· The Town of Oakville is…

· The Town of Oakville is supportive of the existing Municipal Class EA Process as it provides a standardized comprehensive framework to protect Ontario's environment, review alternative solutions in a holistic manner and engage the public, indigenous groups and stakeholders.

· The Town of Oakville is also generally supportive of efforts by the Province to streamline the Class EA process to date, and would be generally supportive to further streamline the Class EA process to deliver critical infrastructure and works to Ontario residents in a timely manner.

· Prior to the inception of the Municipal Class EA process, Ontario municipalities delivered projects in a less consistent manner, sometimes with little or no public engagement and sometimes with unintended environmental impacts. The Municipal Class EA process, and the legislation that allows same, was an improvement.

· The Municipal Class EA process has generally worked well for Oakville, and we believe, for Ontario municipalities in general.

· The proposed MPAP excludes many project types that are currently subject to the MCEA process. Some project types that are proposed to be excluded from the new MPAP have the potential for significant environmental impacts (e.g., linear infrastructure such as new or expanded roads) as well as municipal policy and provincial and federal legislation implications. These proposed changes to the EA process remove a streamlined and standardized review process that ensures the town, as well as regional or private proponents of infrastructure projects, do not conflict with applicable town policies or provincial or federal legislation. They are also projects that can garner significant public interest. Municipalities may still wish to undertake studies and consultation, similar to the elements of a Class EA, to engage the community and demonstrate how the project will meet policies and legislation and the needs of the residents. The studies and engagement will require a similar schedule to a Class EA, but without a defined and consistent structure, and may not be delivered more quickly than they are under today’s framework.

· The proposed change will necessitate that municipalities develop their own review processes for some project types, which will result in patchwork of municipal processes across the province that are not streamlined or standardized, and that may not apply to upper tier or private proponents of infrastructure projects. There is also significant concern about environmental impacts if the development and consideration of project alternatives are not incorporated into whatever process is developed to review infrastructure projects not subject to the proposed MPAP.

· Under the section heading, ‘Proposed projects not to be subject to the new Regulation’, in the last paragraph, it is acknowledged that there may be other legislative, regulatory and/or municipal requirements outside of the EA Act. If a majority of projects are removed from an environmental assessment process, how will those requirements be identified for those projects? In the current system, the EA process is used to identify and flag for the municipality requirements under municipal official plans and different acts and regulations.

· In the same location referenced above, it is acknowledged that municipalities may continue to carry out master servicing planning under their own processes to assess planned municipal infrastructure. Given the proposed changes, how can lower tier municipalities ensure that upper tier municipalities and private developers carry out a robust enough review process for projects taking place within their jurisdiction if it is not required under MPAP?

· In the event that the Province decides to revoke the Municipal Class EA process, Oakville would be generally supportive of the recommendations of the Ontario Municipal Engineers Association as outlined in their later dated March 12, 2024 and submitted as a comment to ERO -019-7891.

· The MPAP process, as currently presented, presents a timeline which appears too short to properly review the environmental and other issues associated with large undertakings. Improvement is required. For example, some environmental matters need four season monitoring to establish baseline conditions. To properly assess impacts of potential solutions, this work will still be required – but it will need to be completed before the MPAP begins. The MPAP would not necessarily result in an overall time savings in situations like these.

· Is there an option to consider proposed excluded projects under an MPAP process anyway, as a voluntary option, to the discretion of the affected municipality? If a voluntary option based on municipal discretion is offered, could it also be applied to upper tier and private proponents of infrastructure projects?

· The current Provincial Policy Statement, 2020, (and the proposed provincial planning statement) defines development as,

“the creation of a new lot, a change in land use, or the construction of buildings and structures requiring approval under the Planning Act, but does not include: a) activities that create or maintain infrastructure authorized under an environmental assessment process…”

How will the proposed changes impact any municipal processes that rely on this definition of development? E.g., site plan, site alteration, etc. Is the Province proposing changes to the Provincial Policy Statement?