Letter to Prime Minister re IAA amendments
Expert letter regarding strengthening federal impact assessment and regulatory efficiency, with recommendations on amendments to the Impact Assessment Act (2019) following the Supreme Court of Canada’s recent opinion on the constitutionality of the Impact Assessment Act. A majority of the Court identified four elements of the Act that require amendment in order to bring the Act into conformity with the Constitution. We believe that these amendments can be drafted in a way that largely preserves informed decision making and helps Canada contribute to sustainability and meet its climate and biodiversity targets.
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Joint Comment on the Implementation of the Fisheries Act - Cumulative Effects
We are writing to express our serious concerns with your department’s approach to implementing the amended Fisheries Act and addressing cumulative effects. Many of our organizations have previously written to you about these concerns and we therefore request a meeting with you to discuss this issue.
In 2019 Parliament established a specific mandate to address cumulative effects associated with regulations and decision-making under the Act. Unfortunately, DFO is failing to follow the new legal requirement to consider cumulative effects when making policies and regulations, resulting in the ongoing degradation of fish habitat in Canada.
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Joint Letter About Proposed Ontario Offsetting Policy ERO 019-6161
We, the 56 undersigned organizations, are deeply concerned about the proposed development of a natural heritage offsetting policy in the context of current major legislative and policy changes that are eroding environmental protections across the province (e.g. , changes to the Conservation Authorities Act, the Planning Act, and the Ontario Wetland Evaluation System, removal of lands from the Greenbelt). Although the Ministry of Natural Resources and Forestry (MNRF) is proposing a net-gain approach, decades of evidence suggest that even no net loss is rarely achieved through offsetting. We urge extreme caution should MNRF choose to proceed, and request that you strike an expert panel to advise on policy options and carry out full Indigenous and public consultation on the draft policy if and when it is developed.
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Joint Comment ERO - 019-6160 Proposed Update to the Ontario Wetland Evaluation System
We, the 70 undersigned organizations, are strongly opposed to the Ministry of Natural Resources and Forestry's (MNRF) proposed changes to the Ontario Wetland Evaluation System (OWES), as they would completely undermine the protection of wetlands in Ontario.
As you know, the OWES is a science-based ranking system that provides a standardized approach to determining the relative value of wetlands. OWES assessments are necessary to designate Provincially Significant Wetlands (PSWs). This designation in turn results in a high level of protection under provincial law and policy such as the Provincial Policy Statement (sections 2.1.4, 2.1.5 and 2.1.8). Yet the complete overhaul of the OWES, as proposed, will ensure that very few wetlands would be deemed provincially significant in the future and that many if not most existing PSWs could lose that designation. As a result, very few of Ontario's wetlands would benefit in the future from the protection that PSW designation currently provides. We urge you not to proceed with the proposed changes to the OWES, for the reasons outlined below.
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Joint Comment - Letter of Support to World Heritage Committee re: Wood Buffalo National Park 17 August 2022
As a group of fifteen Indigenous organizations and civil society organizations, we write to the leads of the IUCN/World Heritage Centre Reactive Monitoring Mission for Wood Buffalo National Park to express our collective concern with the deterioration of Outstanding Universal Values (OUV) of Wood Buffalo National Park World Heritage Site and express our agreement with decision 44 COM 7B.190 by the World Heritage Committee that the property likely meets the criteria for inscription on the List of World Heritage in Danger.
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