Commission on the Reform of Ontario's Public Services

Environment and Natural Resources
Responsibility for protecting the province’s environmental and natural heritage falls to the
Ministries of the Environment (MOE) and of Natural Resources (MNR). At a time when fiscal
restraint will further restrict their supply of funds, it seems certain that demand for oversight
of environmental approvals, compliance and natural resource stewardship will rise.
Our recommendations are aimed at more effective and efficient operations.
Full Cost Recovery and User Pay: Full cost recovery is not in effect for all of the
government’s environmental programs, and existing fees do not keep pace with the rising
costs of program delivery; where possible, the costs of those services should be shifted
to the beneficiary. The Water Charges initiative should be expanded beyond high users to
medium- and low-consumption industries and put on a full user-pay basis. The Renewable
Energy Approval, which consolidates the range of approvals needed for renewable energy
projects while recovering about 90 per cent of its direct operating costs, is a good example
of a modern approval. The Drive Clean program fully recovers its costs.
Jurisdictional Crowding: Federal, provincial and municipal governments all set
environmental rules, with some overlap. Even within the Ontario government, regulations are
set by several ministries. This results in inefficient use of government resources and creates
uncertainty and confusion for industry, developers and citizens. The government should work
to rationalize roles and responsibilities that are shared by different governments.
The Approvals Process: Growth in natural resource extraction and energy will put pressure
on provincial environmental approvals and compliance systems. The MOE recently launched a
significant transformation of the environmental approvals process; it enhances environmental
protection with a greater focus on risk, responds to the needs of business, takes advantage
of current technology and addresses the increasing complexity of current approvals. Further
work should be done, especially in natural resource extraction.
The Environmental Assessment (EA) Process: Many projects require both provincial
and federal EA requirements. The 2004 Canada–Ontario Agreement on Environmental
Assessment Co-operation is under review, but removing duplication may require new
legislation and both governments are reluctant to give up decision-making authority.
Some projects need environmental and land use approvals in addition to an EA, though
proponents are often unaware of this when an EA process begins. The government
should further streamline the process.
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