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, urban sprawl into hazardous floodplains and sensitive habitats actually hurts affordable housing and safegbeing achieved and the safeguarding of Ontario’s sensitive ecosystems. Building new homes outside of city boundaries requires new vast investments both to build new infrastructure (roads, transmission lines, transit routes and sewers) as well as to maintain and refurbish these . Roads fragment natural habitat and harm biodiversity. Meanwhile, existing urban boundaries still contain 350 square kilometers that could be developed for affordable homes which would have less of an impact, and which would be closer to existing transit (Carranco 2023).
The government states that moving towards a Class EA process will leave a “robust” framework for environmental protection but my own experience as a consultant is that class EAs are a fast-track process whereby small, routine projects are deemed and to have minimal impact to the environment. IN real life, Class EAs are often used for pre-approved projects that are never rejected (See :Lindgren and Dunn 2019, 284), and higher impact environmental projects have been inappropriately slipped under Class EAs (Lindgren and Dunn, 296). Since 1993, 90% of all EAs have been obtained through Class EAs. Class EAs have proven completely ineffective in protecting our environment.
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. So in effect, if this amendment is to pass, the public will have no real democratic process to determine 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 the Sustainable Development Goals (SDGs) by 2030 as put forth by United Nations, and 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 already incredibly ineffective. The movement towards Class EAs operates purports to secure affordable housing, while providing no evidence it will do so. To meet SDGs by 2023, we should be strengthening environmental protection, and safeguarding our sensitive habitats from further human activity.

Sources:
Lindgren, Richard D., and Burgandy Dunn. “Assessment in Ontario: Rhetoric vs. Reality.” he 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…