I have concerns with the…

I have concerns with the proposed changes in five areas:

1. Consideration of heritage and archaeological resources:
I echo the concerns raised by the Ontario Archaeological Society (OAS) that this proposed change to the EA process does not provide sufficient protection for cultural heritage resources, archaeological resources, and ancestor burials. Removal of the current regulations that trigger heritage and archaeological assessments in advance of impactful infrastructure projects could leave known and potential cultural heritage resources and archaeological resources, as well as ancestor burials vulnerable to disturbance and destruction.

2. Lack of municipal trigger/processes in place:
The ERO listing notes: “Depending on the project and location, there may be other legislative, regulatory and/or municipal requirements outside of the EA Act.” This essentially states that the responsibility and onus for requiring any studies for most infrastructure projects will be on the municipalities. The ERO statement notes that the proposed process will “reduce duplicative requirements,” even though there is no duplicate system for cultural heritage resources. Most municipal legislative frameworks do not currently have any trigger for heritage or archaeological assessments in infrastructure projects as this has always been part of the MCEA system. Municipal heritage planners would not have the authority, capacity or ability to identify and address impacts to cultural heritage resources as a result of the gaps left by the proposed legislation.

3. Creates inconsistency and risk:
By downloading the triggers for cultural heritage and archaeological assessments to individual municipalities, there will be inconsistency across the Province. This inconsistency will create significant uncertainty. Further, without the consideration of cultural heritage resources early in the process, there is a risk that key information regarding cultural heritage resources will not be obtained by the project team until late in the process, which will cause project delays and increased costs.

4. Makes it more difficult to reduce carbon pollution:
The Bill would remove our carbon pricing system, which puts rebate money back into the pockets of Ontarians. Carbon pricing is one of the best ways to reduce carbon pollution from public, private and industrial activity - it’s “Pay for what you use”, which is a pretty conservative concept. While it’s commonly called a “carbon tax”, it’s not actually a tax; most of the money (80%) is returned to us and deposited straight into our bank accounts. Most of us get more money back than we are charged. Those that get less back have more incentive to change. The other 20% is used for projects to help reduce Canada’s carbon pollution.

5. Increases both sprawl in housing and highways:
Sprawl housing forces people to live farther from work and necessities, is usually difficult for public transit, and is rarely affordable housing. As well, creating more highways can actually slow traffic down, due to more cars on the road network. This all increases costs for homeowners, in both gas money and time spent in traffic. It will also lead to more carbon emissions at a time when we need to significantly lower our emissions.

While the changes proposed through the Get it Done Act may accelerate the construction of certain development, it comes at the price of our health, our environment, and our cultural heritage.