The City of Belleville is…

The City of Belleville is happy to provide comments on the December 2025 update (ERO 19-7891) to the proposed municipal environmental assessment requirements, called the Municipal Project Assessment Process (MPAP). The City of Belleville appreciates the effort put into streamlining the environmental assessment process by the Province of Ontario. These improved timelines will help the city support the increased demand for the construction or rehabilitation of critical infrastructure. The questions are as follows:

1. How does this impact the use of Master Plans? Will there be an alternative EA process for broad scope, long-range plans or large integrated systems of projects?

2. If there are no public consultations after alternative solutions have been identified, how will the public have an input on the solution selected and planned throughout the rest of the report? Would there be a plan to discuss this to avoid having to redo the planning and design if the selected solution is questioned?

3. If there are no public meetings, just public notices and access to the draft and final report, will there be a way to address/manage the likely increase in questions received or comments made if the public cannot ask clarifying questions or make comments during a community meeting?

4. What is the procedure for an EA review if 10 years have passed without the project progressing/getting completed?

5. How is a municipality supposed to determine potential for archeological resources without in-staff professionals or hiring a licensed archaeologist? Additionally, why does a report need to be written even if it is determined there is no archaeological potential, compared to the planning act, which only requires the use of a checklist?

6. If an archaeological resource is identified, which does not have a relation to Indigenous communities, why is Indigenous consultation necessary?

7. For the AAP, how is the process more streamlined than the existing ASP if the requirements for mandatory consultation with Indigenous communities are increasing? How will these Indigenous communities be supported to meet this increase in demand for consultation?

8. Why are the project EA and AAP requirements so different between public and municipal sectors if the environmental impacts and risk to archaeological resources are the same?

9. Will formal guidance be provided by MECP / Canada for consistency in municipal consultation with Indigenous Communities? The Duty to Consult is routinely downloaded to municipalities without direction on how to satisfy consultation requirements.

10. Are there any relevant dates with respect to Planning Act applications that would indicate whether old/ current, new, or transition provisions would apply? 

11. What if there are conditions to complete an EA for a draft approved subdivision, and the project no longer requires one under the new rules? 

12. For a private developer project that requires a Schedule B or C EA under the current EA process, but that does not appear in the MPAP list: Do Schedule B and C EAs continue to be required in full?

An example would be to establish a new sewage pumping station, which currently requires a Schedule B EA, but not included in the MPAP Appendix 2 of the slide deck.

13. For Appendix 2 - does 'applicable to private sector' extend to off-site works that a developer must undertake as a condition of their planning application approval - or is private sector work limited to within the boundary of the planning application? 

The City of Belleville appreciates the opportunity to comment on this matter.