“Registration first” for…

“Registration first” for development activities, without permitting and on the basis of an honour system, is not acceptable for Ontario. We know from past practice that developers will cut corners and ignore regulation; we have seen plainly that there is not sufficient oversight available through the MNRF or MECP to monitor developments already in progress; we know that developers act with impunity once they are on the land, and will not be constrained by these loose guidelines. Self monitoring is a colossal failure. For evidence, see the Ontario’s own recent Auditor Generals’ reports on issues around Species at Risk and the Aggregate Industry, for examples.

For an example, only look to the record of the aggregate industry which acts with impunity. (see the record of fines, and the Auditor General’s Report of 2023 “Value for Money”. ) This industry regularly clear cuts mature hardwood forests, and fills in wetlands before undertaking any required natural environment assessment. This is cynical and self serving. Media reports would indicate that there are many instances of such flagrant disregard for the environment — even within the existing process. With fewer constraints, we can only imagine what desecration will take place.

Surely, what is the point of us having the Auditor General report on activities in the province and make suggestions, only to ignore the reports? This an offensive waste of taxpayer funds, and a blatant “thumb in the eye” of the democratic process in this province.

Do not pass Bill 5.

This legislation would allow a shameless cash grab by developers, at the expense of the province’s future. This legislation suggests deliberate and blatant ignorance of the publicly held environmental values of this province to advantage politically well connected corporate interests who support the current government. This is both shortsighted and immoral.

Further, the use of the argument that housing and transportation are needed is an egregious and deliberate use of faulty logic. “Build more housing now” is a red herring where environmental values are concerned. The need for these services only emphasizes how important oversight must be, and that care and caution must be exercised by the government on behalf of all its citizens to protect our natural heritage. The government must do better.

Great swaths of Ontario remain unevaluated wetlands and forest reserves; their wealth of flora and fauna must be accounted for, and protected for our future health and well being.

We know, for example, that our wetlands are more valuable as carbon sinks that even our forests. Ontario has a wealth of unevaluated wetlands, many of these located inconveniently for developers. We rely on our elected representatives to act in the best interests of all the citizens of Ontario. Unprecedented heat waves and storm events have caused millions of dollars in damage in recent years, to the GTA and the wider area of developed southern Ontario. Such damage will only be exacerbated by the unconstrained and relentless drive of the bulldozers into areas of the province that have not been assessed, in particular wetlands and river systems that are home to a wide range of species at risk.

Urgent Recommendations:

do not replace permitting with mere registration; that is an invitation for exploitation, corruption, and ultimately the loss of our natural heritage in this province. As well, the future potential of this heritage for tourism, and our fundamental well being, will be damaged.

do not limit the protection of species to merely their nesting/den areas, as any development around such sites will not protect the creatures in the long run

do not remove the term “harass” from the protective legislation, as this is a key term in the protection of birds and animals on any development site;if necessary, more clearly define the term habitat, but without diminishing its meaning

do not alter the constitutional requirement to consult with Indigenous communities on these issues

do not limit the democratic rights of citizens to appeal through the courts against unbridled development that interferes with our rights to a safe, healthy and rich natural environment in the future

Recommendations:

Use a Natural Heritage Valuation system, to enumerate the dollar value of environmental assets in a given jurisdiction, so that the true costs of unbridled development are known, understood and made public. Developers should be paying a great deal more for the privilege of interfering with the natural environment in Ontario. In a topsy-turvy world, we are giving away our environment to developers, at a great cost to us, in our health, enjoyment, future propserity through tourism, and safety. In particular, the costs of potential catastrophic heat and weather events are borne by the citizenry, when developers have damaged (and profited from) the destruction of environmental assets. This is wrong.

Do not use the “registration” system to allow developers to proceed with projects and self monitor. Their ability and willingness to play by rules has been shown to be suspect in many past instances. Past is prologue.

Stop using the flawed argument of needed housing and transport as a political rallying cry; yes, these services and facilities are needed. However, better use of existing vacant land in urban areas must be prioritized, and pristine wetlands and forests protected for the future. New builds are always cheaper than retrofits — but greedy developers should not be given the easy way to amass fortunes, at the expense of our environment and the protection of our species at risk.

Use a case by case approach to assessing whether a development project should proceed in a sensitive area, with a threatened species habitat.

Revisit the Auditor Generals Reports Protecting and Recovering Species at Risk
(2021) and Value for Money: Management of Aggregate (2023) , and use those guidelines in crafting appropriate legislation that serves ALL of Ontario’s citizens, not just already wealthy developers in the housing and aggregate sectors.