January 20, 2019 The…

January 20, 2019

The Honourable Todd Smith
Minister of Economic Development, Jobs and Trade
900 Bay Street, Hearst Block
Toronto ON M6H 4L1

Dear Minister Todd Smith,

RE: Bill 66, Restoring Ontario’s Competitiveness Act

Women in Ontario in Water is a diverse group of water practitioners, engineers, and scientists living or working in southern Ontario. The group was formed in 2012 and consists of 67 registered members. Among our contributing members are consulting engineers and EITs, planning and engineering staff from conservation authorities and water related NGOs, PhD students in civil engineering, water management and governance professionals, and environmental scientist consultants.

In response to the Ministry of Economic Development, Jobs and Trade (the Ministry) request for comments on the proposed Bill 66, Restoring Ontario’s Competitiveness Act, representatives from the Women in Ontario in Water (est. 2012) provide the following.

Overall, information provided to-date on the proposed Bill 66 and associated Acts (Proposed open-for-business planning tool (ERO # 013-4125)) and Regulations (New Regulation under the Planning Act for Open-for-Business Planning Tool (ERO # 013-4239)) is limited. However, our main concern is for the implementation of science and evidence-based policies, strong safeguards for surface and groundwater resources, and decision-making founded in meaningful stakeholder engagement.

Section 10 of Bill 66, as currently proposed, addresses none of those concerns. As such, we recommend that if amendments to the Planning Act proceed through Bill 66, that Section 10 be removed in its entirety. Furthermore, we reiterate requests made by the City of Guelph (January 15, 2019) and others that the province undertake formal consultation with municipalities and hold in-person public and stakeholder consultation sessions on potential changes to the Act.  We respectfully request that the Progressive Conservative government uphold platform assurances to protect the Greenbelt in its entirety and pass on a cleaner environment to future generations.

We, the undersigned:

a. Do not support Schedule 10 of the proposed Bill 66 to remove planning requirements under the Clean Water Act, Great Lakes Protection Act, Lake Simcoe Protection Act, the Greenbelt Act, Oak Ridges Moraine Conservation Act, Places to Grow Act, etc. To date, rigorous evidence-based, scientific information or studies regarding the impacts of Bill 66 on areas protected by these Acts have not been provided to the public. More information regarding the potential social, environmental, and economic impacts of Bill 66 and the associated “Open for Business” zoning bylaw is required before informed decisions can be made regarding the proposed Bill 66. These Acts primarily serve to protect our regional ecosystem services; namely, water resources for providing safe tap water and clean recreational environments that support Ontario tourism. Compromising the intentions or ability to uphold these Acts will in turn threaten the safety of our drinking water supplies, our health and the costs associated with drinking water treatment upgrades; and damage tourism and fishing industries in Ontario.
b. Are concerned for the protection of ground and surface water resources that flow across municipal boundaries and non-market ecosystem services from the Green Belt and southern Ontario that provide an estimated $2.7 billion and $85 billion yearly, respectively, to the province. Schedule 10 would dramatically undermine the integrity of these cross-boundary resources by allowing upper- or lower-tier municipalities to enact an “Open for Business” zoning bylaw, that have far reaching impacts on water quality and ecosystem health beyond municipal borders.
c. Call for mandatory public and stakeholder consultation as part of the Ministry’s approval process. Are highly concerned about provisions under the proposed Bill 66 which allow municipalities to enact the “Open for Business” zoning bylaw without public meetings or consultation with other stakeholders (e.g. neighbouring municipalities). Due to the far-reaching implications of these bylaws and the provincial government’s own recognition of the importance of meaningful engagement as stated on the Ontario Government Public Engagement webpage (Updated: Sept 5 2018), if amendments to the Planning Act proceed through Bill 66, public and stakeholder consultation must be mandatory.
These comments do not represent the opinions of all members of the Women in Ontario in Water network nor the opinions of our employers. Thank you for the opportunity to comment Bill 66. We appreciate you taking the time to review the opinions of the public during this comment period with the care and attention they deserve. Please do not hesitate to contact us if you have any questions regarding Women in Ontario in Water’s feedback.

Sincerely,

Select members of Women in Ontario in Water