On behalf of the 58 undersigned groups, we are providing these comments on the draft Great Lakes Binational Strategy for Mercury Risk Management (April 2018, hereafter “Mercury Strategy”). Note that these comments expand on comments submitted by Canadian Environmental Law Association, National Wildlife Federation and Toxics Free Great Lakes Network on this matter on May 25, 2018.
ORA has fully participated in the Canadian Environmental Assessment Process review and was very hopeful with this government’s promise to “rebuild public trust, protect the environment, advance reconciliation with Indigenous peoples, and ensure good projects get built…” While there are some encouraging components, such as requiring the Minister and Cabinet to provide reasons for environmental approvals and creating a single agency to conduct assessments, it is extremely disappointing that the proposed Impact Assessment Act (IAA) further undermines credibility and trust as well as its ability to protect the environment. It is a very flawed process when after going through years of application review and examination of science-based evidence, that the Minister could make a purely political decision and prioritize economic considerations over meeting climate commitments – as it is doing now with the Trans Mountain Pipeline.
The proposed binational strategy on PBDEs outlines limited actions to address PBDEs levels in the Great Lakes beyond the measures that have already been committed on PBDEs by each country. It is also important that U.S. and Canada outline expected reduction targets for PBDEs in contrast to the current approach to outline intended measures. Without targets the ability to indicate successful and effective actions on PBDEs would be difficult to achieve.
ORA understands the pressure municipalities are under when communities rally to maintain or rebuild their beloved mill ponds. However, it is up to all authorities and municipalities to take a leadership role that places public safety and landscape scale ecological integrity above local individual or group interests.
We at the ORA fully support strengthening the Canadian Environmental Protection Act (CEPA) through the list of 87 recommendations made by The Standing Committee on Environment and Sustainable Development in its Eighth Report, tabled on 15 June 2017. The ORA supports the right to a healthy environment. Healthy communities, a healthy economy and a healthy environment are essential to Canada’s sustainability. A review of the Act presents the federal government with a golden opportunity to improve the health and well-being of all people in Canada.
On 23 – 24 June of 2017, the upstream Gorrie Dam failed and the Howson Dam was at capacity during an extreme rain event and flood when 175 mm of rain fell in just 7 hours, placing more than 150 property owners at risk and resulting in an estimated $11-million in damages in the Town of Harriston. This severe rain event broke previous records by approximately 40% and was the second highest flow on the North Maitland in the 48 years of record. Fortunately, no one was killed; however, it could have been much worse, as in October of 2015, when a South Carolina flood breached 18 dams, and resulted in 16 deaths.
It has come to ORA’s attention that the Gorrie Dam on the North Maitland River failed as a result of flooding during an extreme rain event on 23 – 24 June 2017, and that Maitland Conservation is considering its options. We understand that no one is more aware of the extremes of a volatile and changing climate than Conservation Authorities, and yours in particular; and we understand the pressure that Conservation Authorities and municipalities are under when communities rally to maintain their coveted mill ponds. However, it is up to all authorities to take a leadership role that places public safety and landscape scale ecological integrity above local individual or group interests.
Drought conditions could place additional stress on riverine ecosystems, while more extreme rainfall will heighten the risk of dam failures (18 dams were breached in a South Carolina flood in October of 2015) with rapid release of high volumes of water. There have also been recent dam failures right here in Ontario – the Gorrie Dam failure last year in Wingham was the most recent, putting more than 150 property owners at risk.