Browsing the archives for the Invasive Species tag.

MNR Proposal Abdicates Responsibility for SAR

Green Reality, South March Highlands

The Ontario Ministry of Natural Resources (MNR)’s current regime for managing approvals for permits affecting Species-At-Risk (SAR) is already flawed and the proposed changes described in the Environmental Bill of Rights Registry (EBBR 011-7696). make the situation worse – not better.

The current regime is based on providing a process for approving an activity that might harm SAR, or SAR habitat, that is based on an emphasis that mitigates impacts.

  • This is based on a false presumption that mitigation is always possible.
  • Most permit applications are granted if the mitigation for the SAR in question is relocated to a different ecosystem (i.e. moved, transplanted, or seeds replanted).

The existing Approvals process completely ignores the ecosystem implications of a permit by focusing too narrowly on the SAR in question and not on its relationship to the ecosystem it resides in and contributes to.

No vegetation or wildlife (or humans) exist in isolation of other living things.  Each has an impact on the other and within a natural ecosystem, these impacts are beneficial, balanced, and necessary for the whole – otherwise the ecosystem would be different.  Ecosystem change is usually caused by a dis-balance caused by an external event such as human activity, disease, fire, flood, or invasive species.

Instead of (a) requiring a burden of proof that mitigation is possible and (b) ensuring that broader ecosystem effects are included in this process, this proposal makes matters worse by continuing the MNR’s policy of ecosystem piecemealing via regulation.

The breadth of exemptions in the proposal is unreasonably broad because it includes all already approved or planned activities that might damage habitat.

  1. Encompassing all activities is unreasonable in scope.
  2. The proposal does not take into account the fact that approvals (such as a PTTW or CoA) have been granted in the past by agencies without regard to impact on SAR.  These agencies granted their approvals under the expectation that the MNR would fulfill any SAR-related approvals. If the MNR abdicates responsibility, then there is no consideration for SAR under any prior approval granted by any provincial ministry.
  3. The definition is so vague as to allow virtually any activity to quality – for example proposed plans of subdivision approval that have not yet been approved under the Planning Act.  This would remove what little protection exists for all 22 SAR documented in the South March Highlands.

The MNR’s rationale for grandfathering so many activities & exemptions is so dubious as to completely lack credibility.  How will the grandfathering and creation of so many exempt activities that damage habitat contribute to the overall benefit of SAR?

While it is apparent that the MNR seeks to shrink its job in the face of insufficient funding by McGuinty, the creation of so many exemptions will create an unsustainable workload for the MNR to manage the enforcement of compliance with.  Any alleged violation would require considerably further substantiation and validation of prior approvals by other agencies.  In my view, not performing such validation would constitute environmental negligence on the part of the MNR.

The proposed exemptions would also create two classes of SAR (existing and new) which has no reasonable basis in the Crown’s primary obligation to protect all SAR.  This also creates a legal liability for the province in view of recent Federal Court ruling on the fiduciary obligation of the Crown to provide such protection.  Protection of critical habitat is a duty – not a government discretion.

The Federal Court ruling sets a precedent that all levels of government must follow.  In Ontario, this duty is also enshrined in the Environmental Bill of Rights.

The proposed changes amount to abdication, not modernization, and should be opposed.   The Coalition to Protect the South March Highlands, Carolinian Canada CoalitionOntario Nature, and the David Suzuki Foundation have already expressed their opposition to this.

If you also oppose this, please make an individual posting to the EBBR.  Type in the 011-7696 Registry Number in the search box.  Search for and select the proposed change to bring up a description of it.  From there it takes less than 5 minutes to click on the Submit Comment button on the right side of the screen and to fill out the form or to cut and paste your comment.

Feel free to use any or all of the above via cut-and-paste if you wish.

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Can You Still See The Forest?

South March Highlands

This is the text of the presentation that I gave to the Ottawa Forest and Greenspace Advisory Committee meeting on April 26, 2010.

I am here today as a local resident

  • who is part of a larger coalition of concerned citizens that oppose the TFD expansion project

I’m here to ask Why does this City keep systematically destroying the SMH?

  • This has been going on for the past 40 years

In the past 10 years the City has been using the road to justify development of the area and vice versa.

  • This has been going on for so long that it is now difficult to tell which came first
  • The chicken or the egg

What baffles me most is how is it that City planners (who have been so busy planning how to cut down trees) have lost sight of the importance of the very forests within which they stand?

So with this presentation I’d like to start by stepping back about 50 km so that we can properly see all the forests involved.

Ottawa’s Other Transportation System

As you can see from this aerial photo, looking down from 50 km, we can see 3 major eco-corridors running in parallel to each other:

  • Gatineau Park to the North
  • Constance Lake – Shirley’s Bay along the River
  • South March Highlands to the South

Each of these eco-corridors plays a vital role in the transportation system of the National Capital:

  • They enable the transportation of animals, fish, and birds who live in and travel within them
  • Who in turn carry native seeds, pollen, and other genetic material up and down these corridors
  • This transportation of vital  genetic material helps the City fight off the invasive species that our now threatening us as a result of the combination of irresponsible development and climate change
  • These eco-corridors also help absorb the GHG emitted by the City’s other transportation system, turning these noxious fumes back into life-giving oxygen.

 How is it that City planners have been oblivious to the whole transportation picture?

Integral To Shirley’s Brook Hydrology

Now let’s zoom in a little so that we can see another transportation system at work

  • This map uses the City’s hydrology database
  • To show how the SMH are the source for the hydrology of Shirley’s Bay
  • The provincially significant wetlands are all shown in Blue so that they show up better
  • Shirley’s Brook drains the SMH wetland complex, transporting water that feeds the nationally significant wetland in Shirley’s Bay
  • In other words, the SMH eco-corridor is connected to the central eco-corridor that we saw on the previous slide.

 Ottawa’s Most Important Ecological Reservoir

Let’s zoom in a bit more and take a closer look at SMH in perspective

  • This area has been described by scientists as  one of the most important ecological reservoirs in the City of Ottawa

 Densest Bio-diversity in Ottawa

SMH has been called a “wild island” that has the richest biodiversity per hectare in the City

  • Over 654 identified species
  • Probably actually over a thousand because the area has not been holistically studied
  • All within a 3×2 km area

 What are we doing to protect it?

Even though this area has been identified as needing protection since 1972, the City has failed at conserving it.

Only 1/3 of the original “protected” 1972 lands remain

  • Lost to development in the south
  • Losing to development in the north
  • Hollowed out in the middle

 It’s Time to Stop The Madness

What little that does remain will not be sustainable if TFD is allowed to cut the remaining area in two:

  • Enabling so-called development within the arc of the road
  • Trillium woods will cease to be a forest
  • South March Conservation forest will die as a forest
  • And all we will have is yet another urban park with nothing left but squirrels and some diseased trees

Greenbelt Shepherd’s Hook Alternative

But it’s not too late to do the right thing!

  • We can extend the greenbelt with a shepherd’s hook that includes SMH
  • This will simultaneously provide protection of both SMH and Shirley’s Bay

 Ottawa’s Gatineau Park

We can then extend this with eco-corridors that encompass the wetlands beyond

  • Perhaps working with the NCC to build Ottawa’s own version of Gatineau Park
  • And then we will have a real and  holistic transportation plan that values eco-connectivity as much as we value automotive connectivity

 It’s Never Too Late To Do The Right Thing

Many I’m sure will whine about the consequences of all the bad decisions made in the past

  • Some will argue that it is too late and we can’t turn back the clock
  • Others will conveniently blame the OMB
  • But it is NEVER too late to do the right thing

All it takes is vision and the courage to follow what your heart knows is right.

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