The MCEA should not be…

The MCEA should not be revoked but instead should be updated. While the Environmental Assessment Act has been around for 50 years the MCEA has only been in place for approximately 30 years. It most certainly needed to be updated but revoking it is a drastic step that will have consequences in the future that will be difficult to turn back around. For example, it is worrisome that anything to do with roads (except for expressways which very few municipalities propose) and bridges will no longer require any environmental review when those are projects that the public, stakeholders and Indigenous communities often have key comments about since the road can be adjusted based on the environment present but it leads to where watermains and sewers will potentially be located.

Another overall main concern is that the proposed regulation would appear to download the responsibility for consideration of environmental issues and possible alternatives to the municipality. Many municipalities may see this as uncertainty in how to deal with this and will they now need to develop their own process? What will be the mechanism for ensuring consistent application of environmental requirements in the planning application process?

It was difficult when legislation removed the opportunity for the public to raise concerns (previously Part II Order requests) and they felt they didn’t have a voice in the process. This proposed regulation of revoking the MCEA will remove them from the process and move us to just building homes and associated infrastructure. We will no longer take into consideration the potential impacts on all aspects of the environment, as defined in the Environmental Assessment Act. More consideration should be given as to how to address consideration of alternatives and potential environmental impacts since once they occur and infrastructure is constructed we remove the opportunity to step back in time and correct it back to the previous state.

See the attached file of comments for additional specific comments on the proposal.