Senior Policy Advisor…

Senior Policy Advisor
Intergovernmental Policy Coordination Unit

Dear Sir:

RE: 013-4293 Bill 66, Restoring Ontario’s Competitiveness Act, 2018; 013-4125, Proposed open-for-business planning tool; and 013-4239, New Regulation under the Planning Act for open-for-business planning tool

McIlwraith Field Naturalists of London, Ontario Inc., operating under the public name Nature London, strongly opposes aspects of Bill 66, Restoring Ontario’s Competitiveness Act, 2018, especially in Schedule 10. Nature London, with origins dating back to 1864, has for many years advocated for the protection and enhancement of the natural environment and natural heritage of the London municipality and surrounding areas, and has provided input into the planning process for new development as it relates to potential impacts on the natural heritage. The proposals listed in Schedule 10, if passed into law, would override very important environmental protections under existing Acts for land, water, and wildlife. Nature London objects to the Government of Ontario’s contention that Bill 66 cuts “unnecessary” and “out of date” regulations (as per ERO posting 013-4293). Nature London requests that the comments below be considered with respect to all the ERO postings relevant to Bill 66 (i.e. 013-4239, 013-4125, and 013-4293).

Nature London strongly opposes any proposed open-for-business by-law that would trump or circumvent existing requirements set out in current legislation, especially the Provincial Policy Statement under the Planning Act; Clean Water Act, 2006; Great Lakes Protection Act, 2015; and municipal Official Plans, all of which are relevant to London and vicinity. Nature London also opposes the following;
1. The proposal to repeal the Toxics Reduction Act, 2009;
2. The proposal to allow an “open-for-business planning by-law” to be passed without public notice and consultation; and
3. The proposal that citizens would not be able to appeal such a by-law to the Local Planning Appeal Tribunal (LPAT). Public notices and consultation, and the right to appeal to the LPAT, help to ensure that a planned development is being assessed carefully for potential impacts on surrounding areas, including the natural environment, and may provide valuable additional information to municipal planners. Citizens, especially those paying provincial and municipal taxes, should not be deprived of this right to provide input.

A healthy natural environment is absolutely essential for a healthy human population and for beneficial flora and fauna. Facilitation of development under an “open-for-business planning by-law” that ignores sound and well thought-out existing environmental protection policies, which are based on transparent and fair public consultation, should never be allowed (a possible exception being in the case of extremely dire circumstances). Schedule 10’s short-sighted policies for short-term economic gain could potentially result in harmful long-term environmental damage.

The economic and health benefits provided by wetlands, forests, grasslands, farmlands, and other natural areas have been estimated to be about $85 billion/year for southern and eastern Ontario, and this should be carefully taken into consideration before any environmental protections under existing legislation are overridden in the name of expedited large-scale economic development under an ill-conceived “open-for-business by-law.” These natural areas contribute to fresh water, water filtration, wildlife habitat, flood control, pollination, soil formation, erosion control and climate regulation. Sprawling and unchecked development facilitated by “open-for-business by-laws” could threaten the long-term health and resilience of communities and natural areas, and have disastrous results. Environmental deregulation was partly responsible for the Walkerton tragedy.

Nature London urges the Provincial Government to remove Schedule 10 from Bill 66.

Thank you for providing the opportunity to comment.