To the Environmental…

To the Environmental Registry of Ontario RE: ERO #019-4219 under the Environmental Assessment Act

ERO #019-4219 proposes that transportation, including highway and rail “of any length”, and electricity transmissions be moved to a “streamlined EA process”, known as Class Environmental Assessments (Class EAs). The Minister claims that these changes are important for “affordable housing”, and will still “ensure environmental oversight and robust consultation”.

While Ontarians need affordable housing, building urban sprawl into sensitive habitats actually harms important goals towards affordable housing and the safeguarding of Ontario’s sensitive ecosystems. Building new homes outside of city boundaries requires vast new investments to build infrastructure — including roads, transmission lines, and new transit to connect to these new urban areas. Roads, in particular, fragment greenspaces and harm biodiversity by isolating populations of flora and fauna — resulting in problems with migration and breeding. Meanwhile, existing urban boundaries still contain 350 square kilometres that could be developed for affordable homes — thereby reducing the negative impacts on the environment, while saving money and making existing transit accessible. (Carranco 2023).

The government states that moving towards a Class EA process will leave a “robust” framework for environmental protection. Class EAs are a fast-track for environmental assessments where projects are deemed somewhat routine, with minimal impact to the environment. However, there is much well-deserved criticism for Class EAs used in real practice. Currently, Class EAs are essentially pre-approved projects that are never rejected (Lindgren and Dunn 2010, 284), including some higher impact environmental projects which have been inappropriately slipped under Class EAs (Lindgren and Dunn 2010, 296). Since 1993, 90% of all EAs have been obtained through Class EAs. Class EAs are completely ineffective at providing any protection for the environment, and leave public input relatively meaningless.

Furthermore, ERO #019-4219 states that the only valid reason for asking for the Minister to escalate further action, under a Class EA, is on the grounds of aboriginal treaty rights, which, yes, must always be considered. In effect though, if this amendment is to pass, there will be no full public forum available to provide a true democratic process when determining how land is developed, and whether a valuable habitat in question warrants enough care to refuse the project altogether.

The federal government committed to meeting Sustainable Development Goals (SDGs) by 2030, as put forth by the United Nations — these actions of our provincial government go directly against multiple goals:

Goal 11: Sustainable cities and communities
Goal 13: Climate Action
Goal 15: Life on Land - protect, restore and promote sustainable use of terrestrial ecosystems, sustainably manage forests…halt and reverse land degradation and halt biodiversity loss

In conclusion, ERO #019-4219 further erodes an environmental assessment process that is incredibly ineffective at both local and provincial levels. The movement towards Class EAs operates under the guise of securing affordable housing, while providing no evidence it will do so. To meet SDGs by 2023, we should be strengthening environmental protections, and safeguarding our sensitive habitats from further human activity.

RESOURCES

JOURNAL ARTICLE

Lindgren, Richard D., and Burgandy Dunn. “Assessment in Ontario: Rhetoric vs. Reality.” The Journal of Environmental Law and Practice, 2010, https://cela.ca/wp-content/uploads/2019/08/766.LindgrenDunnFinal.pdf.

REPORT

Toronto Region Board of Trade, and World Trade Centre Toronto. Meeting in the Middle: A Plan to End Exclusionary Zoning and Tackle Ontario’s Housing Crisis. December 2021, https://bot.com/Resources/Resource-Library/Meeting-in-the-Middle.

Carranco, S. (2023, May 1). Greenbelt Status Update. The Grind Magazine, 1(04), 8. https://www.dropbox.com/s/e0zo5kkya4hcdo9/THEGRIND_ISSUE4_FINAL_MAYJUNE…