Response to EBR 101-8986 All…

Response to EBR 101-8986 All quotations taken from the EBR 101-8986 are in quotation marks. Each quotation from EBR 101-8986 is followed by my comments. The proposed Phosphorus Reduction Strategy adopts a watershed approach to phosphorus reduction, with the goal of achieving proportional reductions from each major source of phosphorus, including sewage treatment plants (STPs), storm water runoff from urban areas, runoff from rural and agricultural areas, agricultural polders such as the Holland Marsh, private septic systems located close to the lake and atmospheric sources of phosphorus such as dust and windblown erosion. I believe that the idea of proportional reduction is a concept that is easy to understand and means that all sources of phosphorus pollution have to share in the cleanup of Lake Simcoe. However, I am sure that you will get howls of protest from the operators of the Sewage Treatment Plants (STP). However, I believe that the STPs must do their share to help reduce the amount of phosphorus flowing into the lake. Purpose of Policy The key objective of the proposed Phosphorus Reduction Strategy is to reduce phosphorous loadings to where we will achieve a dissolved oxygen level in Lake Simcoe of 7 milligrams per litre (mg/L), a level that current scientific research indicates will support Lake Simcoe's long-term ecological health. Achieving this objective requires reducing total phosphorus loading in the watershed to 44 tonnes per year (T/yr), from the current total annual loading of 72 T/yr—which means annual reductions of about 40 percent. Achieving this aggressive goal will be challenging and will take several decades. I believe that the annual reductions are not 40 percent. The annual reduction required to reach a target of 44 tonnes after 30 years would require a reduction of only 1.5% per year. I do not believe that 1.5% per year is an aggressive goal; in fact, it would appear to be a modest goal. New developments that are already approved for the Lake Simcoe area will likely push annual phosphorus loading higher over the next several years”. I am bitterly disappointed that the Ministry is going to allow phosphorus loadings to increase over the next several years. Why are developers of new housing and other developments not being encouraged to undertake best practices management to reduce the amount of phosphorus loadings into the lake by the new developments? Are there not some incentives that could be given to the developers? In many cases, it is not expensive or onerous for developers to conform to the new regulations contained in the Lake Simcoe Protection Plan. I am aware of the Transitional Regulations but maybe provincial funds could be released to assist the developers meet the new regulations. Can the Ministry not be more creative? I am on the Board of directors of the Lake Simcoe Conservation Foundation. We are raising money for the Lake Simcoe Region Conservation Authority so they can undertake remedial projects that will reduce the amount of phosphorus flowing into the lake. At the same time the Ministry is going to allow new developments to further pollute Lake Simcoe. The Ministry is making the cleanup of Lake Simcoe an uphill battle. Other Information For each major source, specific reduction goals and potential reduction opportunities are identified that will work towards achieving the whole-lake goal of 44 T/yr. However, current projections indicate that, with today's technology, annual phosphorus loadings would be reduced to about 58 T/yr by 2045. I do not understand why today's technology cannot make a reduction of only1.5% per year in the amount of phosphorus released into the lake. We have the technology to make the required annual reduction; what are lacking are funds and the political will. Policy 4.24 SA (Chapter 4 Water Quality) Policy 4.24 would be revoked and replaced with the following: I do not understand why the Ministry wants to revoke Policy 4.24 SA when the policy has not yet been completed. Better to leave Policy 4.24 as it now stands and add a new policy called Policy 4.241 that will contain the Ministrys proposed comments as shown below: Policy 4.241 Following the release of the Phosphorous Reduction Strategy, released on {specify date of release}, as part of the progress reports required every five years under subsection 12 (2) of the Lake Simcoe Protection Act, 2008, the Ministry will report on, (a) the implementation of the strategic directions set out in the Strategy; (b) the extent to which the phosphorous reduction goals established in the Strategy are being achieved; (c) the progress being made to achieve the overall long-term phosphorus loading goal of 44 T/yr; and (d) whether the Strategy should be revised to deal with results from ongoing research and monitoring. I believe that progress reports should be made more frequently than every five years. Making a progress report every five years means that an phosphorus reduction implementation problem may not be discovered for up to six years. A problem that lingers for five of six years may set back the whole phosphorus reduction program and jeopardize the goal of reducing the phosphorus load to 44 tonnes by 2045.

[Original Comment ID: 125548]