1. While FODE understands and endorses the concept of Smart Growth, we perceive a bias in Ontario, not as prevalent in other jurisdictions, in favour of population and economic growth, aided by improved transportation and infrastructure planning as espoused in phases such as "we need to ensure that infrastructure is in place to support growth before development happens", rather than Sustainable Development based on natural heritage protection. FODE respectfully points out to the Panel that that infrastructure is development, and that once it is in place the decision to develop natural areas has already been made.
   
   Rather than this approach of 'business as usual', FODE suggests the panel recognize that the priority in Ontario must be the clear articulation of the primacy of the natural environment and a framework for sustainable development. FODE also suggests the panel take a strong position that the primacy of the environment as the basis of public health and a sustainable economy must be enshrined in provincial legislation, policy directives, the administration of the regulatory framework, appropriate ecological and community health monitoring, enforcement, and the improved articulation of the roles and responsibilities of agencies involved in these efforts.
   
   
2. While FODE sees encouraging efforts being made in Ontario toward source protection, natural heritage inventories and strategic planning, and watershed-based planning, there are incomplete, unequal, and costly inefficiencies and gaps in natural heritage protection and inter-agency co-ordination.
   
   On a broad scale, there is no over-arching requirement for or a province-wide standard for GIS-based planning tools. It would be helpful if the Panel could recommend, for example, where and how GIS planning tools could become the basis of natural heritage protection, inter-agency co-operation, and public consultation. On a finer scale, FODE encourages the Panel to address all and any accepted norms that might mitigate against the development of significant progress toward sustainable development, and offers the following four specifics for your consideration, as follows:
   
   
   • The OMB must be re-constituted in a manner that it become any agency of sustainability, more democratic, more financially accessible to the community, and more accountable than as at present;
     
     
   • The Ministry of Transportation must provide improved access to information and public consultation for long-range transportation planning, including postings to the EBR, as recommended in the 2002 report of the Environmental Commissioner of Ontario (pg 24);
     
     
   • Conservation Authorities should be given greater regulatory responsibilities, financial and political independence from the municipal tier, and greater financial resources to protect local natural features, in co-operation with MNR and other provincial agencies as required; and,
     
     
   • ORC should not have to obtain "full market value" for lands deemed surplus by the province, as full market value means, by definition, solely the development value of those lands;
     

The Regional Framework

3. Within Central Ontario, FODE hopes that the Panel will recommend an agency or series of bodies to replace the role of the abandoned GTSB with respect to reviewing municipal plans vis-vis sustainability in general and to encourage policies and co-ordinated action on specific issues such as green corridors, transportation/transit planning, and other regional issues.
   
   In addition, and further to our recommendation within the submission from the Don Watershed Regeneration Council, FODE suggests the Panel recommend that municipalities and regional municipalities be mandated to develop policies and plans to address eco-efficiency, or industrial ecology as it is known in Europe, to be applied to new industrial/commercial parks. As articulated in the award-winning Eco-efficiency Resource Manual published by The Economic Developers Council of Ontario (EDCO), industrial/commercial developments that include co-generation, water cascading and material cycling enhance both environmental conservation and economic competitiveness and send a strong signal about the commitment to sustainability.

4. Clearly, the predominant issues facing the Panel - population growth, sprawl, natural heritage protection, agricultural lands protection, and transportation planning - are greenfield issues. FODE is concerned that a pre-occupation with mitigating the impacts of greenfield development may result in a lack of consideration for the impacts that urban intensification may have on existing urban areas: suffocating densities, overwhelmed infrastructure, over-stressed greenspace and natural heritage features, locating hard infrastructure in valley corridors, and increases in pollution, noise, and urban heat island effects. All of these impacts could make life less enjoyable for human residents and the existing natural landscape of cities. In short, we consider that using urban intensification as a strategy to limit sprawl should not result in the loss of critically important and sensitive natural areas that exist within urban areas; and,
   
   
5. FODE is concerned not just about the lack of community involvement at the municipal level to creating smarter communities, as articulated in the submission from the Federation of Ontario Naturalists, but about the lack of a standardized protocol for communication between municipalities and their citizens. We suggest that the Panel consider commenting on the need for a standardized process, time-lines, access-to-information, and guarantees for meaningful dialogue between from municipalities to their citizens across the province. We also suggest a municipal Environmental Registry for truly large urban areas such as Toronto as a means of ensuring informed citizen participation in the development of our communities.