Thank you for this…

Thank you for this opportunity to comment on The Canada-Ontario Draft Action Plan - Partnering in Phosphorus Control: Achieving Phosphorus Reductions in Lake Erie from Canadian Sources.

Comments offered below are based on review of the "Draft Action Plan" and participation in the Lake Erie Nutrients Working Group (LENWG). Initially, I have provided four general comments, and thereafter I have tried to briefly respond to the seven (7) specific questions provided with the EBR posting.

1. As noted at the LENWG meeting held on April 18, my greatest concern is that the "Draft Action Plan" does not provide key components of a real action plan.
In order to be effective, action plans should include the following four components: detailed specific/measurable actions to reduce phosphorus, clear accountability for co-ordination and implementation, clear/realistic schedules and costs/funding sources.
Unfortunately, this "Draft Action Plan" does not adequately address any of these essential components. Therefor the document requires a great deal of work in a relatively short period of time in order to effectively respond to the 2012 GLWQA and the followup agreements between the parties to produce Action Plans by February 2018, which will result in a 40% load reduction in phosphorus entering Lake Erie by 2025 and an aspirational goal of 20% reduction by 2020.

2. The focus of the document should be to reduce phosphorus loadings. Unfortunately, the "Draft Action Plan" does not reflect this intended focus. The Section of the document - Category A: Reduce Phosphorus Loadings is almost an afterthought in the document. It is less than five pages in length and does not respond to any of key elements of an Action Plan noted above.
By comparison, those sections of the "Draft Action Plan" that the Federal and Provincial Governments responsible for producing the document are most familiar; Categories B,C,D,E, which make up the bulk of this Section of the document, will not have short term impact on Phosphorus Reduction. The obvious exception is Legislation, which could certainly benefit from various positive, helpful and often incentive based activities. While these sections/Categories are very important, I suggest that real collaborative partnership initiatives engaging all beneficial/responsible partners and providing appropriate incentives are essential to achieving desired results and timeframes.
Since the priority areas identified in the "Draft Action Plan" are essentially five - seven "watersheds", it is strongly recommended that the watershed management agencies namely CONSERVATION AUTHORITIES, which have proven experience with developing and implementing effective/collaborative action plans, be asked to coordinate the production of real Action Plans for phosphorus reduction. These should be produced in collaboration with senior levels of government and other key partners and must be produced within the next six months in order to obtain necessary collaboration, landowner partnerships and funding,
to begin implementation in 2018.

3. Priority Areas as identified; Thames, Grand, "Leamington area", Kettle, Big Otter, Grand watersheds, are primarily based on quantity of phosphorus at the River outlets to Lake Erie. As with "watersheds around Leamington", other high phosphorus concentration watersheds, especially in the Western Basin should be included in Priority Areas. This would recognize the key relationships between these high concentration watersheds and the nearshore water quality of the Western Basin which is most dramatically effected in terms of tourism, property values, human health threats. All high concentration watersheds within the Western
Basin should be included as Priority Areas for purposes of immediate phosphorus reduction plans and activities.

4. Budgets, which include both costs and sources of funding should be clearly addressed in an "Action Plan". Neither estimated costs or sources of funding are identified. In part this is because of the lack of detailed actions to reduce phosphorus entering Lake Erie. Additionally, I am concerned that that the lack of effective actions is as a result of the Parties limiting Action Plans based on existing Federal and Provincial Budgets for phosphorus reduction. Obviously, new funding is required, which would logically be approved based on sound and defensible Actions Plans.
As in the US, where over $300 million new Federal dollars (through GLRI) plus significant other Federal and State funds have be committed for meaningful multi year phosphorus reduction initiatives, I believe that we as Ontarians and Canadians should not shy away from our responsibilities. We should not hide behind the fact that total contributions from the US are very large in comparison to Canadian contributions. We should lead by example and address our high contribution and high concentration phosphorus problems in Lake Erie and especially the Western basin. Using the historical 10% guideline, Canada/Ontario as well as estimated capacity to implement effective cost reduction programs, new Fed/Prov investments of at least $25-30 million per year for a minimum of ten to twenty years, in order to significantly reduce our phosphorus loading into Lake Erie.

The following brief summary comments are provided in response to the seven (7) questions noted on the EBR notice.

1. General feedback and specific recommendations are noted in the above four points.

2. I am speaking as a member of the public, so I cannot speak for any organizations. I would however specifically suggest that the directly effected Conservation Authorities could contribute significantly in order to develop and implement meaningful collaborative Action Plans. See 2 above.

3. In addition to Conservation Authorities, Regional and Municipal planning bodies could have significant longer term impacts through planning policies and documents. Leading progressive regional and municipal planning bodies should be engaged to work with Federal and Provincial governments to develop effective planning tools to add to shorter term collaborative actions to reduce harmful phosphorus from entering Lake Erie.

4. Comments noted in 1, 2, 3, and 4 above all address this question.

5. Many successful incentive and cross compliance programs have been developed and planned in the past (both in Canada and the US). These can be used to assist in the development of meaningful action plans as noted in comments 1-4 above. As noted, Conservation Authorities working in co-operation with directly effected Federal and Provincial Ministries can build on these past programs to quickly develop an effective Action Plan which of course will be subject to ongoing adaptive management.

6. Tracking progress, adaptive management, and ongoing science based monitoring are crucial ongoing activities. Specifics can be developed collaboratively by Federal and Provincial governments in partnership with Conservation Authorities and other significant partners in order to ensure streamlined and appropriate monitoring, reporting and adaptive management actions.

7. Public awareness is very important as noted in Category D of the "Draft Action Plan". Local watershed organizations (Conservation Authorities) can be great partners in informing and engaging the public, with corresponding awareness and buy in from all levels of government.

Thank you again for this opportunity to comment on this EBR posting.

P.S. Please disregard the partially completed comments which were inadvertently submitted earlier today.

[Original Comment ID: 209301]