The posting is particularly…

The posting is particularly vague and the requirement to view supporting materials in person is not in line with transparent governance. As a member of the public I would at least like to have seen a summary of the main findings that support this work available online. A summary of how other provinces regulate similar aspects would also be interesting.

In my opinion, the proposed changes under the Lake and Rivers Improvement Act
45(1) subsection 3(2) bi) are not prescriptive and do not state any of the triggers that would require the owner of a dam to have a plan for the monitoring and reporting of impacts. It seems that there would be cases where a plan is not required. Are dams simply not regulated at all if a plan is not required?

The impacts listed also do not seem to allow for the inclusion of impacts outside of fish, wildlife and other natural resources. What about protection to the shoreline to protect erosion and flooding related to operation of the dam?

Also, there is no definition of what the circumstances that must be considered in the plan are: is it normal operating conditions or does it include those experienced during extremes - emergencies, flooding, drought, etc? The plan should include the full range of conditions and plan for future uncertainty, particularly with regards to changing climate conditions.

Do these plans ensure protection of the ecosystem during critical periods (drought) and during critical phases of development (spawning)? This should be included in plans to ensure that ecosystems are protected when they need to be most. The way the regulation is written seems to indicate that plans are optional. Where is it written that energy needs trump those of the natural ecosystem or even riparian land owners, particularly during extreme conditions, when the ecosystem may already be stressed?

In my opinion, plans should be mandatory and should be updated regularly to adapt to changing climate conditions as well as changing ecosystems and changing shoreline development.