OFA submission regarding proposal to move to a project list approach under the Environmental Assessment Act

OFA commented on ERO 019-4219: Moving to a project list approach under the Environmental Assessment Act. Specifically, this proposal looks to move all transportation (highways and rail) and electricity transmission projects that had been proposed for a comprehensive Environmental Assessment (EA) to a streamlined EA process. The revised proposal also includes a new transition provision for waterfront projects.

OFA insists that any and all projects that have the potential to impact agricultural lands, activities, or systems, be required to complete a mandatory Agricultural Impact Assessment (AIA), regardless of the need to complete some form of environmental assessment or not. OFA encourages specific wording within the streamlined EA process to require proponents to complete an AIA for projects potentially impacting agriculture.

It remains essential that the public retains the ability to provide meaningful comment and input into project proposal based on the potential impact, and that an appeal process is also incorporated, and must allow relevant considerations that actually reflect the potential environmental impact of a project.

Rail and transportation projects risk bisecting farm communities and their design should mitigate impacts to agriculture. Electricity transmission projects impact agricultural lands. At a minimum, these infrastructure projects must avoid further depletion of specialty crop areas and/or Canada Land Inventory Class 1, 2, 3, and 4 lands. The siting of energy generation and waste management facilities also must encourage the use of existing underutilized industrial lands before considering the removal of Ontario’s dwindling supply of agricultural land inventory.

Previous related OFA submissions:

October 30, 2023 – OFA submission to the Ministry of the Environment, Conservation and Parks regarding the proposal to streamline environmental permissions for stormwater management under the Environmental Activity and Sector Registry (ERO # 019-6928)

October 30, 2023 – OFA submission to the Ministry of the Environment, Conservation and Parks regarding the Proposal to explore changes to streamline the permit-by-rule framework (ERO # 019-6951)

March 24, 2023 – Waiving or altering the 30-day Waiting Period for Class-Environmental Assessment Projects (ERO # 019-6516 / #23-MECP004)

February 23, 2022 – OFA submission to the Ministry of Environment, Conservation and Parks regarding the Environmental Assessment Act (ERO # 019-4867)

January 25, 2022 – OFA submission to the Environmental Assessment Modernization Branch regarding the Environmental Assessment Act (ERO # 019-4219 & ERO # 019-4428)

November 19, 2021 – OFA submission to the Ministry of Environment, Conservation and Parks regarding a class environmental assessment process (ERO # 019-4189)

September 1, 2021 – OFA submission to the Ministry of the Environment, Conservation and Parks regarding transmission lines (ERO # 019-3917)

November 9, 2020 – OFA submission regarding proposed project list for comprehensive environmental assessments under the Environmental Assessment Act (ERO # 019-2377)

August 14, 2020 – OFA submission regarding proposed Environmental Assessment exemptions for GTA West Transportation Corridor project (ERO # 019-1882)

August 14, 2020 – OFA submission regarding proposed Environmental Assessment exemptions for various general projects (ERO # 019-1883)

April 30, 2020 – OFA submission regarding proposed earlier access to land to conduct preliminary environmental studies for electricity transmission projects (ERO # 019-1371)