This comment is in relation…

Comment

This comment is in relation to EBR Notice 019-8562, posted by the Minstry of Energy (Ministry) on April 17, 2024, in respect of "Proposed Regulations Under the Ontario Energy Board Act, 1998 to Support Building Homes and Transit Faster by Prescribing Conditions for Fast-Tracking Approval of Certain Small Energy Infrastructure Projects" (Proposed Regulation).

I strongly disagree with the statement n the EBR Notice that the Proposed Regulation "would have no impacts on the environment".

This is because the Proposed Regulation seeks to facilitate the process for expansion of methane gas infrastructure to promote the transportation and use of methane gas.

Methane gas is a powerful greenhouse gas (GHG), and the process of extracting, transporting and combusting it results in the discharge of these powerful GHGs, which will have a huge effect on climate change and contribute to the current climate crisis.

The Ministry of Energy's Statement of Environmental Values (SEV) acknowleldges that cliamte change is a material component of the "environment" for the purposes of the Environmental Bill of Rights.

The SEV states that the Ministry develops regulations it will "Consider the ... threats from climate change to Ontario’s environment, and people’s health, safety, and prosperity, and evaluate opportunities to reduce greenhouse gas emissions and/or enhance Ontario’s resilience to a changing climate".

There is nothing in the EBR Notice which indicates that the Ministry has considered the potential for "threats from climate change to Ontario's environment", or "evaluate[d] opportunities to reduce greenhouse gas emissions" in respect of the Proposed Regulation, which will facilitate the construction of infrastructure for the transportation and use of a powerful GHG (methane gas).

I would respectfully request that the EBR Notice for the Proposed Regulation be reposted to reflect consideration, as required by the Ministry's SEV, of the potential threats from climate change and of alternatives to the Proposed Regulation which would reduce GHG emissions.