The Pickering Naturalists…

The Pickering Naturalists are submitting this comment regarding Bill 66, and in particular our concerns about the proposed Schedule 10 which we believe is counter to decades of public policy designed to protect Ontario's environment, water and green spaces.

The Pickering Naturalists nature club has members from Pickering as well as from Toronto, Ajax, Whitby and Oshawa and points further north. We are very familiar with the ecological and agricultural value of the Greenbelt and are familiar with the past and current threats the Greenbelt has faced over the years from development and urban sprawl.

We have particular concerns about the opportunities for municipal councils to submit an "open-for-business" bylaw to the Minister without prior notice and public consultation and oversight. Some municipal councils have demonstrated decisions in that past that erode public confidence in the local government decisions.

1. Bill 66 affects every municipality in Ontario. Bill 66 allows municipalities across the province to create “open-for-business by-laws” that would trump critical legal requirements to protect water, natural heritage, farmland and human health and well-being. These bylaws would take precedence over municipal official plans.

2. Bill 66 threatens drinking water across Ontario. Open-for-business by-laws would override policies in approved source protection plans intended to protect existing and future sources of municipal drinking water from threats such as landfills, sewage systems and improper handling of fuel, manure and pesticides.

3. Bill 66 threatens wetlands, woodlands and habitat for species at risk across Ontario. Open-for-business by-laws would circumvent protections for these important habitats and species set out in the Provincial Policy Statement (PPS) under the Planning Act.

4. Bill 66 threatens farmland across Ontario. Open-for-business by-laws would bypass agricultural protections set out, for example, in the PPS. This could lead to more urban sprawl.

5. Bill 66 threatens two million acres of natural areas and farmland across the Greenbelt. Open-for-business by-laws would override protections for natural heritage and farmland set out in the Greenbelt Plan and the Oak Ridges Moraine Conservation Plan.

6. Bill 66 threatens fresh water and the ecological health of the Lake Simcoe watershed. Open-for-business bylaws would trump requirements set out in the Lake Simcoe Protection Plan.

7. Bill 66 would undermine efforts to make Ontario communities more livable, sustainable and resilient. Open-for-business by-laws would override PPS policies supporting active transportation, affordable housing, green infrastructure and climate resiliency.

8. Bill 66 would compromise transparency and public engagement. Contrary to current legal requirements (Planning Act, Clean Water Act), the by-laws could be passed without any prior public notice, behind closed doors.

9. Bill 66 would leave citizens without recourse. Community members would not be able to appeal open-for-business by-laws to the Local Planning Appeal Tribunal.

10. Bill 66 threatens human and wildlife health through increased exposure to toxic chemicals. Bill 66 proposes to repeal the Toxics Reduction Act, which requires certain industrial facilities to consider ways to reduce the use and emission of toxic chemicals in their operations.

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