[All] Environmental Commissioner re: Waterloo Moraine/Galt Paris

[Louisette Lanteigne]

The Environmental Commissioner has released his annual report which covers his feedback regarding the Environmental Bill of Rights Request for Review to request a Waterloo Moraine and Galt Paris Moraine Act.

In the attachments are the specific references to the Waterloo Moraine as issued in the report as well as the summery report. For those who can't access PDF here's a breakdown of the key points made:

-Population growth may be appropriate where there is adequate access to water supplies. However, the long-term supply of potable water will be adversely affected by increased development and demand for water.

-MNR Models predict that by mid-century Southern Ontario will experience at least and average 2.5 degree Celsius warming in the summer with consequent increased evapotranspiration.

-The region expects to spend $826 million in the next 10 years in treatment upgrades and expansions to water and wastewater treatment.

-The City of Guelph Water Supply Master Plan indicates the need for additional ground and/or surface water supplies by 2017-2025. 

-Cambridge is examining the option of bedrock wells to meet it's water demands. 

-The MOE review did not consider items outside their mandate including the PPS 2005, the Greenbelt Plan, the Growth Plan nor did they include decisions made within the last 5 years  eg: Clean Water Act 2006, The Ontario Water Resource Act, Nutrient Management Act 2002, Environmental Assessment Act. Finally the ministry outlined that it's review would not affect current planning decisions.

-The report (MOE review) found the Region of Waterloo has been pro-active in water resource protection and has developed and extensive monitoring program and sub-watershed development plans. Nevertheless, no specific land-use controls have been proposed. 

-With respect to the Paris and Galt Moraines, MOE's report found that there was detailed data for developed areas of the moraines but insufficient detailed data for the majority of the moraines. 

-Gravel extraction in the area does not appear to have significant impacts on the groundwater flow systems or surface water and wetlands (re: Galt/Paris)

-Although not officially part of the review the (MOE) report found that the CWA, the PPS, the Greenbelt Plan and the OWRA provide adequate protection for groundwater recharge in the upper Grand River Watersheds and other watersheds. 

-MOE revealed that additional studies examining water supplies were being conducted and were expected to be completed in 2010. The report also stressed the continued need to analyze data and monitor and assess future growth implications.

-MOE committed to developing guidance materials to assist with the implementation of policies protecting hydrologic functions of the moraine.

ECO COMMENTS

-If the principles of watershed-based planning are applied, and the environmental and socio-economic context of the moraines are examined to assess the cumulative effects of development, the ECO believes that the current provincial policies do not adequately protect the ecological and hydrogeological integrity of moraines. 

-In our 2006-2007 Annual Report, which examined the challenges to creating sustainable communities in southern Ontario, the ECO found that "serious conflicts are inherent in the province's plans for balancing growth and ecosystem sustainability."

-The mandated use of a system-based approach - in contrast to the voluntary nature of the PPS - should ideally require the explicit prioritization of the ecological and hydrological integrity in land use planning.  For example, watersheds should be a key unit within land use planning in which to frame decision-making.

-Ecologically sustainable water management requires the protection of the integrity and resilience of the affected ecosystems while meeting the human needs for water.

-It (the MOE report) did not assess whether the ecological capacity of the moraines can realistically accommodate the projected growth in the region.

-interestingly, several models cited by the report indicate that the water capacity of the moraine's recharge areas decreased as the population increased.

-The population projections for Growth Plan communities were established before the future water and wastewater infrastructure was identified, and their associated costs and environment impacts, were assessed. This clearly indicates that provincial policies, such as the Growth Plan, favor economic development over sustainable planning processes. 

- Not only does the Growth Plan fail to require that population allocations be adjusted for communities with watersheds close to or already at carrying capacity, it favors large-scale infrastructure projects to overcome natural limits. Waterloo is proposing to address any futyure water shortages by constructing a pipe to Lake Erie to pump water in and out of the city.  Not only do infrastructure projects like these override natural ecological carrying capacity, they are also extremely costly and energy intensive, and as a sewage and water systems, ("infrastructure") they are exempt from natural heritage protections in the PPS and Greenbelt Plan despite their potential for significant environmental effects. 

-It is unlikely that every jurisdiction or level of government will have the same priorities. The resulting piecemeal approach to planning and protection can leave ecologically and hydrogeologically significant areas vulnerable or under protected, thereby compromising the entire landscape and the communities that rely on it. 

-A comprehensive system-based plan for natural heritage protection, as well as land use planning is clearly required to address such problems.

-Our past reviews reveal that they (Provincial planning laws) were ineffective in preventing, curtailing or modifying environmentally destructive developments. 

-Natural features such as large moraines should be the very basis at the outset, on which local land use planning decisions are weighed.  Yet the province does not specifically identify moraines as a landform or natural heritage feature to be considered for protection.

-On numerous occasions the MOE has asserted that it's planning system is adequate to protect significant environmental features. The ECO finds this assertion unconvincing given that the government has had to create several individual laws and policies to protect specific vulnerable ecosystems including the Oak Ridges Moraine, the Protected Country Side and Lake Simcoe. The province should acknowledge, as it did for the Oak Ridges Moraine, that these laws and policies on their own are inadequate to protect complex ecological features spanning several jurisdictions. 

-The province has the opportunity to make a strong commitment to ecosystems-based planning in Ontario. The PPS is under review. 

-MMAH should revise the PPS to require
 that diversity and connectivity of natural features, as well as their 
long-term ecological function, and biodiversity, be maintained and 
restored. This would improve planning in Ontario and help to ensure 
significant natural features are protected. 

RECOMMENDATION 14- The ECO recommends that the Ministry of Municipal Affairs and Housing amend the Provincial Policy Statement to require that long term ecological function and biodiversity of natural heritage systems are maintained. 

Lulu :0)
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