Comment
Consistent with ensuring a rigorous Municipal Class EA for collector roads, Romandale raises the following issues:
1. The MCEA process no longer allows for a Part II Order request by a landowner based on environmental concerns. It is Romandale’s view that the EA Act should restore stake-holders rights to request from the Ministry a Part II Order for matters concerning requirements to conform to Provincial Acts and Policies such as the Greenbelt Act and Plan; private property issues; and ecological concerns.
2. Where there is a conflict of interest (bias), MCEA’s for municipal infrastructure should not be advanced by private developers.
3. As set out above, the proposal on the ERO website does not clearly state what changes are being considered. It was only recently that the Minister approved a new Municipal Class EA. There is no discussion in the proposal as to the potential implications to the changes and how the changes are in the public interest.
4. In addition to ensuring that collector roads remain subject to the Municipal Class EA, Romandale emphasizes that the location of a collector road should be as relevant to the type of EA as the “estimated costs”: in particular, any project through the Greenbelt Plan Protected Countryside should be subject to the most onerous Municipal Class EA, regardless of its estimated cost.
5. All decisions to approve must be accompanied by an evaluation analysis. The notice of approval and the evaluation analysis should be made public.
Supporting documents
Submitted May 9, 2023 5:39 PM
Comment on
Evaluating municipal class environmental assessment requirements for infrastructure projects
ERO number
019-6693
Comment ID
86059
Commenting on behalf of
Comment status