blood money - Simcoe County Greenbelt Coalition

Comments on the
Species at Risk Conservation Fund

With the Species at Risk Conservation Fund and broader changes to the ESA, the future of these species is very grim.

This letter was submitted to the Environment Registry of Ontario in response to posting ERO 019-2636, which proposes use of a “Species At Risk Conservation Fund.”

Simcoe County’s Context as a Home to Species-At-Risk

At 4,841 square kilometres, Simcoe County is one of the largest regions in the Greater Golden Horseshoe.

Its vast interconnected water system includes provincially and internationally important water resources: Wasaga Beach, Minesing Wetlands, Matchedash Bay and Wye Marsh.

Geologically diverse, Simcoe is home to over 1500 species of vascular plants, 150 species of nesting birds, 50 mammals and 33 types of reptiles and amphibians¹. It offers specialized vegetation communities adapted to unique habitats such as coastal plains, prairies and savannas, alvars, bogs and fens, the Great Lakes shoreline and the Niagara Escarpment.

In addition, the county contains provincially significant wetlands, provincially significant Areas of Natural and Scientific Interest and more than 60 species of plants and animals deemed vulnerable, threatened or endangered in Ontario and/or Canada.²

Extensive tracts of undisturbed forest in the north and east are habitats for forest-dwelling birds and mammals.

All these features combine to provide a healthy habitat for Simcoe County residents, flora and fauna.

Our concern is how these sensitive habitats will be treated in future under the potential changes.

In broad strokes, we are strongly opposed to the Species at Risk Conservation Fund for the following reasons:

The loss of biodiversity has been shown to put climate action and public health at risk. This fund normalizes and establishes a process to continue biodiversity loss without any opposing policies that stop the losses overall;
Funds aren’t required to be applied to affected watersheds, municipalities or Indigenous traditional territories where the harm occurs;
Provides a perverse incentive to destroy sensitive habitats;
Payment into the fund is an alternative to “overall benefit” approach that the Endangered Species Act was intended to uphold;
The funding charge fails to fully calculate the risk and liabilities that arise with the removal of sensitive habitats;
No long term government financial commitment that assures conservation efforts will continue outside of pay to slay fees. Will this require MECP to allow more permitting and fee collection to keep this fund financially independent as the Ministry anticipates? If the fund is not financially independent as hoped, will funds be diverted from other conservation programs accordingly?
Lack of transparency with the public regarding the success indicators of this program including species-specific or cumulative impacts of activities undertaken by proponents. These indicators should be measured and included in public reports.

New Changes Put in Context of Species at Risk in Simcoe County/Lake Simcoe Watershed

As noted in Figure 1, there are several species at risk in one of our watersheds and they are most at risk within Simcoe County communities. The new changes proposed could pose significant threats to Simcoe County’s most vulnerable species and sensitive habitats.

In 2012, MNRF looked at the Lake Simcoe Watershed to assess the vulnerability of species at risk within the Lake Simcoe watershed in light of climate change. Out of the 62 species at risk known in the watershed, 17 were identified as most at risk and therefore high priority for study. As easily seen in Figure 1, these species were most imperilled (red/orange/yellow) in Barrie, Oro-Medonte, Orillia, Innisfil and Bradford West Gwillimbury.

Further, the vulnerability assessment found that two species at risk were going to face devastating futures factoring in climate change – the Redside Dace and the Jefferson salamander. Assessments concluded that in both cases, the current habitat, which is currently under threat, is the only one left that is suitable for them in the entire watershed.

Although from two different ecosystems, what these species tell us is all we need to know about how effective current ESA regulations are at protecting species and their habitat.

Urban development is the most significant threat to both of these species as clearly outlined in their recovery strategies.

The Redside Dace requires clean water with forest cover while the Jefferson Salamander requires connected habitat which includes well-functioning wetlands and clean water systems.

However, their habitats continue to be affected by urbanization despite coherent recovery strategies. That we are not only threatening their “officially recognized habitat”, but also degrading adjacent habitats so they have no other habitat options is a scathing assessment of what we are doing to our landscapes and watersheds.

In Conclusion

With the Species at Risk Conservation Fund and broader changes to the ESA, the future of these species is very grim.

We support the submission of Ontario Nature and, like Ontario Nature, stand strongly opposed to the government implementing the Species at Risk Conservation Fund.

Instead, the government should be implementing policy that puts public health first and foremost. This would include stronger protection of sensitive habitats, measures to increase and strengthen biodiversity, preserving places that are known carbon sinks, flooding regulators and climate change mitigators (wetlands, forests).

Unfortunately, these proposals move us further away from forward thinking conservation action that has been the backbone of Ontario’s policy structure for decades.

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Open letter to Minister Clark regarding Bill 229 and keeping faith with Ontarians

…if this government is truly committed to these initiatives, by which we mean that they are not being used as cheap politics to deflect from the criticism, fully deserved, that they are receiving with regard to the policy changes noted above, then we expect the following…

This letter was written after the Province passed Bill 229, which came after a huge outcry from the public, from environmentalists, from Conservation Authorities, and from municipalities, among others, and which prompted the resignation of seven members of the Province’s Greenbelt Council.

Dear Minister Clark.

There has been much attention paid lately to the future of our Conservation Authorities – one of the last regulatory bodies designed to protect our environment. In a response to the public outcry regarding the neutering of Conservation Authorities’ ability to protect water, wetlands and public health, Minister Clark made a series of statements and announcements:

First, was the promise of $30 million dollars to “create, restore and enhance wetlands” across Ontario;

Second, was a promise to improve the “quality and quantity of the Greenbelt”.

The timing of these announcements is troubling and does not add to our confidence in the government’s commitment to protecting the environment coming, as it has, on the heels of eight members of the Greenbelt Council quitting in protest over provincial policy changes. Changes that former Toronto Mayor and, until he resigned this past week, Chair of the Greenbelt Council, David Crombie outlined as “high-level bombing”.

But we are willing to accept these announcements in good faith, and we look forward to hearing more about these initiatives. To be very clear, however, if this government is truly committed to these initiatives, by which we mean that they are not being used as cheap politics to deflect from the criticism, fully deserved, that they are receiving with regard to the policy changes noted above, then we expect the following:

That no more MZOs will be issued that allow development in provincially significant or locally significant wetlands. It makes no sense to commit to restoring wetlands and putting taxpayer money towards that, while simultaneously destroying or impairing other wetlands. Refusing to do this would be creating a boondoggle for developers, using public money to offset wetland destruction.

Any MZO that is issued in the Lake Simcoe watershed will clearly outline how the Lake Simcoe Protection Plan policies will be adhered to, in order to ensure conformity with said policies as MZO conditions.

The Lake Simcoe Protection Plan, which will be reviewed in the new year, will be strengthened by building on proven existing policies (e.g. phosphorus loading targets and WWTP moratoriums), demonstrating the government’s commitment to protect the environment with policies that protect more high quality natural cover, including wetlands and forests. This should be a zero loss target and policy structure, meaning that there should be no reduction in the quantity and quality of natural cover going forward. Currently, the target in the LSPP is 40% high quality natural cover – a target that we are failing to meet.

The $30 million Wetland Restoration Fund will be money invested by the Government of Ontario and not “blood money” that comes from developers paying a fee to permit the destruction of wetlands. If it is based on offsetting, this is a “pay to pave” mentality that has been proven disastrous for watershed health in other jurisdictions. Funding wetland restoration through the destruction of other wetlands would be disingenuous to the government’s commitment and breaks faith with Ontarians who rely on wetlands for flood mitigation, drinking water purification and recreation.

Growing the Greenbelt includes keeping the existing Greenbelt strong. We don’t want to see a bait and switch where more Greenbelt is added in exchange for current Greenbelt lands being removed from protection. The Greenbelt, its farms and communities, contribute $9.6 billion of economic impact and $3.2 billion of environmental services to Ontario every year. As a region that is growing we will be relying on the services it provides far into the future. Dismantling it through land swaps threatens its ecological functions, and, consequently, its contributions to our collective prosperity and wellbeing.

The province, if it is genuine in its commitment to growing the Greenbelt, will base new included areas on science and public health, not just land ownership. Following such a process means that all source water areas (highly vulnerable aquifers, significant recharge areas, moraines and locally significant wetlands) in Simcoe County should be added to a bigger Greenbelt, at minimum. Simcoe County residents are highly reliant on groundwater for their daily needs. If we don’t protect these areas soon, the public’s health is at risk.

We hope that your government is genuine in its commitment to these ends. We are sure you would agree that using environmental policy as a ploy is dangerous to our public health and erodes faith in our democratic institutions and your governments’ commitment to acting in the best interest of all Ontarians.

Ultimately, it is in no one’s interest that a government fails – such an event has real life consequences for the people of Ontario, including to their health and wellbeing. We are committed to helping where we can to find success in the above noted expectations, but we will not betray our knowledge and understanding, born by evidence, of the actions required to create a more just, prosperous, and sustainable Ontario. We will be watching closely to ensure that you stick to the commitments you have made and do so in a genuine manner.

Bill 229 - Additional Resources

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