An open letter to The Hon. John Wilkinson, Minister of Environment and The Hon. Linda Jeffrey, Minister of Natural Resources
[Letter written by County resident H. G. Garand]
Ontario’s Ministry of Environment (MOE) and Ministry of Natural Resources (MNR) have a long record of protecting the health of citizens and the natural environment, and overseeing wise use of public land. But I suggest that the Green Energy and Green Economy Act is distorting the mandate of both ministries.
Consider this strong evidence:
- The Renewable Energy Approval (REA) process effectively limits ministerial responsibility to a bureaucratic review of a wind developer’s application because it relies on reports prepared by consultants hired by developers, not independent experts employed by the ministries.
- Permits to “kill, harm, and harass” threatened and endangered species, protected under federal and provincial legislation, are approved on the basis of these consulting reports and the developer’s promised mitigations.
- Ministry approvals are given for wind projects on Crown land and within Important Bird Areas, like Wolfe Island and Prince Edward County’s South Shore. (These decisions conflict directly with the wind industry’s own “best practices” standard, as described by the Great Lakes Wind Collaborative, which discourages development in IBAs and bird migration corridors.)
- The REA process restricts the filing of complex appeals to a 15-day period following project approval, places the burden of proof on citizens, and requires the absurdly high tests of “serious harm” to human health and “serious and irreversible harm” to the environment.
- The REA process has compelled citizens to participate in sham consultations with developers, submit futile comments to the ministries, and undertake expensive litigation both in Ontario’s Divisional Court and before an Environmental Review Tribunal.
The problems with MOE and MNR are not unique. Political scientists use the term regulatory capture when government agencies serve the interests of those they are supposed to regulate. The MOE and MNR call private wind developers “clients” and “proponents”—these very words place public-minded citizens outside the approval process. Wind developers have become partners with the government, and we are assigned the role of adversary.
The ministries of Environment and Natural Resources, however, were not established to benefit private businesses. They must return to carrying out their democratic responsibilities to protect the well-being of all Ontario residents and the natural environment, and to provide stewardship of Crown lands.
To do otherwise, Minister Wilkinson and Minister Jeffrey, is a betrayal of public trust.
H. G. Garand