The undersigned applaud the Ontario Ministry of Environment and Climate Change (MOECC) for its initiative in developing runoff volume control targets to reduce urban stormwater runoff and associated water pollution. We look forward to working with the Ministry on both the development and implementation of a Low Impact Development Stormwater Management Guidance Manual (which the above-noted Registry notice indicates will be drafted and consulted upon at a later date) and the further evolution of rainwater management policy and practice (both urban and rural) in Ontario. Our comments are directed only at the consultant reports attached to the Registry notice.
ORA feels this proposed Bait Policy falls short of the Ministry of Natural Resources and Forestry’s (MNRF) goal of finding options that minimize the ecological risks associated with the use, movement and harvest of baitfish, while also reducing the complexity of current management regimes and increasing business certainty to the bait industry.
Stream-side forests are crucial to the protection and enhancement of freshwater resources. They are extremely complex ecosystems that provide useful ecosystem services such as mitigating or controlling non-point-source pollution as well as providing optimum food and habitat for stream communities. As a component of an integrated management system including nutrient management and sediment and erosion control practices, stream-side forests have important effects on water quality. They remove excess nutrients, pollutants and sediments from surface runoff and shallow groundwater and they also shade streams to optimize light and temperature conditions and provide dissolved and particulate organic food for aquatic plants and animals.
The Chair of the Ontario Rivers Alliance presented to the Expert Panel on the Review of the Environmental Assessment Process, on Thursday, 3 November 2016, in Sudbury, and also made a detailed written submission below:
Our experience in Ontario is that the Department of Fisheries and Oceans defer to the will of the provincial regulators, which should be the other way around. We need our federal government to set a high standard that will be followed by the provincial players. Both the federal and provincial governments have gone through an intensive streamlining process which has undermined confidence in their ability to effectively review applications and Environmental Reports, let alone adequately monitor and enforce the conditions of approvals. Consequently, environmental protections have become very lacking in these streamlined and broken processes.
The hydro lobby is very powerful and deep pocketed, and has gone to great lengths to undermine and debunk studies that clearly demonstrate the significant contribution that reservoirs make to total world GHG emissions.[i] Shifts in water temperatures, or the availability of fresh water due to climate change could lead to reductions in electricity production capacity in more than two thirds of the world’s power plants between 2040 and 2069, said a study from an Austrian research centre. In fact, Keywan Riahi, Director of the Energy Program at the International Institute for Applied Systems Analysis says, “power plants are not only causing climate change, but they might also be affected in major ways by climate”.[ii]
[ii] Power generation could take a big hit from climate change. CBC News, Technology & Science, Thomas Reuters, Posted 4 January 2016.
Sustainable management of natural resources such as forests, soils, water, wetlands and fisheries are at the heart of conservation, and these resources are the building blocks for green cities, energy production, agriculture, water supply and sanitation systems. Relatively stable ecosystems and species dynamics are indicative of sustainable resource use, and conservation science has been broadening this knowledge to buffer ecosystems and species from negative climate change impacts.
Ontario’s fisheries resources are an important part of its biodiversity, and contribute to the province’s economic, social, and environmental well-being. This document, Ontario’s Provincial Fish Strategy: Fish for the Future, sets out a practical and strategic framework for managing Ontario’s fisheries resources from 2015 forward.
ORA’s ongoing work towards improving government policy as it relates to healthy rivers:
The City of Sudbury recently passed a unanimous Council Motion to implement a Sewage Bypass Alert, whereby the public will be informed in real time when there is a sewage bypass or spill at any of their 13 wastewater treatment facilities. Sewage bypasses are becoming more frequent due to the extreme rain events associated with climate change, and this contaminated freshwater could pose a risk to residents who take their drinking water or swim downstream of these facilities. Ontario Rivers Alliance also made a request to the Ministry of Environment and Climate Change, in October of 2014, to incorporate this important public safety measure into policy throughout the province. All Sewage Bypass Alerts will be posted on the City of Greater Sudbury website here.
There are numerous Waste Water Treatment Facilities (WWTF) across the province releasing treated, untreated and partially treated effluent into streams and rivers that run through large and small communities that also rely on river water for their public and private drinking water and general household uses. Increasing incidences of extreme rain events are making overflow and bypass of sewage a common and necessary strategy for many WWTF’s in Ontario. ORA understand that in the short-term this is done in order to avoid back-ups into their treatment facilities as well as individual residences; however, in the long-term there must be a province-wide strategy to avoid untreated and partially treated releases of sewage effluent into the environment.
For example, in the Greater City of Sudbury, there are nine wastewater treatment facilities releasing treated, partially treated and untreated effluent into the Vermilion River watershed. On 13 and 14 April, 262,999 m3, and again on 15 May, 59,778 m3, of partially treated sewage was released into the Vermilion River and its connecting lakes. During 2013, 427,235 m3 of partially treated sewage was released through bypass and overflow from one Sudbury facility alone. Many residences rely on the Vermilion River for their drinking water and general household water usage, and public health and safety is placed at risk if untreated and/or partially treated sewage is present in their private water intakes or children and adults are swimming in affected river water. There must be a standardized policy in place that sets out when and how the public is to be alerted when their water supply has been compromised.
ORA is confident that this is not an isolated problem, as very few WWTF were made to handle the extreme rain events that are becoming more and more prevalent with the effects of Climate Change. The cumulative effects of numerous bypass and overflow events on the creeks and rivers feeding the Great Lakes also contribute to the prevalence of Cyanobacteria blooms on area lakes, as well as the Great Lakes.
The City of Kingston has a great model for other municipalities to follow through their Sewage Alert System and on-line Bypass Log which reports bypass and overflow incidents on their website. Facebook and Twitter communications should also be utilized in an effective strategy.
The bottom line is that local downstream residents need to be notified at the earliest possible moment of any potential risk to their water source and/or their health and safety. When an overflow or bypass is reported to the MOECC and local health unit, at the same time the public must also be notified through an alert so that precautions can be taken.
The City of Sudbury is now in the process of implementing this policy; however, we are awaiting a decision by MOECC on whether this policy will be implemented throughout all of Ontario.
The Ministry of Natural Resources and Forestry (MNRF) is conducting the provincial bait policy review to determine how the ecological risks associated with the movement and use of bait (i.e., baitfish and leeches) can be minimized to help maintain healthy fisheries and aquatic ecosystems, while reducing the complexity of current management regimes and providing business certainty to the bait industry. ORA made submissions on two EBR postings.