What kind of projects should…

What kind of projects should require environmental assessment in Ontario?
Agree that exempting minor (low impact) projects would assist in streamlining the Municipal Class Environmental Assessment (MCEA) process. Similar to Project Schedules in the MCEA document which are being simplified/ amended for 2019 i.e. using change in road allowance rather than Cost to determine level of assessment, amongst other amendments.

Are there some types of projects where a streamlined assessment process is appropriate?
Small trail projects where the project is just extending the alignment rather than creating a new one, and no impacts are proposed on natural heritage and hydrological features.

What could a one-project-one-review process look like for projects in Ontario subject to both provincial and federal requirements?
The City primarily follows the MCEA process.

Can you identify any other examples of provincial processes that could be better integrated?
Other Provincial processes such as the Endangered Species Act (permitting), Planning Act (development review), Clean Water Act (source water protection), and Conservation Authority Act (regulation 166/06) processes should be considered in the EA review.

What other actions can the ministry take to eliminate duplicative or redundant processes or approvals?
The Province should consider delegating certain roles and responsibilities to agencies that have the technical expertise and work closely with municipalities i.e., Conservation Authorities. From a municipal perspective it is easier to work with one agency than multiple agencies on technical matters. For instance, on Species at Risk matters municipalities are not engaged in the approvals process therefore not aware of what was negotiated between proponent and Ministry. Whereas, we work closely with Toronto and Region Conservation Authority (TRCA) on technical matters and are engaged throughout the decision-making process. We also work with TRCA on climate change and source water protection compliance and review through the development review process. The review of these matters can also be delegated to CAs for EAs.

What could a coordinated one-window approach look like for Ontario projects?
The one-window approach can assist municipalities with the circulation of correspondence and communication of comments with technical agency staff. The circulation/communications process is quite onerous, time consuming and costly. Submission of information can be sent to one agency rather than multiple. Often times our Federal and Provincial contact lists are out of date and time goes into updating the lists accordingly. We suggest the one-window approach have one generic email that would distribute the information to all the relevant agencies for comments. An online tool can generate a project file for the project. The Province should consider Dynamic 365 web tool. The one-window approach should work as long as it does not get bogged down.

Can you identify any areas in the environmental assessment process that could be better streamlined with the municipal planning process or with other provincial processes?
Yes, municipal staff need further clarity on how City Block Plan processes can be integrated into the MCEA process. We are especially interested in streamlining the process for Greenfield Areas where new collector roads are being created. Meeting MCEA requirements at this stage of development would streamline the need to conduct an EAs at the Plan of Subdivision stage.

What advantages and disadvantages do you see with the ministry’s environmental assessment process being the one-window for other approval/permit processes?
A one-window approach would allow proponents to deal with one agency not multiple agencies. For instance, the current contact list for a MCEA can consist of over 15 different agencies ranging from Federal to Provincial departments. If the one-window approach was established, the municipalities would only need to consult with one Provincial agency and one Federal agency. Unless, the intent is to have one agency manage both Provincial and Federal agencies? This would be even more efficient.

What areas of the environmental assessment program could benefit from clearer guidance from the ministry?
The City is looking for further direction on Indigenous Engagement and to understand our obligations on the Duty to Consult.

The City is looking for training on the climate change guidelines prepared by MOE. City staff are not qualified to review technical reports prepared by consultants. We suggest that the Conservation Authorities be delegated this review on behalf of municipalities.

Also, we need to understand the Province’s expectation regarding Source Water Protection policies review and implementation in the MCEA process.

TRCA Guidance documents can be lengthy and difficult to navigate. They should as succinct as possible.

What other actions can we take to reduce delays and provide certainty on timelines for environmental assessment?
Provincial staff should consider the following:
-Acknowledge receipt of notice of commencement and subsequent correspondence
-Timelines should be established for Provincial staff
-Timelines should be adhered to
-2-3 week turn-around to review draft TOR, ESRs etc.

What are the advantages and disadvantages of using a sector-based terms of reference?
A Terms of Reference for MCEA will help streamline the process as it will provide guidance on the specific technical requirements for the various technical reports. This information can be used to develop RFP to hire consultants. With a baseline TOR we can modify each project TOR to suit the needs of the project.

Are there other ways we could improve our review timelines?
We support Provincial agencies having set timelines for responding to EA technical reports. Also, an online process can also help improve review timelines.

How would you like to be consulted on environmental assessment projects?
Yes, we would like to understand what types of projects are taking place in our neighboring municipalities.

Would an online environmental assessment registry be helpful for you in submitting an environmental assessment or accessing environmental assessment information?
Yes, an online system will assist with the transfer of information (correspondence) rather than printing and mailing large documents. Please keep in mind that these reports are very large and have many images therefore space and capacity is required for an online system. We suggest that online web-based tool Dynamic 365 be considered.

Perhaps a registry with email notifications for submissions and reviews. Guidance documents all in one place.

What type(s) of environmental assessment project information would you like to access online?
All the various EA projects should be included in on online database similar to the Canadian Environmental Assessment Registry where you can browse by type of project. For instance, the City would be interested in Brampton’s EA projects as they also have a Block Plan process.

Are there any existing online tools that would be appropriate to use for environmental assessment information?
Suggest the creation of an online checklist to screen for the various types of projects i.e., roads, waste, wastewater. The online checklist can assist municipalities in screening projects first by using a set of criteria. Once the online checklist has been filled out than the output would determine the schedule. It can also screen for low impact projects.