Good evening, and thank you for inviting me to testify to this important bill.

I appeared before this committee six years ago, I think, when it first began its review of CEPA, so I'm very pleased to be here to speak to Bill S‑5 after all of this work. It has not been quite as long as Lisa and her maternity leave.

My colleagues have already addressed several of our joint recommendations of strengthening the bill, so I don't want to repeat those, given my limited time, but I do press upon the committee to build upon the amendments made by the Senate and the wisdom of the Senate to uphold things like the watch-list and to strengthen the recognition of the right to help the environment, including the framework and the recognition, as Lisa spoke to.

I'm going to speak specifically to amendments we're seeking with respect to timelines and ensuring accountability. My thunder got stolen a little bit by some of the questions, but I'm going to go ahead anyways.

Specifically, we're seeking amendments to three areas through clauses within the bill with respect to timelines: the planning in clause 19; the toxic substance assessments in clause 21; and the risk management of toxic substance in clause 22. These clauses are where the rubber hits the road. Let me explain.

Priority planning, which Scott just mentioned, is under clause 19. It's very similar to the chemicals management plan, but there is no requirement within the priority planning section to set timelines or update the plan. We are recommending amendments to require timelines and plan updates to ensure that the plan remains current and is updated at least every five years.

Delays in the assessment and management of toxic substance equal delays in the implementation of many of the important provisions my colleague spoke to that strengthen the bill, such as the recognition of the right to a healthy environment, consideration of vulnerable populations and cumulative affects. Waiting several years for an assessment to be finalized after submitting comments is unacceptable. I am in that place right now on several comments I have submitted, five years on some of them.

It only puts the environment and human health at risk, because action delayed is action denied, and it also undermines public participation. To prevent multiple-year delays, we recommend a one-year time limit between the proposed and final risk assessments, but we also allow for an inclusion of an extension if additional data or additional studies are required.

Lengthy delays can also occur in the implementation of risk management plans, which typically involve several measures. The CEPA clock, as it is locally known, refers to timelines written within CEPA requiring one risk management regulation or instrument to be proposed within two years and finalized within 18 months. There is no such timeline for subsequent regulation instruments in the risk management plan, and it's very common for there to be multiple ones, and this leads to years and years of delay.

Bill S‑5 requires a minister to publish a statement respecting the development of subsequent regulations and instruments that specify, to the extent possible, an estimated time frame, but to provide greater certainty, we recommend that Bill S‑5 be strengthened to require timelines for every planned risk management regulation and instrument, and those timelines, when possible, should correspond to the two-year CEPA clock requirement.

I think I'm out of time.

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