To the Environmental…

To the Environmental Registry of Ontario RE: ERO #019-4219 under the Environmental Assessment Act

ERO #019-4219 proposes that transportation, including highway and rail “of any length”, and electricity transmissions be moved to a “streamlined EA process”, known as Class Environmental Assessments (Class EAs). The Minister claims that these changes are important for “affordable housing”, and will still “ensure environmental oversight and robust consultation”.

While Ontarians need affordable housing, urban sprawl into sensitive habitats actually hurts both important goals towards affordable housing and safeguarding Ontario’s sensitive ecosystems. Building new homes outside of city boundaries requires new vast investments to build new infrastructure, including roads, transmission lines, and new transit to connect to these new urban areas. Roads fragment greenspaces, and harm biodiversity by isolating populations of flora and fauna from successfully migrating and breeding. Meanwhile, existing urban boundaries still contain 350 square kilometers that could be developed for affordable homes which would have less of an impact, and which would be closer to existing transit (Carranco).

The government states that moving towards a Class EA process will leave a “robust” framework for environmental protection. Class EAs are a fast-track for environmental assessments where projects are deemed somewhat routine and with minimal impact to the environment. However, there is much well-deserved criticism for Class EAs used in real practice. In practice, Class EAs are essentially pre-approved projects that are never rejected (Lindgren and Dunn, 284), and higher impact environmental projects have been inappropriately slipped under Class EAs (Lindgren and Dunn, 296). Since 1993, 90% of all EAs have been obtained through Class EAs. Class EAs are completely ineffective at providing any protection for the environment.

Furthermore, ERO #019-4219 states that the only valid reason for asking for the Minister to escalate further action, under a Class EA, is on the grounds of aboriginal treaty rights. So in effect, if this amendment is to pass, the public will have no real democratic process to determine how land is developed, and whether a valuable habitat in question warrants enough care to refuse the project altogether.

The federal government committed to meeting the Sustainable Development Goals (SDGs) by 2030 as put forth by United Nations, and these actions of our provincial government go directly against multiple goals

Goal 11: Sustainable cities and communities
Goal 13: Climate Action
Goal 15: Life on Land - protect, restore and promote sustainable use of terrestrial ecosystems, sustainably manage forests…halt and reverse land degradation and halt biodiversity loss

In conclusion, ERO #019-4219 further erodes an environmental assessment process that is incredibly ineffective at both local and international levels. The movement towards Class EAs operates under the guise of securing affordable housing, while providing no evidence it will do as such. To meet SDGs by 2023, we should be strengthening environmental protection, and safeguarding our sensitive habitats from further human activity.

RESOURCES

JOURNAL ARTICLE

Lindgren, Richard D., and Burgandy Dunn. “Assessment in Ontario: Rhetoric vs. Reality.” he Journal of Environmental Law and Practice, 2010, https://cela.ca/wp-content/uploads/2019/08/766.LindgrenDunnFinal.pdf.

REPORT

Toronto Region Board of Trade, and World Trade Centre Toronto. Meeting in the Middle: A Plan to End Exclusionary Zoning and Tackle Ontario’s Housing Crisis. December 2021, https://bot.com/Resources/Resource-Library/Meeting-in-the-Middle.

Carranco, S. (2023, May 1). Greenbelt Status Update. The Grind Magazine, 1(04), 8. https://www.dropbox.com/s/e0zo5kkya4hcdo9/THEGRIND_ISSUE4_FINAL_MAYJUNE…