We appreciate the Ministry’s…

We appreciate the Ministry’s efforts to provide greater clarity and structure through the proposed Municipal Project Assessment Process (MPAP), including the updated project lists and more defined procedural steps. These additions help municipalities better understand expectations and improve the predictability of project planning and delivery.

At the same time, we remain concerned that elements of the proposal may reduce environmental oversight, particularly for projects that would become exempt from broader EA Act requirements.

To further support consistency and reduce ambiguity in how project categories are interpreted, we recommend the Province establish a small working group of municipal Environmental Assessment practitioners. This group could focus their review to refine the project descriptions within the Municipal Project Assessment Process. This review would ensure the descriptions are reflective of municipal projects and the descriptions are clear, current, and consistently understood across municipalities. A collaborative practitioner review would help minimize confusion, reduce interpretation challenges, and support more efficient project planning aligned with provincial expectations.

In reviewing the proposal, we also seek clarification on whether projects exempted from EA requirements and not included in the Archaeological Assessment Process would continue to be subject to the requirements of other applicable provincial legislation. In particular, we request confirmation that the proposed changes do not exempt municipalities from obligations under the Ontario Heritage Act or other statutes that provide important environmental, cultural, archaeological, or community protections.

Given the importance of providing municipalities with a stable and predictable regulatory environment, we respectfully request that the Ministry make a timely decision on the proposed amendments. A prompt resolution will enable municipal project teams to update internal processes, plan consultations, and align project schedules with the new regulatory framework as early as possible.