We have to think about long…

I agree with the threats to clean water identified on pg 12 of the Made in Ontario Environment Plan. These threats will not disappear without a commitment to upholding Ontario’s excellent water policies but I see no specific commitments here to upholding those policies.

I am also pleased to see the following statement in the environment plan: “Build on previous successes and continue to implement the Lake Simcoe Protection Plan to protect and restore important natural areas and features of the lake. Ontario has invested annually in the implementation of the Lake Simcoe Protection Plan,” (pg 13).

Lacking in the environment plan is an over-riding clause that will prevent the gutting of hard-won environmental legislation, such as the Lake Simcoe Protection Act.

Section 6 (Effect of Plan) of the Lake Simcoe Protection Act states, (4) Despite any Act, but subject to a policy described in paragraph 6 of subsection 5 (2), if there is a conflict between a provision of a designated policy set out in the Lake Simcoe Protection Plan and a provision in a plan or policy that is mentioned in subsection (5), the provision that provides the greatest protection to the ecological health of the Lake Simcoe watershed prevails. 2008, c. 23, s. 6 (4).

This concept should be front and centre in any environmental plan.

The Lake Simcoe success story reported in the plan (pg 14) “Celebrating recovery of freshwater fish in Lake Simcoe” highlights successes while ignoring evidence that we have a long road to recovery at Lake Simcoe, and that the threats to the watershed’s health remain. Average phosphorus levels in Lake Simcoe are still as high as they were in 2005, nearly twice the annual phosphorus loading target level set by previous governments and scientists to keep Lake Simcoe swimmable, fishable and drinkable. Status quo effort is not enough to make the lake healthy again. Further effort is needed to protect this valuable watershed from increasing algal blooms, toxic drinking water, fish kills, species extirpation and extinction.

Wetlands and woodlands:

The Made in Ontario Environment Plan does not include policies to protect wetlands and woodlands. It promotes greater access and public use of existing parks but promises no funding or targets to increase public parklands or wild lands to meet the United Nations and Canada’s target of 17% in protected lands, a target that many in Ontario have embraced.

Climate Change:

Climate change is a major stressor to Lake Simcoe. Shorter winters, less ice cover, and hotter summers mean that water temperatures rise, which stresses aquatic life in streams and lakes. More common flooding events mean more scouring of streams and rivers, and thus more sediment (containing phosphorus) flowing into the lake. Mitigating and adapting to climate change are essential components of saving Lake Simcoe.

It is disappointing that the plan’s climate change section presents less aggressive greenhouse gas targets than Ontario’s previous climate plan. The document refers to “the policies within this plan” (pg 22), but there are no specified policies contained in the plan. The plan is oddly silent on alternate energy sources such as wind and solar power that other countries are now successfully using as a significant clean energy source.

The plan is very clear that provincial incentives or rebates will not be forthcoming for low-carbon refueling infrastructure (pg 33). In addition, select industrial polluters will be granted provincial exemptions from accounting for the carbon emissions they produce (pg 25).

Furthermore, the implementation section does not mention any policies to be brought forward in the future. Please confirm that policy will be developed for this plan and that the public will have the opportunity to review and comment and therefore better understand the impact and context of this plan. Without it, this plan is ambiguous and lacking vital implementation detail and clarity.

Safe soils:

I am pleased to see that the plan includes “revising the brownfield regulations”, setting “clear rules for beneficial reuse of safe soils”, and “increase enforcement of illegal dumping of excess soil”. The process in place at present does not control dispersal of contaminated soils.

Drinking Water:

The following statement from the Made in Ontario Environment Plan is a good start: “Ensure the knowledge gained through the Drinking Water Source Protection Program helps inform our management programs,” (pg 14).

In the past, the Drinking Water Source Protection program, developed by Conservation Authorities and Province of Ontario under the Clean Water Act, 2006, was highly respected and worked to protect vulnerable aquifers from incompatible development and practices.

Likewise, the current government should be clear that the development community must protect these vulnerable areas in their development activities, not just use the information “to inform our management programs”.

I am worried about clean water and having a healthy environment for our children and generations to come. I love our parks, wildlands, forests, lakes, rivers and clean drinking water. Please put actions behind the words in the Environment Plan and secure a healthy future for all Ontarians.

We need better long term planning. I question the real need for more urban development. I question why are we using viable land that can be used to feed our province to build huge estate homes that will only house 10 - 12 families. I question what we will be leaving future generations to work with. Growth for the sake of growth is not a good plan.

The following is an excerpt from Tim Grey, Executive Director for Environmental Defence, and I support his views. Also included are links to two other websites with similar justifications to continue to protect our land and waters.

"For almost 40 years, successive Ontario governments have been incrementally encouraging less urban sprawl, more compact urban growth, and moves toward greater public transit capacity.
But this will now change if the Ontario government’s proposed weakening of the Growth Plan proceeds.
These proposed changes include:
• Allowing urban boundaries to expand without proper evaluation of need. This will increase rates of sprawl and eat up more farmland and natural areas. We know that this is not needed as provincial data shows there is enough land designated to meet housing needs to at least 2031.
• Reducing the requirements to build within cities instead of outside them. This lowers the priority of building new development within the existing town or city and also lowers the priority that new areas are developed more densely than the past. In other words, it encourages low-density sprawl over redevelopment and revitalization.
• Removing the requirement to plan for future housing needs based on what is actually needed. This marks a return to the bad old days of building more detached single family homes on farmland because that is what was done in the past.
• Allowing new public transit stations to be built and developed around in areas of low population and employment instead of in mobility hubs that service large numbers of people. This is the return of the “GO station in a cornfield” model which encourages more sprawl, cars and highways.
In the long run, a return to sprawl-focused development will eat up the farm lands and natural areas that surround our cities and towns. It will decrease our quality of life, increase our commute time, increase our property taxes and diminish the quality of our air, water and food. It will also eventually bring development right to the boundary of the Greenbelt and other protected lands which could lead future government to argue for opening them up to development.
The proposed changes to the Growth Plan are huge mistakes. Instead of gutting our efforts to make our cities more livable and keep our farmland, water and natural areas protected we should:
Keep the existing 2017 Growth Plan approach to maintain denser, compact cities and towns that can only grow after a full review based on evidence
Save farmland for healthy local food, employment and food security
Revitalize our urban areas by keeping intensification targets for missing housing types, so housing that people want and need (e.g. rental, row houses, town houses, smaller mainstreet condos, smaller homes for seniors and new buyers) is what is built – not monster homes on big lots.
Build purpose built rental housing and supportive housing options near major transit hubs (subway, bus and train stations)
Base Growth Plan changes on good information, involvement by local citizens and long term planning of infrastructure needs, costs and tax implications."

Once we have given up our precious farmland and wetlands to urban sprawl we will never be able to replicate or recover those resources again.

Thank you for taking my comments into consideration.