I am writing over my concern…

I am writing over my concern of this government’s recent move to revoke the Municipal Class EA (MCEA) and Private Sector Developers Regulation.
I believe that this move will have significant negative effects on the natural and cultural heritage of Ontario, the rights of First Nations and the overall public good, while only serving to advance the interests of developers.

We currently face problems of climate change, biodiversity loss, habitat destruction, invasive species, and loss of ecosystem services from our natural areas. With all of this in mind we should be increasing environmental protections – making more robust requirements for environmental assessments – trying to streamline these processes seems misguided. If we truly want to make these processes faster, and more effective, we should be investing in education in the earth sciences, especially fields like environmental science and ecology. We should be developing in ways that work with the natural environment, ways that cause the least disturbance. We should be moving towards ecological restoration not merely mitigating our harms. We should be focused on missing middle housing, upzoning, walkability and mixed-use development, and yet this government seems intent on facilitating suburban sprawl into our natural spaces.

In addition to these environmental concerns there are numerous concerns related to the impact this could have on the cultural heritage/archaeological sites of Ontario concerns as well, not to mention the implications for First Nations regarding their cultural heritage and their right to a role in the development of their traditional territory. The Ontario Archaeological Society (OAS) has stated “The OAS finds this recent proposal very concerning, and in our opinion this new model does not provide sufficient protection for archaeological heritage and Ancestor burials”. The OAS goes on to point out that most municipalities depend on a Stage 1 archaeological investigation to determine not only the archaeological potential of an area, but also the presence of KNOWN archeological sites in an area (information that municipalities may not have on hand). The OAS has noted in particular that some of the activities considered ‘low risk’ include municipal roads, bridge reconstructions, and all private sector infrastructure. I find these categories concerning. One of the most extraordinary archeological sites in my home county of Essex, Ontario was found during the widening of a bridge (Puce, AbHq-3), and several well-preserved sites are known throughout Essex County Ontario from replacing intersections with roundabouts. Would these sites have been considered “low risk” under the new guidelines? What protections will be in place to ensure that undiscovered sites are not destroyed? How will municipalities ensure they are meeting their obligations under the Ontario Heritage Act? What mechanisms are in place to protect the rights of First Nations in the development process? Is this government simply moving red tape and costs away from developers and onto First Nations? Many First Nations (see examples below) seem concerned that these policy changes would functionally result in less consultation. Is this government simply attempting to reduce consultation with First Nations on development projects (actions that fly in the face of United Nations Declaration on the Rights of Indigenous Peoples and the Truth and Reconciliation Committee’s Calls to Action)?

While I understand the desire to reduce bureaucracy, I am concerned that the ramifications of this have not been fully considered. If my degree in geological engineering, my classes in environmental science, or my work in archeology have taught me anything, it is that you can never be certain what a site holds until you check – especially when it comes to features (like archeological sites) that are often buried.

I understand that ostensibly these changes are intended to facilitate the development of more housing and infrastructure and thus “solve the housing crisis”. While I would like to see further action to solve the housing crisis, I do not believe that this action will be effective in its ostensible goal. There is no need for the wanton destruction of our natural heritage, farmland, and waterways to house people. In fact, I believe entirely the wrong approach has been taken to this crisis.

I understand that with the urgency of the crisis, housing stock is needed as fast as possible – but I do question whether everything reasonable has been done to ensure that existing housing stock is being used as effectively as possible. How many houses and apartments sit empty due to people not being able to afford them? Would higher minimum wages and rent control lead to these existing resources being used more effectively?

The additional housing stock that is needed should prioritize redeveloping brownfields with dense, walkable, mixed-use neighborhoods, and ensuring that the soil of said brownfield sites is adequately remediated (using strong environmental investigation beforehand to ensure there isn’t a public health concern). We should be making serious moves away from car dependency, incentivizing the construction of housing and nearby services instead of incentivizing speculators to build surface parking lots in city centers. Serious consideration should be given to modification of zoning and restrictions that at present functionally ban traditional rowhouse style construction and other ‘missing middle’ housing solutions like duplexes and quadplexes, or otherwise makes these types of developments unprofitable for developers. This could include reduction of minimum road setbacks and reduction of minimum square footage for housing, and a reduction to the minimum lot size for housing. For larger lots, to minimize environmental impacts stipulations could be made to incentivize ecological restoration on private property instead of vast swaths of monoculture lawn, or astroturf, this could include increasing the setbacks from bodies of water and buffers around natural areas. The number of greenfield sites for new development should be kept as low as possible. Farmland should be developed before natural areas. What environmental harm does have to occur should be mitigated to the greatest extent possible by promoting dense, walkable/bikeable, mixed use, transit accessible spaces, and promoting the restoration of ecosystems surrounding developments (ex. re-wilding corridors surrounding waterways etc.). In heavily deforested areas (ex. Counties of Essex/Chatham-Kent Ontario) this could even offer the option for reforestation/restoration during development.
There is no reason that more housing/infrastructure should come at unnecessary environmental or archeological costs.

There are other ways to loosen red tape around housing construction that do not need to facilitate urban sprawl, irresponsible environmental destruction, and an attempt to rob indigenous people and First Nations of their heritage.
It seems to me that at a time when we should be focused on public transportation, we are building highways. At a time when we should be focused on preserving and restoring the natural environment to build climate resiliency, we are bulldozing it. At a time when we should be working towards reconciliation with indigenous people, and a consent-based approach to development we are trying to reduce the role of First Nations in consultation. All of this to facilitate construction and supposedly “solve the housing crisis”. And yet what are we constructing? Sprawling, single family suburban homes on greenfield sites. This is not a housing solution. It does not serve us as Ontarians. If this government really wanted to solve the housing crisis they should be focused on well-funded, safe public housing. They should be focused on increasing housing density and filling the missing middle niche and rezoning for higher density. They should be building walkable mixed-use communities – communities you can comfortably live in, even if you don’t own a car. Instead, they are paving crucial habitat to build luxury homes.

In addition to the comments, I have left here myself, I would like to lend my support to the comments/suggestions/questions made by:

The Canadian Environmental Law Association:
https://ero.ontario.ca/public/public_uploads/2023-05/CELA%20ltr%20re%20…

The Chippewas of the Thames First Nation:
https://ero.ontario.ca/comment/86088#comment-86088

Mississaugas of the Credit First Nation
https://ero.ontario.ca/comment/31454

Ginoogaming First Nation
https://ero.ontario.ca/comment/84894#comment-84894

Sierra Club Canada
https://ero.ontario.ca/comment/84731#comment-84731