Dear Mr. Michael Helfinger, …

Dear Mr. Michael Helfinger,

I am writing to provide comments on Bill 66 for the Ministry's consideration, specifically with regards to Schedules 3, 5 and 10.

Schedule 3: Ministry of Education
While I appreciate the government's efforts to increase access to affordable child care, safe, quality and attentive care also need to be a priority in order to prevent the tragic daycare deaths that have happened in the past. Increasing the limit of children in home-based child care settings must be accompanied by strengthened government programs and stronger oversight to provide adequate training to child care providers, and licensing and inspection of child care settings.

Schedule 5: Ministry of the Environment, Conservation and Parks
I humbly ask the government to reconsider the proposal to completely repeal the Toxics Reduction Act, 2009 and associated regulations by 2021. While the government cites the science-based Federal Chemicals Management Plan as a robust mechanism to manage toxic chemicals, it should not replace the need for toxic substance reduction plans to be developed by owners/operators of certain industrial facilities in Ontario. Polluters must be held accountable for preventing pollution and protecting public health and safety by reducing the use and creation of toxic substances in their facilities. By eliminating the Toxics Reduction Act, the Government of Ontario is peeling back the multi-layered protection against toxic substances in Ontario, and forfeiting important provincial oversight of the use of toxic substances, for which the Province could be held liable.

Schedule 10: Ministry of Municipal Affairs and Housing
Again, I humbly request the government to reconsider the proposal to introduce a new municipal tool that would allow municipalities to pass an open-for-business planning by law without the need to: be consistent with the PPS, conform with Provincial Plans (including the Greenbelt Plan, Lake Simcoe Protection Plan, Growth Plan for the Greater Golden Horseshoe, Oak Ridges Moraine Conservation Act, etc.), conform with municipal Official Plans, consult with the public, adjudicate disputes through the Local Planning Appeal Tribunal, conform with significant threat policies identified under the Clean Water Act, among other provincial requirements. These provincial policies and plans play an essential role in protecting our quality of life and a clean and healthy environment in Ontario. A single test of meeting minimum job creation thresholds should not replace the need to conform/be consistent with the array of essential policies and plans listed above. Furthermore, municipalities have/are in the process of identifying employment lands through a municipal comprehensive review, to identify appropriate locations for current and future employment uses. An expedited approvals process for approving business development is unnecessary if these business were to be located in identified employment lands. While the respect for local municipal flexibility and autonomy is appreciated, the Province must also ensure that municipalities do not abuse their planning powers provided through the Province. The significant policies and plans that municipalities are able to by-pass through the proposed open-for-business planning tool is a disaster waiting to happen.

Thank you for your consideration.