecosystem services for everyone, against the temporary promise of cost savings and jobs for limited individuals? What evidence exists that this will ultimately benefit the province, and how is that being weighed against what we stand to lose? We are already in a time of reduced unemployment rate, and economists know that most governments operate in a deficit and can safely do so almost indefinitely. Ontarians are smarter than this and know it costs money to run a province worth living in.

Many citizens (myself included) make a modest income but are willing to pay more for healthy and livable communities that protect our natural resources, and we are seeking out and moving to forward-thinking communities that do. We do not want to live in communities that enable developers to enjoy more profits by eliminating their due diligence through proper Environmental Impact Assessments and causing irreversible long-term impacts.

Many citizens also know that the lack of funding and resources for public service is what takes time for approvals, not the policies and regulations that protect us. But instead of providing proper support to implement due process, you are eliminating the rules altogether to appease a limited interest groups at the expense of all others. Ontario does not want to be held to the same reduced standards as developing economies, nor is it in our best interest.

Official planning and natural heritage policies under the Provincial Policy Statement are not red tape. They are a livable future for Ontario.