Re: ERO number 019-4219 –…

Re: ERO number 019-4219 – Moving to a project list approach under the Environmental Assessment Act

The proposed Project List in the Environmental Assessment Modernization document (Nov 21, 2021) is very incomplete and will not result in safeguards for Ontario’s environment. It is imperative that the list be expanded to include all projects that can have serious environmental effects.

Among the projects that must be included in the project list if Ontario’s environment is to be protected are the following.

All hydroelectric projects ≥10 MW, not only those ≥200 MW.

Other projects that affect Ontario’s water systems including non-hydro dams and reservoirs, water diversion projects and irrigation projects. Hydro and non-hydro dams have many negative environmental effects, such as blocking fish passage. Yet, in Ontario, even basic fish passageways are almost never required in such projects.

All new highway projects, not only those that are >75 km long. These projects can cause serious harm to wetlands and farmlands, and invariably result in increased automobile and truck traffic - at a time when reducing traffic is important in the fight against climate change.

All new railway lines, not only those that are >50 km long.

Mineral development projects. The documentation on the website states that: “Ontario has a long history of regulating mineral development and has a deep understanding of the nature and type of environmental effects that mineral development can potentially create in some circumstances, as well as how to manage such potential effects.” In reality, Ontario has a long history of mining development that has resulted in polluted landscapes and waterways, as well as many abandoned mining sites that have not been properly rehabilitated.

Aggregate quarries.

Logging operations and associated mills. Logging operations and logging roads in Ontario have a long history of causing severe environmental damage, including loss of wildlife habitat and habitat fragmentation.

Pipelines. Pipeline spills pose serious threats, especially to waterways and wetlands that they cross or run alongside.

Public Consultation Process: In addition to updating the project list, it is critical that a comprehensive consultation process involving the general public, First Nations and interest groups be in place for all development projects and that the information be made readily available through an EBR-type website.