Tag Archives: comments

Making Regulations under Subsection 36(5.2) of the Fisheries Act – ORA Submission

By Linda Heron on Saturday, March 22nd, 2014
Posted in Fisheries Act, ORA Submissions, Regulatory, Regulatory Submissions, Rivers at Risk

Lake Sturgeon

Excerpt:
“ORA respectfully offer our comments as prescribed in the Canada Gazette as listed above.

The proposed Regulations Establishing Conditions for Making Regulations under Subsection 36(5.2) of the Fisheries Act (Regulation) fundamentally alters the intent and enforceability of one of Canada’s most important federal laws. There has also been no meaningful, transparent and open process, or effort made to consult with the general public and stakeholders. As a result of the Government of Canada’s failure to consult with Canadians and those with expertise on this issue, both the Regulation and the supporting Regulatory Impact Analysis Statement are seriously flawed.

The sweeping changes to the Fisheries Act which were introduced in 2012 have weakened one of Canada’s most important and effective water and fisheries protection laws. This has provided opportunities for government to exempt industrial and resource development from federal rules.

The proposed Regulation lacks clarity and consistency, and amounts to an abdication of its federal responsibly for protecting fish, habitat and waterways in Canada. The contradictory regulatory scheme would make it impossible for any government regulator to fulfill the purpose of the Act, which is to “provide for the sustainability and ongoing productivity of commercial, recreational and Aboriginal fisheries”….. Continue reading →

EBR 011-7696 – Proposed Approaches to the Implementation of the Endangered Species Act – Nottawasaga Steelheaders

By Linda Heron on Tuesday, February 26th, 2013
Posted in Endangered Species Act, Environmental Registry, ORA Submissions, Regulatory Submissions, Species at Risk

February 25th , 2013

Krista Adams
Senior Permits & Agreements Specialist
Ministry of Natural Resources
Policy Division
Species at Risk Branch
Permits and Agreements Section
300 Water Street , Floor 2
Peterborough Ontario  K9J8M5
Phone: (416) 326-1672
Fax: (705) 755-5483

Dear Ms Adams:

Re: EBR-011-7696 Proposed Approaches to the Implementation of the Endangered Species Act

The Nottawasaga Steelheaders is a volunteer group of anglers, conservationists and concerned residents who have been working in concert with The Nottawasaga Valley Conservation Authority, Ministry of Natural Resources and various communities to improve, rehabilitate and preserve the integrity of the Nottawasaga River watershed over the past twenty years years. Over this time we have committed tens of thousands of man-hours and hundreds of thousands of dollar in many beneficial programs. These have included the removable of numerous barriers to fish migration, undertaken countless garbage pick-ups, tree plantings, stream bank stabilizations, cold water delivery projects, spawning ground improvements and commitments to ensure the survival of wild species in this watershed such wild steelhead. Our organization was the first of its kind to undertake a comprehensive study to make uncover the genetic diversity of migratory rainbow trout (Oncorhynchus mykiss). Eighteen (18) distinct strains were found, each with its own set of co-adaptive gene complexes established over a hundred years. Recent studies including those at the University of Western Ontario have determined that that 35-40% of migratory Chinook salmon are of Nottawasaga River origin! This speaks highly of complex and delicate interdependent biodiversity which has taken hundreds if not thousands of years to establish in this watershed. This biodiversity and its interdependence in this watershed and across Ontario is something we know little about and should not be putting at risk with hasty decisions and without the input of Ontarians. It is OUR province with OUR resources and WE are responsible…not a few. Continue reading →

EBR 011-7696 – Proposed Approaches to the Implementation of the Endangered Species Act – ORA Comments

By Linda Heron on Monday, February 25th, 2013
Posted in Endangered Species Act, Environmental Registry, ORA Submissions, Regulatory Submissions, Species at Risk

Excerpt:

“While there are some good recommendations in these proposed amendments to the Endangered Species Act (ESA), many are worded in language that is far too vague and open-ended, and others are simply unacceptable. ORA is very concerned that this will significantly weaken the hard-fought protection already afforded to our species at risk and their habitats, and is inconsistent with the ESA.  Further, many of the proposed approaches appear to be in violation of the EBR in that there is no provision for public and First Nation consultation or transparency.

MNR’s Mission and Promise to Ontarians:

MNR’s Statement of Environmental Values (SEV) and strategic direction ensure sustainable development, protect and restore biodiversity, and must be the guiding principles in all decisions with regard to streamlining, modernization and economic development.  The values set out in the SEV must be adhered to in the contemplation of any existing or planned activities where endangered species or habitat protection is in question.  The SEV clearly states, “The Ministry’s mission is to manage Ontario’s natural resources in an ecologically sustainable way to ensure that they are available for the enjoyment and use of future generations.  The Ministry is committed to the conservation of biodiversity and the use of natural resources in a sustainable manner.”

Streamlining and modernization of the Ministry of Natural Resources (MNR) is a good idea, but only if environmental, ecological, and species at risk protection is not threatened or diminished.  All the streamlining, modernization and framework EBR postings preceding this one promised to uphold environmental and ecological values; however, this posting demonstrates that this promise is not being kept. This proposal clearly reflects a development at all costs approach taken by this administration.” Continue reading →