Regarding: Our Sept 18, 2023…

Regarding: Our Sept 18, 2023 Request for Extension of Public Comment Periods for ERO Numbers 019-6928, 019-6853, 019-6963, and 019-6951 to a Minimum of 145 Days

Dear Hon. Andrea Khanjin, Minister of the Environment, Conservation and Parks,

The Oxford Environmental Action Committee (OEAC) is a non-profit organization based in Oxford County, Ontario. We promote responsible and environmentally sustainable land use planning, use of the precautionary principle in decision making, the safeguarding of Ontario’s environment, and the protection and enhancement of public health and wellbeing.

It is our position that 60 days will not provide enough time for the public to review and prepare comments on the Environmental Registry of Ontario (ERO) proposals numbered 019-6928, 019-6853, 019-6963, and 019-6951, posted by the Ministry of the Environment, Conservation and Parks (MECP) on August 31, 2023. Therefore, the Oxford Environmental Action Committee is reiterating our September 18th request that the public comment period be extended to 145 days.

The OEAC is requesting the MECP extend the time period allotted for comments on the concurrently posted ERO proposals numbered 019-6928, 019-6853, 019-6963 and 019-6951 from 60 days, to a minimum of 145 days; to begin following the provision of all related materials.

The associated webinars being offered as part of the supporting materials for the proposals are all scheduled to occur after a substantial amount of the current 60-day comment period has already elapsed, with the last unique webinar being offered only 4 days before the final day of the public comment period. The public has had no prior notice of the proposals or their contents. It is our position that it is in the public interest for stakeholders to be well informed, and provided with a minimum of 145 days from the date of the last webinar and provision of all associated materials, in which to prepare comments.

We are also requesting that relevant Regulatory Impact Assessments related to the proposals be made publicly available at the outset of an extended public comment period. All materials and information related to the proposals, including webinar transcripts and descriptions should be made available on a website that is compliant with WCAG 2.0 at minimum, or in a PDF format compatible with popular screen readers, to ensure accessibility.

Our organization appreciates your attention to the request for an extended comment period, and enhanced accessibility of supporting materials, and looks forward to contributing further thoughts on the proposals.

Sincerely,

The Oxford Environmental Action Committee (OEAC)