Bill 66, Restoring Ontario's…

Bill 66, Restoring Ontario's Competitiveness Act, 2018 is aimed at increasing employment by cutting red tape - eliminating redundant regulations. This bill contains two Schedules, 5 and 10, that will needlessly bypass or eliminate critical regulations and put public health and safety at risk. Schedule 10 will result in expensive sprawl, harm to wildlife and sensitive ecosystems and the reduction of public participation in the planning process.

Regulations that protect public health and safety and our natural environment are not red tape.

For nearly two years, Canadian Environmental Law Association (CELA) represented the Concerned Walkerton Citizens at the Public Inquiry investigating that Ontario community's tainted water tragedy. It has definitely caused me to be very concerned about Bill 66 for the reason that CELA has expressed very strong opposition to Bill 66 Schedules 5 and 10.

With regards to Bill 66 Schedule 5, CELA states it does not agree “that the Toxics Reduction Act, 2009 (“TRA”) is duplicative of requirements under federal law on control of toxic substances and, therefore, does not find persuasive the [Minister’s] argument that repealing the TRA will reduce a burden on industry from having to comply with duplicative programs. Ontario has also previously identified many toxic substances in Ontario not covered by federal requirements that if they are still present in the province could benefit from application of the TRA.”

Regarding Bill 66 Schedule 10, the long list of laws, plans and policies that the Open For Business Zoning By Law created by Bill 66 are exempt from includes: the Ontario Planning and Development Act, Places to Grow Act, Greenbelt Act, Oak Ridges Moraine Act, Lake Simcoe Protection Act, Provincial Policy Statement, Great Lakes Protection Act, and the most concerning the Clean Water Act (CWA). CELA concluded “there is no legal justification or compelling public policy rationale for allowing open-for-business planning by-laws to bypass key Planning Act provisions, and to circumvent or override the provincial laws, policies and plans listed in Schedule 10 of Bill 66. CELA maintains that Schedule 10 is a regressive, unwarranted and potentially risky proposal that is inconsistent with the public interest, and that does not adequately safeguard the health and safety of Ontarians. In particular, CELA objects to Schedule 10’s ill-conceived rollback of current legal requirements that were specifically enacted under the CWA to prevent a recurrence of the Walkerton Tragedy. Accordingly, CELA strongly recommends that Schedule 10 be immediately abandoned or withdrawn by the Ontario government.”

It is my opinion that CELA's warnings and recommendations should be taken very seriously. None of us want to see another tragedy like the Walkerton water crisis or the Lac Megantic train disaster happen in Ontario. We count on the Provincial Government to protect our public health and safety.

With a thriving local food movement, prime farmland needs protection, but Schedule 10 would do the very opposite. Agriculture is a major driver of the Ontario economy, particularly in Brant County where I live. It does not make sense to undermine this important sector of the economy by allowing development that bypasses acts, policies, plans and regulations that have been put in place to protect existing agricultural land within Brant County and in other areas such as the Greenbelt. Implementing Section 10 will only promote sprawl. Sprawl will use up agricultural land and it will be expensive. Sprawl results in higher taxes to pay for the additional infrastructure and public transit.

Brant County relies heavily upon ground water from the Grand River watershed, and every municipality in Ontario relies on having a source of clean high quality drinking water. Wetlands and other areas such as moraines are critical to maintaining water quality in lakes, rivers, streams and aquifers. We need the Province to protect watersheds such as the Grand River watershed. Moraines and wetlands also require protection because they play a critical role in maintaining water quality within the watersheds. The Paris-Galt Moraine, the Oak Ridges Moraine, the Greenbelt along with drinking water sources such as Lake Simcoe and the Great Lakes must remain protected. Sprawl puts extreme pressure on existing aquifers, and can result in contamination of water sources. It is critical that development plans comply with the Clean Water Act and other planning policies and regulations that protect water sources.

I would like to state that I have deep concerns regarding the the right to appeal and the requirement for public notice and consultation that could all be bypassed with Schedule 10. Public notice and consultation is critical to ensure that the we have the ability to present perspectives and information that will balance those of the developer. Public participant requirements are also not red tape, they are essential to good land use planning.

In conclusion I would like to respectfully request that both Schedule 5 and Schedule 10 be withdrawn from Bill 66.