Ministry should not abandon…

Ministry should not abandon its responsibility to protect our natural environment

Dear Minister, I beg you not to abrogate your responsibilities for "the protection and conservation of our natural environment," responsibilities assigned to you by the Ontario Environmental Protection Act and other legislation.

By downloading the Ministry's duty to care for the environment to municipalities, without taking ANY actions to ensure that municipal staff have the knowledge, support and ability to manage these responsibilities, this proposal puts our natural environment at grave risk.

Previously, municipal infrastructure projects needed to consult with Ministry advisors as to the potential environmental risk they might pose, and then study and propose solutions for the particular risks identified for that project.
This is all gone.

This proposal leaves it entirely up to municipalities to decide if and when special care is needed. This may work in huge metropolises with a wide range of skills on staff, but what about small municipalities with few staff? Who is the watchdog now? Who helps staff needing advice? Worse, who coaches municipal staff that they need advice?

Rather than washing your hands of this responsibility, you as Minister should be ensuring there are sufficient Ministry staff to quickly respond to questions from municipal staff. It is likely that Ministry budget and staffing cuts contributed to the slowness of the Municipal Class Environmental Assessment in the past. There is certainly documentation of long, long delays responding to questions and concerns from First Nations.

If implemented, this proposal must take into account the knowledge and ability of municipalities to make the judgement of what areas need to be studied, what questions need to be asked. Even a simple survey of municipalities' past experience with MCEAs would be a start.

Municipalities which prove to the Ministry they have adequate resources and experience to implement MCEA-equivalent processes could transition to the proposed new regime.
Municipalities which don't could be guided and coached toward this.

Even seemingly benign projects can have dire circumstances. Parking lot runoffs contain oil, grease and toxic chemicals from motor vehicles, pesticides and nutrients from nearby lawns and gardens. How can we be assured that staff in a small municipality will prevent these contaminating our drinking water?

No one wants another Walkerton.