The Ontario Rivers Alliance (ORA) strongly disagrees with your response to our numerous concerns and recommendations when you assert that you “have concluded that temperature effects have been adequately assessed using field data, a nearby wastewater treatment plant’s effluent temperature data, and CORMIX – a state-of-the-art mixing model”. Your response totally ignored a key issue we raised that will impact on every aspect of stream health and Brook Trout survival, both over the short term and into the future.
Thank you again for your invitation to meet. We very much welcome the opportunity to discuss our concerns with you and your representatives. Prior to scheduling our meeting, it would be more productive if you could address the questions below in writing. Our expectation is that your answers to the questions below will provide a framework for our meeting. Details of our concerns are outlined in the updated “Briefing Notes”- attached.
The questions that follow do not represent all our questions and concerns; however, we would appreciate detailed answers to the following:
A highly controversial environmental assessment study under the Ontario Environmental Assessment Act was completed 23 years ago. It concluded that the project would cause adverse effects to fish habitat including severe stormwater and groundwater impacts. The environmental assessment did not evaluate the impacts on species at risk, migratory birds or climate change. This study has not been updated.
The provincial regulatory process is grossly inadequate.
Bill 229 is just the most recent in a long list of omnibus bills containing devastating amendments, exemptions and streamlining of key environmental policy and legislation designed to protect our environment and communities and provide the public and stakeholders with meaningful input. These government actions have created a deep erosion of public trust and confidence. It is unacceptable that it would mislead its citizens and bypass the norms by taking advantage of a world-wide health emergency to aggressively push their destructive agenda through.
Wetlands are among the most productive and diverse habitats on Earth. They provide incalculable benefits for communities, including flood mitigation, water filtration, carbon sequestration, wildlife habitat, wild foods and medicines, recreational opportunities and more. They are also of immense economic value. For example, wetlands can reduce the financial costs of floods by up to 38 percent; in the Great Lakes region the benefits provided by wetlands are worth 13 to 35 times more than the cost of protecting or restoring them; and in southern Ontario alone wetlands provide over $14 billion dollars in benefits every year.
Ontarians may have invented the Blue Box, but our current linear, make-use-dispose economy makes it impossible for recycling alone to solve our growing waste problem. Currently, less than seven per cent of Ontario’s waste is recycled through the Blue Box, and 1 the province sends over 8 million tonnes (70 per cent)2 of trash to landfills and incinerators every year.
The focus of the Strategy’s five goals should not just be on “Natural Resources”, but rather on the resilience of the province’s natural heritage landscape, using a watershed approach, in consideration of the cumulative effects of all past, present and future development on our air, land and water. Additionally, the scope of the Strategy must be broadened to encompass a review of all policies, guidelines and legislation that do not support the resiliency, conservation and protection of our streams, rivers, lakes and wetlands in this warming climate. Continue reading
While the focus of this submission is on urban stormwater in the draft plans and regulation, we have included observations and recommendations related to complementary freshwater and natural heritage issues and other policy needs and opportunities. Ontario needs to transform the way rain is managed on the urban landscape and one important step forward is changing our land use planning framework to address stormwater management.
The campaign engaged thousands of rural and urban residents, and highlighted the need to protect critical agricultural land and water resources inside and outside the provincial plans. It also gave birth to the Food & Water First movement that continues to press for land-use revisions. NDACT and Food & Water First believe the Co-ordinated Land Use Review is an opportunity to bolster existing protections within these plans and extend them beyond their boundaries. In this, the United Nations International Year of Soils, the Ontario government can lead the country by protecting its farmland and water resources in a bold initiative that would benefit future generations.