The disproportionate…

The disproportionate reliance on the “opinion of the Minister” to make key determinations fundamentally undermines the purpose of developing criteria in the first instance.

The environment minister must be of the opinion that the project will benefit communities in Ontario, but wildlife communities are not specifically taken into consideration, even if they are at risk.

The minister considers whether a “trusted proponent” has a plan for engaging and working with Indigenous communities, but the criteria do not require that the “trusted proponent” uphold Canada’s commitment to the United Nations Declaration on the Rights of Indigenous Peoples, and, in particular, the duty to obtain free, prior and informed consent from Indigenous Peoples regarding initiation of projects.