Good afternoon, members of the committee. I'd like to thank you for this opportunity to share with you our recommendations on Bill C-40.
As mentioned, I'm speaking on behalf of Ontario Nature and Environmental Defence. My name is Caroline Schultz and I'm the executive director of Ontario Nature.
Ontario Nature is a charitable organization that works to protect wild species and wild spaces through conservation, education, and public engagement. We represent over 30,000 members and supporters, and 154 member groups across the province of Ontario.
Since our organization was founded as the Federation of Ontario Naturalists in 1931, Ontario Nature has been the voice for nature throughout the province, protecting and restoring natural habitats while connecting thousands of individuals and communities with nature. Over our 84-year history, Ontario Nature has played an instrumental role in establishing most of the province's protected areas.
Ontario Nature and Environmental Defence supports the creation of Rouge national urban park. The park has great potential to protect biodiversity while protecting healthy local food production and connecting urban dwellers in the most heavily populated region of Canada to the national park system.
However, if Rouge national urban park is to realize its full potential, we believe that Bill C-40 must be amended to clearly prioritize ecological integrity.
Here are specific recommendations:
First, we are asking that there be a requirement that ecological integrity be the first priority of the minister in park management. Bill C-40 affords significantly weaker protection to the natural environment than either the Canada National Parks Act or Ontario's Provincial Parks and Conservation Reserves Act. In both of these statutes, ecological integrity must be the first priority of the minister in making management decisions about the park.
In contrast, Bill C-40 omits any mention of ecological integrity, a concept that is integral to the very purpose of the other two laws, nor does it require the park to be managed to protect wildlife and natural ecosystems. Rather, it leaves this critical element of park management up to the discretion of the minister. In other words, the minister need only take protection of natural ecosystems into consideration in managing the park.
Clause 6 should be amended to require and ensure that the protection of the natural environment is prioritized in park management.
On a second point, we believe that the schedule needs to be revised to include in the park approximately 48 square kilometres of publicly owned lands that are under federal jurisdiction. The Rouge Valley connects Lake Ontario and the Oak Ridges Moraine. The lands described in the schedule, however, will not protect this important ecological corridor. There is a wall of urban development around the town of Stouffville that effectively cuts off the Oak Ridges Moraine from Lake Ontario.
The schedule excludes about 48 kilometres of publicly owned federal lands that are currently available immediately adjacent to the proposed park. By including these adjacent lands in the park, the critically important ecological corridor between Lake Ontario and the Oak Ridges Moraine would be secured once provincial lands are transferred. The park would almost double in size, making it far more likely that biodiversity and ecosystem services will be conserved.
On a third point, we believe that the management plan requirements need to be strengthened by explicitly including details about ecological objectives, indicators, monitoring, and reporting. Clause 9 of Bill C-40 sets out details about what must be included in a park management plan, but it lacks in particulars regarding ecological elements to be included. We recommend that subclause 9(1) be amended to require that the management plan include ecological integrity objectives and indicators, provisions for ecological monitoring and reporting, and performance evaluation.
With respect to evaluation, we also recommend that a state of the park report be tabled in the House of Parliament every five years.
From a science perspective, size and landscape connectivity are vital considerations in designing protected areas. We therefore recommend that these adjacent federal lands be included in the schedule.
As point four, we recommend that there be provisions added to ensure that potential adverse ecological impacts are duly considered when decisions are made regarding infrastructure installation or maintenance.
Clause 12 sets out the powers of the park superintendent regarding clearing of land for infrastructure installation or maintenance, and clause 16 sets out the right to dispose of lands within the park for the purpose of installing or maintaining infrastructure. Such activities have the potential to adversely affect wildlife, ecosystems, and ecological integrity. To ensure that these issues are adequately considered and addressed, we propose that each of these clauses be revised to include requirements to consider reasonable alternatives and to minimize and where possible avoid environmental impacts.
Also, please note that we support the 200 hectare limit for transfers, as currently stated in the bill.
Our point number five is to strengthen the preamble. We recommend amending the preamble of the bill so that it first of all, explicitly includes the restoration of natural heritage, and second, avoids the vague and undefined term “diverse landscapes”. We believe that Rouge urban national park offers an exceptional opportunity to protect and celebrate nature and our agricultural heritage. Both nature and farming are specifically mentioned in clause 4, and “diverse landscapes” detracts from this clarity of purpose.
I'd like to thank you for your time and the opportunity to share Ontario Nature's and Environmental Defence Canada's recommendations with you. I'd be happy to answer any questions you might have.