Good afternoon, and thank you for the opportunity to share with the committee our recommendations and thoughts on Bill C-40, an act respecting the Rouge national urban park.
My name is Éric Hébert-Daly. I'm the national executive director of CPAWS. Since our creation about 50 years ago, CPAWS has played a key role in the establishment of about two-thirds of Canada’s protected areas. We have 13 regional chapters across the country in nearly every province and territory, including the CPAWS wildlands league chapter in Toronto, as well as a national office here in Ottawa. We have over 60,000 supporters across the country, and we work collaboratively with governments, industry, first nations, and others to conserve Canada’s natural heritage.
Over the last five years we've welcomed the arrival of new federal park initiatives, including the sixfold expansion of Nahanni National Park Reserve in 2009, and the creation of Gwaii Haanas national marine conservation area in B.C., in 2010.
We're here to discuss a different kind of park, the creation of Canada’s first national urban park in the greater Toronto area. CPAWS has been quite excited about and has supported this idea from its very inception. We see it as a remarkable opportunity for us to protect a very special natural valley in Canada’s biggest urban area, and at the same time to engage and connect people with nature.
Let me also be clear that CPAWS has recognized from the very beginning that farming is and will continue to be an important aspect of this park. We believe that farming can contribute to nature conservation at the same time that nature conservation can contribute to farming. We as conservationists actually share a very common interest with farmers, that of keeping urban development and urban sprawl from these lands. We often remark that the opportunity to create this national urban park is in part due to the farmers who themselves have kept urban development at bay, and the local grassroots groups who have been championing the Rouge for decades. In fact, we make no suggested changes to the aspects of agriculture within the bill.
In recent weeks we have listened with great interest to the debates about the appropriate management framework for the Rouge: should it be ecological integrity or ecosystem health? While we think there are valid arguments being made for both, CPAWS believes there is a more fundamental issue that needs to be addressed in the legislation, which is that nature conservation be clearly identified as the overarching priority for managing the park. This gets to the very essence of what a park is. Without it, we don't really have a park; we may have something else. We may have a multi-use zone or we may have other types of reserves.
However, prioritizing nature conservation is both consistent with international standards for protected areas and with existing federal and Ontario provincial legislation for parks and protected areas. It should, and it can, be reflected in the Rouge legislation as well, yet it is absent from the current bill, which only requires that the minister take into consideration nature and wildlife in managing the park.
For several years, Parks Canada has expressed a preference for managing the Rouge national urban park under an ecosystem health framework, rather than an ecological integrity framework, to distinguish national urban parks from other national parks. In the spirit of being solutions oriented, we have developed constructive recommendations over that period of time that focus on maximizing ecosystem health.
We are recommending that the legislation be amended to clearly identify maximizing ecosystem health to the greatest degree possible, which is a very important condition as part of the the overarching management goal for the Rouge. We also recommend that a robust definition for maximizing ecosystem health be embedded in the legislation.
Our recommendations would mean that language in the bill would meet international and Canadian standards for protected areas. They would provide park managers with stronger tools to protect the park’s existing natural values and improve the health of its ecosystems as much as possible, particularly given its urban and agricultural context. It would make Parks Canada accountable for improving the health of the ecosystem over time, while not giving the impression that they must achieve an end point of full ecological integrity.
Moreover, our recommendation would provide a clear mandate and incentive for Parks Canada to work collaboratively with farmers to identify strategies that would be good for nature and for farmers in the long run.
We have also identified a few areas where the legislation needs strengthening. On the management planning side, we see requirements for setting ecological objectives and indicators, as well as provisions for ecological monitoring and reporting that are needed in clause 9.
A state of the parks report should be required to be presented to Parliament every five years, as is the case with other national parks, so parliamentarians and the public can track how well Parks Canada is meeting its objectives over time.
Related to public infrastructure, clauses 12 and 16 need to be bolstered with stringent criteria to guide decision-making prior to the clearing of land or disposal of land in the park for infrastructure purposes. For example, we suggest that decision-makers be required to consider reasonable alternatives and to ensure that lowest cost is not the sole justification for infrastructure proposals that might harm the park.
Finally, I'd like to acknowledge parts of the bill that we support and would like to see remain in an amended bill. We support the list of prohibitions currently in the bill. We support the fixed limit of a maximum of 200 hectares that can be removed from the park for infrastructure. This is critically important to avoid the park being nibbled away at over time.
CPAWS urges committee members to work together to strengthen the bill to ensure that the Rouge national urban park effectively protects this natural treasure in the long term, while also supporting a healthy and vibrant farming community and encouraging people to connect with nature.
We've prepared several specific amendments that we will provide to all members of the committee in the upcoming days.
I thank you for the opportunity to share our recommendations. I'd be pleased to answer any questions you may have.