Ontario draft biodiversity strategy deficient

Letter from Blue Mountain Watershed Trsut Foundation August 5, 2012

to: Alan Dextrase, Policy Advisor

Ministry of Natural Resources, Policy Division, Biodiversity Branch

Biodiversity Policy & Program Development Section

300 Water St. Floor 2, Robinson Place North Tower

Peterborough, ON K9J 8M5

Re: EBR Registry Number 011-6450

Dear Mr. Dextrase:

The Blue Mountain Watershed Trust Foundation (BMWTF) is a non-profit, non-governmental organization that is committed to ensuring the continued environmental health and integrity of the Blue Mountain area watersheds.   The Watershed Trust’s area of interest consists of 50,000 hectares from the Niagara Escarpment to Georgian Bay, encompassing Silver Creek, Black Ash Creek, Townline Creek, Batteaux River, Pretty River, Indian Brook and the Beaver River watersheds. Our goal is to protect, wisely manage and enhance surface and ground water, wetlands, woodlands, fish and wildlife habitat, ravines, valleys and streams in our watersheds.  For more information on the Watershed Trust please visit our web site at www.watershedtrust.ca.

The Ontario Government should be commended for moving forward on a plan to conserve biodiversity.

However, the introduction to the Plan is totally deficient in assessing the seriousness of this issue which threatens the survival of the planet as we know it. We are well into the sixth major extinction event in the history of life on Earth. Extinction rates have been fifty times normal and are increasing. The other events were caused by various geological or astronomic factors but this time it is caused by one species – homo sapiens. (see attached graph). The destruction of so many species by humans is an ethical issue. 

How can we tackle a reduction in biodiversity if we cannot be clear about this fact? In the Royal Ontario Museum (ROM) publication Rotunda, summer/fall 2001, Dr. Allan Baker said: “If things don’t change, 30 to 70 percent of all species in the world will disappear, if not in our lifetime, then during the lives of our children.”

In the same article, Dr. Mark Engstrom said: “Mankind has already precipitated a minor extinction event… Whether it continues is entirely up to us. It does appear that we are picking up the destructive pace.”

The destructive pace has continued since 2001. Perhaps you should consult the ROM in order to put the issue of biodiversity into perspective. We also recommend consultation with Biodiversity Journal and specifically the study by Ted Mosquin and Stan Rowe titled A Manifesto for Earth (contact Stephen Aitken at aitken@tc-biodiversity.org ).

Of course this is world-wide problem and the Plan is limited to Ontario’s jurisdiction. Nevertheless, the Plan should be more realistic about the seriousness of the issue and should deal more effectively with the following matters:

1. Population:

The government tends to accept the forecast population growth as a given. Before accepting the forecast, the first question should be “Is this forecast of population growth consistent with a plan to conserve biodiversity?” If not, it must be modified to halt all urban spread or to accept fewer immigrants especially to Southern Ontario. It is clear that past growth is not consistent with the Plan when one notes the continued loss of biodiversity. The Places to Grow legislation and Species at Risk Act are helpful but incapable of arresting biodiversity losses as currently written. It is necessary to resist the pressure by the business community to always push for more growth.

2. The Ethical Question:

The introduction stresses the importance of biodiversity for “our quality of life” and how “we depend on” and “rely upon” nature’s biodiversity for outdoor recreation, enjoyment, well-being and prosperity. All of this is true but it fails to mention the ethical problem that it is not right to allow our species to reduce biodiversity so dramatically. Biodiversity includes insects, fungi, parasites, viruses, etc. as well as the animals and plants that are more obvious.

3. Interface with the Planning Act, Provincial Policy Statement (PPS) and the Aggregate Resources Act,

(a) It must be recognized that amendments must be made to the PPS and the Planning Act to be consistent with the Biodiversity Plan objectives. The current PPS, in section 2.1, requires that a study be conducted to determine the potential for harm before development or site alteration occurs on lands adjacent to specified natural features. The study must cover an area of 120 metres from the specified feature. The assessment of harm is to a large extent a matter of judgment. Buffers as small as 10 metres from a wetland are sometimes allowed because the studies are done by the proponent’s consultants and it is difficult and costly to prove that harm will occur to a specific wetland habitat. However, we know that in many cases harm does occur over the period of generations. The conservation of biodiversity in Ontario requires overhaul of the PPS in order to assign minimum buffers to prevent harm to the habitat that important species rely upon. To mention only a few cases, reptiles and amphibians are increasingly threatened and grassland birds are declining precipitously (see The State of Canada’s Birds 2012 published by Environment Canada for NABCI). Most reptiles and amphibians require both wetland and extensive adjacent upland areas in their life cycle.

(b) Similarly, amendments to the ARA are required for it to be consistent with the Biodiversity Plan in order to deal more effectively with the encroachment of aggregate mining on natural areas. Furthermore, in order to avoid conflicting objectives, the ARA and NEC should not come under the same ministry. We recommend the NEC be moved to be under the Ministry of the Environment.

4. Measurement of Biodiversity:

Conservation of biodiversity requires reasonable estimates of the amount of biodiversity that exists in Ontario so that some measurement can be made of the success of a Biodiversity Plan. A few years ago a Canadian Biodiversity Index (CBI) was being developed by an inter-government Biodiversity Working Group. Has it developed sufficiently for measurement of Ontario’s biodiversity? The Plan is not clear about the adequacy of currently available measurements. There must be tools to adequately measure the success of the Plan.

5. Agricultural Policy:

(a) There is insufficient stress on the importance of organic agriculture in reducing the stress on ecosystems and biodiversity.

(b) It has been well documented that beef production consumes much more land, energy and water than any other form of food. Ruminant animals also produce GHG’s. A policy of reducing beef production and consumption is consistent with conserving biodiversity. 

6. Funding for MNR and MOE

It is our experience that MNR funding is so tight that they are badly stretched to administer the Acts for which they are currently responsible. The quote from the Biodiversity Plan that The Ministry[of Natural Resources] works to manage Ontario’s natural resources in a manner that sustains and restores healthy, resilient aquatic and terrestrial ecosystems, thereby safeguarding human health and quality of life for Ontarians is not consistent with their current funding. The same comment would apply to the Ministry of the Environment.

7. Greenhouse Gases (GHG)

In order to halt biodiversity losses, a dramatic reduction in GHG’s is required. The Ontario Government can be commended for reducing energy production from coal, but much more must be done.

8. Snapping Turtle: an example of a backward policy

This is a species of special concern which means we must be concerned about its survival. Yet, the Government continues to allow the killing of these turtles. This is an example of failure to be serious about biodiversity.

We have no problem with the structure of the Biodiversity Plan, i.e., Engage People, Reduce Threats and Enhance Resilience. However, the Plan should contain a greater sense of urgency about the continued dramatic losses of biodiversity.

D Kerr, Director

On behalf of the Blue Mountain Watershed Trust