Canada-Ontario agreement on Great Lakes water quality and ecosystem health: the government of Canada's report on comments
Introduction
This document has been prepared by the Government of Canada, pursuant to Section 9 of the Canadian Environmental Protection Act, 1999, to acknowledge and provide a federal report on comments received during the comment period for the draft 2020 Canada-Ontario Agreement on Great Lakes Water Quality and Ecosystem Health (COA). The draft Agreement was made available on the Government of Canada’s website on July 5, 2019 and a notice of its availability was published in the Canada Gazette, Part I on July 6, 2019. Comments were accepted until September 4, 2019.
Input was received through written submissions, meetings as well as other correspondence related to the new Agreement from a wide cross-section of opinions, including individuals, environmental and other non-government organizations, industry representatives, municipalities, conservation authorities, Indigenous organizations and communities, and academia. Many of the comments received indicated support for the Agreement and the comprehensive set of issues addressed, including new areas of focus such as Lake Ontario nutrients, plastic pollution as well as wastewater and stormwater management. All comments received were reviewed and given due consideration. A list of commenters is provided in Appendix I.
Comments of relevance to the Government of Canada’s commitments in the Agreement, and accompanying Government of Canada responses, are described further below and are organized under the following headings:
A number of proposed editorial changes that enhanced context or clarified COA text have been accepted, but are generally not specified in this document. Comments received that were specific to Government of Ontario were noted but are not identified in this document.
| Summary of comment | Response |
|---|---|
Accountability / joint reporting Commenters recommended COA include additional accountability measures, as well as a commitment to transparent reporting of results from the implementation of the Agreement. Commenters recommended Canada and Ontario commit to joint reporting on progress under the Agreement (rather than separately), and do so through publicly available biannual reports that use a consistent set of measures and indicators of progress and success. |
The Government of Canada is committed to conducting its business in an open and accountable manner, including its implementation of COA. A commitment to joint COA progress reporting has been added to Article VII (Reporting) of the final Agreement. The Governments of Canada and Ontario will also continue to report on progress toward implementing COA as well as environmental status and trends through existing mechanisms, including the Progress Report of the Parties and the State of the Great Lakes Report, both of which are issued triennially under the Canada-United States Great Lakes Water Quality Agreement. |
Work plans A commenter recommended that COA ensure that the existing requirement for Annex Leads to follow 5-year work plans to guide COA implementation be maintained. |
COA contains specific commitments to be achieved within a 5-year time frame. Work plans will be developed, as appropriate, during the delivery of COA that will identify key actions along with their associated timelines that will be implemented to achieve commitments. The COA Executive Committee will ensure progress remains on track by holding federal and provincial agencies accountable for their contributions to COA commitments. |
Acknowledgement of Indigenous rights Commenters recommended COA acknowledge Indigenous governments as rights holders with decision-making power and as having a vital role in Agreement implementation. |
The Government of Canada recognizes the section 35 rights under the Constitution Act, 1982 of First Nations and Métis communities in the Great Lakes basin. Recognition of rights is acknowledged in a new recital:
Through COA, the Government of Canada has enhanced commitments to provide meaningful opportunities for First Nations and Métis communities to discuss, advise and participate directly in Great Lakes activities and priority setting, such as through more robust engagement related to Areas of Concern and the lakewide management process. |
COA priorities A commenter recommended that Canada and Ontario prioritize the completion of long-standing goals and commitments, such as eliminating combined sewage overflows and delisting Areas of Concern, in addition to addressing new COA priorities (e.g. plastics, salt and Lake Ontario nutrients). |
The Government of Canada recognizes that a broad range of challenges work individually and cumulatively to impact Great Lakes water quality and ecosystem health. Some are long-standing challenges, such as Areas of Concern and combined sewage overflows, which have been the focus of efforts by the federal government and its partners for several decades. Meanwhile, other challenges, such as plastic pollution, have been the subject of emerging concern in recent years. The Governments of Canada is committed to working with the Province of Ontario and other Great Lakes partners to make progress on the full range of issues. This will include significant progress on legacy issues, such as completing all actions to achieve delisting criteria and restore beneficial uses in an additional 6 Areas of Concern as well as improving the management of combined sewer overflows and stormwater. |
Ecosystem / watershed approach Commenters recommended that COA adopt an ecosystem / watershed approach in recognition of the connection between land use and water quality and ecological health. |
The ecosystem approach is a fundamental element of COA. The Agreement recognizes that Great Lakes water quality and ecosystem health cannot be achieved by addressing individual threats in isolation, but rather depend upon the application of an ecosystem approach that addresses individually and cumulatively all sources of stress to the Great Lakes. While the geographic parameters of COA is consistent with the Canada-United States Great Lakes Water Quality Agreement, which are limited to the waters of the Great Lakes, the Government of Canada will continue to work with the Great Lakes community through COA to strengthen the linkages between watershed-based planning and the process to develop and implement Lakewide Action and Management Plans. |
Protection of areas in good condition Commenters recommended that COA more strongly emphasize the protection and conservation of areas (e.g. Georgian Bay) in the Great Lakes that are in good condition, to prevent these areas from requiring restoration efforts in the future. A commenter recommended that volunteer organizations be provided with better tools under COA to improve the ability of their members to undertake prevention measures. |
COA includes commitments to both restore water quality and ecosystem health in areas of the Great Lakes requiring particular attention, as well as commitments to protect areas of the Great Lakes that are in good condition from potential threats. While the Agreement includes a number of targeted actions to clean up existing Areas of Concern in the Canadian Great Lakes basin, the Government of Canada recognizes the importance of protecting and conserving areas in good condition to ensure they do not become degraded over time. There is a web of environmental legislation, at both federal and provincial levels, including the Canadian Environmental Protection Act and the Fisheries Act, which prevent pollution and hold polluters accountable. These pieces of legislation will prevent the creation of new Areas of Concern in the future. As implementation of COA progresses, the Government of Canada will explore opportunities through the lakewide management process to improve volunteer organizations’ ability to undertake prevention measures. |
Measurable targets / accountability / reporting Commenters suggested that COA include goals / targets that are ambitious, time-bound and measurable. Commenters recommended that COA include accountability measures, such as a commitment to transparent reporting of results as well as an appendix detailing implementation mechanisms, targeted timelines and funding. A commenter suggested that Canada and Ontario set clear, simple, objective benchmarks that indicate Great Lakes health and then monitor and publicly share results. |
All COA results and commitments are time bounded and are expected to be achieved during the 5-year span of the Agreement. The Progress Report of the Parties and the State of the Great Lakes report, issued triennially under the Canada-United States Great Lakes Water Quality Agreement (GLWQA), are the federal mechanisms for reporting on progress both in terms of progress and environmental results. The State of the Great Lakes report assesses the health of the lakes against 9 clear, science-based indicators of ecosystem health that have been carefully selected by Canada, the United States and other GLWQA partners, including the Government of Ontario. The Government of Canada will continue to consider ways to improve this reporting over time. In addition to reporting on progress through existing mechanisms, the Governments of Canada and Ontario have also added a new commitment under Article VII (Reporting) to issue joint public COA progress reporting. In regards to funding to support Agreement implementation, Article III (Resources) ensures that departments and agencies responsible for delivering the Agreement will seek the resources required to implement commitments. Federal resources are currently in place, and federal departments responsible for implementing COA will seek additional resources as may be required to fully implement the Agreement over the longer term. |
Funding Commenters recommended COA include the specific funding that the federal and provincial governments will provide to implement commitments as well as ensure long-term funding for partners that help implement COA. Several commenters called on the federal government to include a $100 million per year investment in Great Lakes protection, consistent with the recommendation of the Great Lakes-St. Lawrence Collaborative. Commenters recommended COA include transparent reporting of funding commitments and actual expenditures. |
COA was negotiated based on existing resources. The Government of Canada is committed to providing the resources needed to implement the Agreement as well as creating opportunities for others to contribute resources to achieving the Purpose of the Agreement. Federal resources that support the implementation of COA are allocated through numerous national programs, such as the Chemicals Management Plan, the Canada Nature Fund and the Canadian Agricultural Partnership, that directly benefit the Great Lakes. Specific regional initiatives, such as the Great Lakes Protection Initiative, complement national programs and provide dedicated resources to deliver on Great Lakes priorities. Information on Great Lakes specific programming is made readily available; however, it is often exceedingly challenging to calculate the portion of national programs that specifically benefits Great Lakes restoration, conservation and protection. |
Green infrastructure Commenters recommended COA include a ‘consider green infrastructure first’ policy and ensure 15% of infrastructure funding support green infrastructure. |
The Government of Canada is investing $26.9 billion in green infrastructure as part of its $180 billion (over 12 years) long-term infrastructure plan, Investing in Canada. This funding will support projects that protect communities from the effects of a changing climate and provide communities with more reliable water and wastewater systems. In September 2016, the Governments of Canada and Ontario announced a bilateral agreement, making more than $1.1 billion in combined funding available under Investing in Canada to improve water and wastewater infrastructure across the province. Wastewater infrastructure funding will contribute to results under COA and the Canada-United States Great Lakes Water Quality Agreement, including reducing nutrients causing toxic and nuisance algae, and supporting healthy beaches. |
Data and information Commenters recommended data and information collected through COA be made publicly available. |
The Government of Canada is committed to improving the openness and quality of federal government data, including data collected as a result of COA implementation, by making all data available through the Open Government portal. Reference to data and information has been added to Article VI (Science). |
Governance Commenters recommended Canada and Ontario clarify how cross Ministerial coordination will be managed and how implementation of COA will be assured using a streamlined governance model. |
The COA Executive Committee will provide all essential management functions under the Agreement. Adjustments to the COA governance model were made to ensure that the management of the Agreement is streamlined and effective. |
Engagement and collaboration Commenters noted the importance of engaging and collaborating with partners to support implementation of COA commitments. Commenters noted contributions of Conservation Authorities, municipalities and others in implementing COA. Commenters recommended that COA include the participation of First Nations and Métis as well as provide support to ensure adequate First Nations and Métis capacity, stable funding and representation. Commenters raised the importance of public engagement. A commenter recommended COA include an outline of the public engagement process for future COAs and establish a public advisory body to provide an ongoing opportunity for the public to provide input and be engaged. |
Canada recognizes the important role of Great Lakes partners, such as Conservation Authorities, Indigenous communities, municipalities and others, in protecting watersheds and the waters of the Great Lakes and looks forward to continued collaboration through COA implementation. While COA is an administrative agreement between federal departments and provincial ministries, the Government of Canada remains committed to engaging with First Nations and Métis in a multitude of ways through COA implementation, such as through decision-making processes related to Areas of Concern and lakewide management, as well as through support for capacity building within Indigenous organizations and communities to address Great Lakes issues. There are existing public engagement opportunities and mechanisms under the Canada-United States Great Lakes Water Quality Agreement, such as annex sub-committees and the Great Lakes Executive Committee, which provide guidance on issues and priority setting. |
Water levels A commenter recommended that COA confirm the adequacy of the IJC’s tool to protect shoreline residents from water fluctuations so residents can take appropriate measures to protect their property. |
This issue falls beyond the scope of COA. |
Garbage A commenter recommended that fines should be levied against those dumping logs, leaves, tree limbs and other forms of waste/garbage into Lake Ontario and efforts should be made to clean creeks of garbage and wood. |
Fining for littering garbage and other waste is under municipal jurisdiction. The Governments of Canada and Ontario will consider cleanup activities through the Lakewide Action and Management Plans, as needed. |
Coastal wetlands Commenters recommended that COA should prioritize projects that enhance natural infrastructure, such as coastal wetlands, to capitalize on their direct contribution toward achieving COA’s purpose. |
The Government of Canada recognizes the importance of wetlands in providing critical habitat and other ecosystem services. Canada has set national targets to help achieve Aichi Biodiversity targets, such as:
In addition to national efforts, the Government of Canada is assessing the impact of climate and other changes on Great Lakes coastal wetlands, and enhancing the resilience of these wetlands by building consensus on priorities for action through the Great Lakes Protection Initiative. The Government of Canada is committed to continuing this work through the Agreement. |
Aquaculture A commenter recommended Canada and Ontario work together to phase out open net cage aquaculture operations in Georgian Bay and the North Channel and support their move into sustainable enclosed systems as well as cease support for the aquaculture industry. |
Net pen aquaculture on Public Lands is a legitimate recognized use of lake beds under the authority of the Government of Ontario (Ontario Lands Act subject to the issuance of an Aquaculture License under the Fish and Wildlife Conservation Act). Environment effects are managed by conditions on the Aquaculture License, and licenses require the monitoring and maintenance of water and sediment quality. There is no direct federal support of the net pen aquaculture sector. The net pen sector is eligible to apply to the Fisheries and Aquaculture Clean Technology Adoption Program, which has broad program objectives to reduce carbon emissions. Any operator in the fishing and/or aquaculture industry is eligible. For Indigenous aquaculture in the Central and Arctic Region of the Department of Fisheries and Oceans, which includes the Great Lakes, there is the Northern Integrated Commercial Fishing Initiative, to which Indigenous communities can apply for development of commercial fishing or aquaculture ventures. |
Responsibility to water Commenters emphasized the lack of acknowledgement of the distinctive relationship First Nations have with water and its cultural, spiritual and ceremonial importance in the draft COA, and recommended that due acknowledgement of this distinctive relationship be provided in COA. Commenters noted First Nations’ responsibilities related to water were established prior to contact with settler governments and that First Nations should contribute more fully to the processes and agreements upon which Great Lakes water governance, protection, restoration, and conservation are founded. |
The Government of Canada recognizes that First Nations in the Great Lakes basin have a distinctive relationship with water and consider the Great Lakes to hold significant spiritual and cultural value. In order to recognize this distinctive relationship, a new recital has been added to the Agreement:
A new recital has been added to recognize the adoption of a Water Declaration by First Nations in Ontario, to further underscore the importance of water to First Nations communities:
Through the Agreement, the Parties seek to work together with First Nations on a good governance basis on a wide range of environmental protection issues, including through decision-making processes. Together with First Nations, Canada and Ontario are committed to developing and implementing processes to engage with First Nations in decision-making as it relates to Areas of Concern and lakewide management. Additionally, a new commitment has been added to “invite First Nations representatives to participate in COA Executive Committee meetings”, to enhance engagement with First Nations in decision-making in the COA context. |
Nation-to-Nation relationship Commenters highlighted the importance of the nation-to-nation relationship, and recommended that COA recognize First Nations’ historical role within the Great Lakes area and the Crown’s obligations and responsibilities as it relates to treaty and Aboriginal rights. Commenters recommended Canada and Ontario move beyond engagement to true partnership with First Nations to better work on joint priority issues related to water, and as a way to realize the nation-to-nation relationship in the COA context. |
The Government of Canada is committed to advancing reconciliation and renewing the relationship with Indigenous Peoples, based on recognition of rights, respect, cooperation and partnership. A new recital has been added to the draft Agreement to acknowledge this commitment:
The Government of Canada is also committed to the implementation of UNDRIP, and has acknowledged this commitment through a new recital:
In order to enhance the partnership with First Nations in the Great Lakes, and enhance engagement with First Nations in decision-making in the COA context, Canada and Ontario have added a new commitment in the First Nations Annex to “invite First Nations representatives to participate in COA Executive Committee meetings”, in addition to the commitments to enhance engagement with First Nations in decision-making related to Areas of Concern and lakewide management. |
Traditional Ecological Knowledge (TEK) Commenters highlighted the lack of recognition and implementation of TEK in decision-making. Commenters recommended TEK be consistently applied throughout COA with direct and explicit guidance from First Nations. Commenters emphasized the lack of capacity and stable funding available to First Nations to adequately cultivate and apply TEK to the benefit of their community or articulate it in a manner that can be shared publicly. |
Canada recognizes the contribution Traditional Ecological Knowledge (TEK) can have in efforts to restore, protect and conserve the Great Lakes. This is acknowledged in a revised recital:
Further, the Parties have revised Article VI (Science) to add acknowledgment of the importance of TEK, and governments’ commitment to consider this knowledge, when offered, in Great Lakes decision-making. COA is negotiated based on existing resources. The Government of Canada provides funding through the Great Lakes Protection Initiative to support First Nations’ capacity building to address Great Lakes issues, and community projects and initiatives. TEK-related projects are eligible under the Great Lakes Protection Initiative, and recognition of eligibility of TEK projects has been added to the applicable commitments in the First Nations Annex. In recognition of the important contribution of TEK, when offered, to the understanding of Great Lakes issues, reference to TEK has been included in commitments in the First Nations Annex regarding engagement with First Nations in decision-making related to Areas of Concern and lakewide management. |
| Summary of comment | Response |
|---|---|
Article I - definitions A commenter recommended adding a clear definition for “Salts” to COA. |
A definition for road salts, consistent with the Government of Canada’s Code of Practice for the Environmental Management of Road Salts, has been added to COA. |
A commenter recommended adding a definition for nuisance algae to focus efforts on nutrient reduction. |
A definition for nuisance algae blooms, consistent with the Canada-Ontario Lake Erie Action Plan, has been added to COA. |
Commenters recommended that COA include additional definitions for terms such as biodiversity, ecological integrity, sustainable development, watershed management, protect, restore and preserve. |
While some of the terms (e.g. biodiversity, restore, protect) suggested for inclusion do appear in COA, those terms are generally understood amongst the Great Lakes community within the context of the Agreement. Other terms, including ecological integrity, sustainable development, watershed management and preserve, do not appear in COA and therefore, do not warrant the addition of definitions. |
Article III - principles A commenter recommended that the Precautionary Principle should include definitions for “serious threat” and “irreversible Environmental Damage”. |
The definition used for precautionary principle is consistent with the Canada-United States Great Lakes Water Quality Agreement. Use of a high level definition will ensure flexibility when the Parties wish to invoke the precautionary principle. |
Article VII - reporting A commenter recommended revising the draft COA to indicate that the COA Executive Committee will be:
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The Government of Canada is committed to an open and accountable government, including through its implementation of COA. Clarification regarding the COA Executive Committee’s responsibility for reporting has been provided in Article V (Administration of the Agreement). In order to deliver meaningful reporting to the public, the Governments of Canada and Ontario have added a commitment to report jointly on COA progress, as well as continue to report under existing mechanisms, such as the Canada-United States Great Lakes Water Quality Agreement. |
A commenter recommended that revisions be made to reflect that the COA Executive Committee is tasked with developing a method to nominate and select Priority Watersheds as well as determine key indicators to track conditions in those watersheds and recommend actions. |
Priority watersheds are established under and addressed through the Canada-United States Great Lakes Water Quality Agreement as well as the Canada-Ontario Lake Erie Action Plan for the purposes of addressing nearshore algae. |
| Summary of comment | Response |
|---|---|
Preamble A commenter recommended adding text to the preamble highlighting the agencies’ work with partners, such as municipalities and conservation authorities, to develop watershed plans for key priority watersheds as a means of identifying science-based local level actions required to reduce the risk of excess nutrients, and wastewater and stormwater pollution. |
As stated in COA, the Government of Canada is committed to working with the Great Lakes community to work towards the long-term goal of attaining sustainable use of nutrients to support a healthy and productive Great Lakes ecosystem and economy, including through the development and implementation of phosphorus management plans. |
Phosphorus management plans Commenters recommended that COA specify the timelines and targets for priority Lake Erie watershed phosphorus management plans. A commenter highlighted that Conservation Authorities have existing resources to support these results, therefore there may not be a need to initiate development of watershed models / sub-watershed research / phosphorus management plans to support decision making but rather these existing resources should be identified, supported, and leveraged. |
A timeline of 2022 for the development of phosphorus management plans for Lake Erie priority watersheds has been added to COA. The Government of Canada recognizes the important role conservation authorities play in managing phosphorus inputs to the Great Lakes. The Government of Canada works closely with conservation authorities in the priority watersheds of Lake Erie to develop phosphorus management plans that identify the most effective actions for reducing inputs from those landscapes and promote their widespread uptake and application through engagement activities. The Government of Canada will continue to explore opportunities to maximize its partnerships through the implementation of the Agreement. |
Achieving Lake Erie targets A commenter expressed support for the inclusion of commitments under Result 1 acknowledging the need for plans to achieve the desired goal of implementing the Lake Erie Action Plan. |
The Government of Canada is committed to taking action to address excess nutrients in Lake Erie and is fully implementing federal actions in the Canada-Ontario Lake Erie Action Plan. |
Demonstration projects A commenter noted that demonstration projects are very important for encouraging uptake of best management practices and would like these projects to continue to be supported. |
The Government of Canada supports demonstration projects as an important driver for broadening the uptake and application of best management practices that help to reduce excess phosphorus inputs to the Great Lakes, particularly Lake Erie. |
Support for existing effective approaches A commenter recommended that in addition to support for ‘innovative approaches and technologies’, there needs to be support for widely effective and practical approaches and technologies (with goal of broad long-term uptake of best practices for long-term Lake improvement). |
While the Government of Canada is supportive of new and innovative approaches and technologies aimed at reducing excess phosphorus inputs to Lake Erie, it also recognizes that broader uptake and application of proven best management practices is also beneficial for improving algal conditions. |
St. Lawrence River A commenter stated that Lake Ontario and the Upper St. Lawrence River water quality are intimately connected with unique nearshore processes affecting both the Lake and the River. They advised that the St. Lawrence River should be specifically identified in the initiatives on Nutrients. |
Specific connecting channels and tributaries have not been referenced in the Nutrients Annex. If the St. Lawrence River is found to be experiencing acute eutrophication issues, it will be considered in the development of a Canadian Nutrients Strategy for Lake Ontario. |
Lake monitoring Regarding the Canada and Ontario commitment to conduct long-term in-lake monitoring to track water quality and algal conditions, a commenter recommended the addition of microcystin to commitment, which is indicative of levels of cyanobacteria that pose major threats to source drinking water. |
The Government of Canada recognizes the threat microcystin poses to Great Lakes water quality and has included a federal commitment under the Agreement to conduct long-term in-lake monitoring programs that track algal communities and associated toxins for Lakes Erie and Ontario. |
A commenter suggested that long-term lake monitoring should include monitoring surveys for algae and nutrients along shorelines, particularly in urban areas, to help spatially assess the relative contribution of stormwater (non-point discharges), tributaries and off-shore point source discharges (e.g. wastewater treatment plan effluents) on nearshore algal blooms and provide insight on where nutrient reductions can be applied to achieve the greatest benefit. A commenter recommended more monitoring to determine whether additional targets are required or appropriate for Lake Erie tributaries and its eastern basin. |
The Government of Canada is conducting long-term lake monitoring through targeted sampling coupled with watershed-lake modeling approaches. Known inputs of nutrients to nearshore areas, such as tributaries, stormwater outfalls, and point source discharges are considered in these modeling efforts. Provincial monitoring programs also capture nearshore surveys. The Governments of Canada and Ontario are committed to conducting necessary research and monitoring to determine whether additional Lake Erie targets are required or appropriate, including for the Eastern Basin. |
Lake Ontario Nutrients Strategy A commenter recommended a Lake Ontario Nutrients Strategy consider scientific data and knowledge from Lake Michigan; future actions that balance the positive impacts of reducing benthic algae beds in the nearshore and potential negative impacts in the offshore; load reduction targets for specific locations and sources that contribute the highest loadings; and, local circumstances as well as municipal considerations. |
As the implementation of COA progresses, the Government of Canada will give full consideration to the most relevant scientific information available as well as other factors, such as local circumstances, as it works with the Government of Ontario to develop a Canadian Nutrients Strategy for Lake Ontario. |
Agricultural management A commenter recommended that Canada and Ontario consider agricultural management to be essential to reducing phosphorus loads, as opposed to increasing stringency on municipal wastewater plants. A commenter recommended that phosphorus run-off be managed through increasingly stringent and enforceable policies, and not be reliant on voluntary measures. A commenter recommended COA include meaningful education for businesses and farms that spread nutrients. |
The significance of excess nutrients inputs from agricultural and urban sources varies by watershed and lake. Future measures to further reduce phosphorus inputs from individual wastewater treatment plants should be considered in this context. The Canada-United States Great Lakes Water Quality Agreement establishes treatment plant discharge concentrations of 0.5 mg/l for wastewater treatment plants discharging 1 million liters per day or more to Lakes Erie and Ontario and 1 mg/l for Lakes Superior and Huron. The Government of Canada and its partners will continue to assess the effectiveness of this approach and consider adjusting discharge concentration limits, as necessary. In terms of addressing excess phosphorus inputs from agricultural lands to Lake Erie, there are several measures underway to manage the application of nutrients and improve runoff water quality through the implementation of the Canada-Ontario Lake Erie Action Plan. The Government of Ontario has primary legislative jurisdiction over soil and water and is responsible for the regulation of their use. The Government of Canada is committed to continuing its collaboration with Ontario to research and develop innovative approaches and technologies, and investigate the efficacy of agricultural best management practices for improved nutrient, soil, and water management in agricultural production through COA implementation. One of the priority areas for funding under the Government of Canada’s Great Lakes Protection Initiative is to demonstrate innovative approaches and best management practices for reducing phosphorus loading to Lake Erie and to promote their broad uptake and application by others, including the agricultural sector. Meaningful engagement of the agricultural sector is also supported through cost-shared programming under the federal-provincial Canadian Agricultural Partnership, which is delivered by the Government Ontario, as stated in COA. |
Funding A commenter recommended Canada and Ontario provide investments in nutrient related research and monitoring, green infrastructure, wastewater technologies and facilities upgrades as well as improvements in urban and rural land use and land management practices. |
Through COA, the Governments of Canada and Ontario have made a number of commitments to conduct science and take action on the issue of nuisance and harmful algae blooms in Lakes Erie and Ontario, as well as commitments to promote eligible investments that will help reduce excess nutrient loadings from both point and non-point sources. While COA is negotiated based on existing resource levels, the Government of Canada is committed to exploring all options to address the problem of nuisance and harmful algae blooms. |
Action in all Great Lakes required Commenters recommended that commitments related to the monitoring of water quality and algal conditions be made applicable to all Great Lakes, rather than be limited to Lakes Erie and Ontario. |
The Government of Canada is committed to continued scientific research and monitoring of Great Lakes water quality and algal conditions. The current approach is to focus available resources on Lakes Erie and Ontario, which are the areas of greatest risk in the basin. |
Science Commenters recommended that COA support methods to better track non-point sources of nutrients and determine how these inputs interact with other conditions on algal growth. |
The Government of Canada works with the Government of Ontario through the Canada-Ontario Lake Erie Action Plan (LEAP) to conduct science that tracks non-point sources of nutrients to the lake. For more information on these methods, please refer to the LEAP. |
Action to reduce nutrient pollution Commenters recommended COA emphasize actions to address non-point sources of nutrient pollution to achieve targets as well as introduce nutrient trading or offsetting to create a market-mechanism to maximize nutrient reductions per dollar spent. A commenter recommended that COA include a commitment to identify priority sub-watersheds and properties contributing a greater share of phosphorus and to provide funding to support actions to reduce phosphorus losses from these areas. A commenter recommended Canada and Ontario employ precision conservation and stormwater optimization, to bridge the gap between farm scale conservation implementation and urban stormwater management with broader water quality impacts in the Great Lakes. |
Details of the actions that the Government of Canada, the Government of Ontario and other partners are taking to reduce non-point sources of phosphorus loading to Lake Erie are provided in the Canada-Ontario Lake Erie Action Plan (LEAP). The Government of Canada is committed to exploring all options to address the issue of nuisance and harmful algae blooms. Nutrient trading is 1 of many policy tools that may be considered in the future. The concepts of identifying priority sub-watersheds and providing funding to support actions to reduce phosphorus inputs from these areas are captured broadly in COA and the LEAP, and will be considered through their implementation. COA is negotiated based on existing resources; however, the Government of Canada is committed to exploring all options to address the problem of nuisance and harmful algae blooms. Though not specifically described as precision conservation, efforts are being made to identify and target high phosphorus contributing areas through the implementation of the LEAP. |
Data management strategy A commenter recommended Canada support Ontario in developing a data management strategy and GIS-based tools to support precision conservation and to facilitate the collection and use of datasets needed to prioritize properties and best practices and to coordinate monitoring and modelling data at a watershed level. |
The Government of Canada is committed to exploring all options to address the problem of nuisance and harmful algae blooms, including approaches for collecting and managing relevant data and information. |
Centre for Water Quality and Nutrient Management A commenter recommended Canada and Ontario work with partners to create a Centre for Water Quality and Nutrient Management to generate and coordinate information to support precision conservation and stormwater optimization approaches in the Great Lakes Basin. |
The Government of Canada is committed to exploring all options to address the problem of nuisance and harmful algae blooms, including approaches for collecting and managing relevant data and information. |
Coordination of Nutrients Annex efforts A commenter recommended that COA clarify how the Lake Erie Action Plan (LEAP) will be coordinated and implemented as well as how cross-Ministerial efforts for a Lake Ontario process will be coordinated in the absence of the COA Management Committee. |
The Canada-Ontario Lake Erie Action Plan (LEAP) sets out how actions to address the issue of nuisance and harmful algae blooms will be coordinated and implemented. The LEAP builds on previous levels of coordination by clarifying roles and responsibilities and by strengthening the effectiveness of existing committees and other governance structures, including those that exist under the Canada-United States Great Lakes Water Quality Agreement and COA. Similarly, cross-Ministerial efforts for a Lake Ontario process will be coordinated through existing committees and governance structures established through the Canada-United States Great Lakes Water Quality Agreement and COA. |
| Summary of comment | Response |
|---|---|
Reducing / eliminating release of COCs A commenter recommended Canada and Ontario consider amendments to legislation to better enable citizens to take legal action for damages caused by violations of laws and regulations aimed at controlling pollutants. |
Following its Parliamentary review of the Canadian Environmental Protection Act, 1999 (CEPA), the House of Commons Standing Committee on Environment and Sustainable Development (Committee), issued its report Healthy Environment, Healthy Canadians, Healthy Economy: Strengthening the Canadian Environmental Protection Act in June 2017. In this report, the Committee made several recommendations with respect to environmental protection actions under CEPA (see recommendations 30-34). Environmental protection actions enable citizens to participate in the enforcement of CEPA by bringing a suit against a person who is alleged to have committed an offence under the Act if it meets certain preconditions. The Committee made recommendations to change the environmental protection action regime by lowering the barriers to bringing an environmental protection action; introducing rules and procedures to protect individuals who bring an environmental protection action from personally suffering damages; specifying the circumstances under which an environmental protection action may be brought; and, codifying safeguards against actions that are duplicative of government enforcement actions, frivolous, vexatious or otherwise brought in bad faith. The Government of Canada stated in its June 2018 response that the recommended legislative changes could fundamentally alter the way CEPA is enforced, changing the balance between civil and governmental enforcement. The Government of Canada committed to addressing these recommendations as part of its broader review of environmental enforcement legislation. |
A commenter recommended Canada commit to delivering compliance promotion and enforcement actions, as appropriate, to prevent and control pollution, including increasing penalties and fines to industry to ensure that the cost of non-compliance substantially exceeds the costs savings from continuing to pollute. |
The sentencing provisions and fine regimes of the Canadian Environmental Protection Act, 1999 (CEPA) and 8 other Acts, including the International River Improvements Act, were strengthened in 2009. One of the new requirements added was for courts to order, in addition to the standard fine for an offence, a fine equal to any benefit, advantage or property gained as a result of the environmental offence. Another requirement was added to review specific fines and sentencing provisions in each of the Acts after 10 years. The intent is to ensure that penalties and fines continue to align with the objectives set forth in legislation, deter future offences, denounce unlawful conduct and reinforce the “polluter pays” principle. The Government of Canada’s Minister of Environment and Climate Change is required to initiate the first series of these reviews in 2020 and table a report by the end of 2021. |
A commenter recommended Canada commit to providing financial incentives to support industry’s development and implementation of innovative approaches and best practices. |
The Government of Canada provides support to industry for the development and implementation of innovative approaches and best practices. Funding opportunities are available through Innovation, Science and Economic Development Canada. |
Plastics / microplastics / flushables Commenters submitted a variety of recommendations on plastics, microplastics and flushables, including:
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COA is consistent with the Government of Canada’s comprehensive agenda to reduce plastic waste and pollution nationally, and move toward its vision of zero plastic waste by 2030. Through the Ocean Plastics Charter, Canada has adopted plastic-specific targets including working with industry to recycle and reuse at least 55% of plastic packaging by 2030 and recover 100% of all plastics by 2040. This is complemented by the Canada-wide aspirational waste targets to reduce the amount of all waste that Canadians send to disposal by 50% by 2040. In June 2019, the Government of Canada committed to ban harmful single-use plastics, where warranted and based on science, and to take other actions to reduce plastic waste. In February 2020, a draft Science Assessment on Plastic Pollution was published for public comment. This assessment found that action is needed to reduce plastics that end up in the environment. The public comment period on the assessment closed on May 1, 2020. The development of any regulatory measures will consider and seek a balance among a range of elements including the lessons from COVID-19, the latest science evidence and other socio-economic factors. Canadians will be given the opportunity to participate meaningfully in informing any measures taken. Through the Canadian Plastic Innovation Challenge, the federal government is investing nearly $19 million to support Canadian innovators and small businesses to develop solutions for plastics challenges. The government is also investing in science, community solutions and the prevention and retrieval of lost fishing and aquaculture gear. The Government of Canada is working with provinces and territories to implement the Canada-wide Strategy on Zero Plastic Waste. Actions include establishing consistent extended producer responsibility programs; providing support for innovations and infrastructure to better manage plastics; increasing the responsible use and recycling of single-use products; facilitating greening government operations and purchasing; and, developing standards for recycled content in plastic products and bio-based plastic products. With regards to flushable products, the Government of Canada understands the issue it may present for some municipalities and other members of the Great Lakes community. The Competition Bureau administers and enforces the Consumer Packaging and Labelling Act and the Competition Act, which contain provisions to address false or misleading representations made to the public in advertising or promoting products. The Competition Bureau may open an inquiry if there are grounds to believe that unlawful conduct has taken place under 1 of these laws, including performance claims based on inadequate testing. The Government of Canada, through the Competition Bureau, continues to explore policy levers at its disposal. It has followed with some interest the ongoing efforts toward standards development within organizations such as the International Water Services Flushability Group, as well as the findings of academic studies on this topic. These efforts can play a critical role in filling data gaps related to products under evaluation during the course of any possible future deliberation or investigation. |
Mixtures Commenter recommended that Canada take the next steps to address exposure to mixtures of chemicals and that Canada improve its engagement with affected communities. |
Addressing exposure to mixtures of chemicals is currently a proposed focus area under the visioning for Canada’s Chemicals Management Plan Post 2020. |
Targeted monitoring of environmental and human health A commenter recommended that Environment and Climate Change Canada (ECCC) and Health Canada (HC) develop a targeted environmental and human health effects monitoring, human biomonitoring and surveillance program to provide early detection of unexpected effects in the Great Lakes basin that feeds directly into a regulatory and non-regulatory response plan to reduce exposure. It was also recommended ECCC and HC develop guidelines to generate and communicate data collected through this program as well as guidance on the appropriate response to exposure and effects. It was further recommended ECCC and HC introduce a Strategy to Promote Substitution of Harmful Chemicals in Products, including a Centre for Chemical Substitution, and a Chemical Substitution Recognition Program. |
COA is negotiated based on existing resources and programming. Additional science resources for Canada’s Chemicals Management Plan would be required in order to investigate the need for designating the Great Lakes as an environmental hot spot requiring a targeted environmental and human health effects monitoring, human biomonitoring and surveillance program. |
Emerging contaminants A commenter recommended attention be given to monitoring emerging contaminants, such as endocrine disrupters. |
COA includes commitments to monitor emerging contaminants, including commitments to monitoring to provide early warning for chemicals that could become chemicals of concern, as well as to advancing research surveillance and monitoring activities on microplastics, including sources. |
Chloride A commenter recommended that Canada and Ontario continue to consult the Great Lakes-St. Lawrence community on initiatives to address chloride as a harmful pollutant, including certification programs, and to extend urban programs to rural areas in the Basin. |
The Code of Practice for the Environmental Management of Road Salts is the Government of Canada’s primary mechanism through which it works with partners to support the application of chloride salts in a manner that promotes environmental protection while maintaining roadway safety. The Government of Canada will consider further opportunities for the engagement of the Great Lakes community on matters related to chloride salts during the implementation of COA. |
Research A commenter recommended Canada and Ontario partner with / support research by private, not-for-profit institutes and academia to develop knowledge on the interactive, long-term impacts of Chemicals of Concern on ecosystem health. |
As stated in COA, the Governments of Canada and Ontario have committed to cooperatively undertaking research, surveillance and monitoring activities to improve scientific knowledge on chemicals of concern and their potential impacts. |
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Funding Commenters submitted a variety of recommendations urging Canada and Ontario to provide significant investments to address wastewater and stormwater issues, including investments to support:
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COA is negotiated based on existing resources and programming. The Government of Canada provides infrastructure funding through the Investing in Canada infrastructure program. As established in the integrated bilateral agreement with the Government of Ontario under this program, funding is available to support public infrastructure projects that result in increased capacity to treat and manage water and wastewater. Projects may include enhancing natural infrastructure, as well as upgrading water and wastewater infrastructure. In addition, as stated in COA, formula-based funding is also available under the Ontario Community Infrastructure Fund to help small, rural and northern communities build and repair core infrastructure, including wastewater and stormwater systems. |
Collaboration with municipalities and others Commenters recommended that Canada and Ontario work with municipalities, Conservation Authorities and others on actions to implement commitments in the Annex as well as to conduct research and develop innovative best practices. |
The Government of Canada looks forward to continuing its work with municipalities, conservation authorities and others in the Great Lakes community to implement commitments of the Agreement. |
Climate change A commenter recommended that COA specify that climate change is not only exacerbating the adverse effects of wastewater and stormwater pollution, but is also causing an increase in this pollution (especially raw and partially treated sewage discharges) due to increasing precipitation intensity. |
The preamble to the Climate Change Impacts and Resilience Annex (Annex 10) notes that the impacts of climate change, such as changing precipitation patterns and extreme weather events, pose significant threats to the Great Lakes including implications for water quality and ecosystem functions. |
Road salt Commenters recommended that COA support training and education on best practices and innovative approaches, including those related to the application of road salt. A commenter recommended that Canada and Ontario invite third party contractors, who generally do not report on road salt usage, to the table to discuss and encourage reporting. A commenter recommended that federal, provincial and municipal authorities work together to address impacts of road salt, including through improvements to winter road salting approaches; the development and implementation of national / provincial guidelines, policies or best practices; and, collaboration with salt makers to study the possibility of new formulas and technologies. Commenters recommended that COA include a commitment to researching and funding the evaluation of cost-effective road salt alternatives. |
As stated in COA, the Government of Canada is committed to working with road organizations, municipalities, conservation authorities and other partners to promote salt application best management practices for road organizations subject to Canada’s Code of Practice for the Environmental Management of Road Salts. The Code of Practice was developed to assist municipalities and other road authorities with best practices to manage the use of road salts in a way that reduces the harm they may cause to the environment while ensuring roadway safety. The Code of Practice encourages the use of best practices for salt storage, application and snow disposal, as well as annual reporting to Environment and Climate Change Canada. Contractors that meet the usage threshold of 500 tonnes per year of salt application to public roads are encouraged to report through the Code of Practice. Environment and Climate Change Canada is currently seeking data to determine the scope of road salt use by others. The Government of Canada does not recommend or endorse the use of specific de-icing products as local authorities are best placed to determine how these practices could be implemented in their regions to maintain road safety. |
Nutrients A commenter recommended that Canada and Ontario consider phosphorus offsetting or trading to maximize phosphorus reduction per dollar spent. A commenter recommended that any baseline control measures developed to evaluate future nutrient control measures also take into consideration wastewater treatment plant performance and not merely take a blanket approach to reductions based on an overall baseline. |
The Government of Canada is committed to exploring all options to address the problem of nuisance and harmful algae blooms. Phosphorus trading and other policy tools may be considered through the implementation of the Agreement. Baseline data is used to understand individual wastewater treatment plant effluent and monitor changes over time. Each individual plant will have a different baseline based on their individual performance. Opportunities for control measures will automatically take into account plant performance. Both baseline data and current plant performance will be required to detect trends over time and to develop and implement future control measures. |
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Ballast Water Regulations A commenter recommended improvements to ballast water regulations including increasing inspections and ecological sampling, enhancing and implementing sterilization procedures and biosecurity protocols, implementing fines and considering all potential sources of aquatic invasive species (e.g. cruise ship industry). A commenter recommended the alignment of provincial, state and federal regulations and research, noting any compatible regulation between the U.S. and Canada must align with the basic premise that it is the discharge of ballast water into their own waters that should be regulated by each country, not loading. The commenter recommends that a binational process seeking a compatible / environmentally protective regulation for discharges from vessels be reasonable, equitable and achievable. |
The Government of Canada’s proposed ‘Ballast Water Regulations’ were posted in the Canada Gazette Part I on June 8, 2019. Comments on the proposed Regulations were invited during the 90-day consultation period and interested parties were able to submit comment until September 5, 2019. Comments submitted through the Canada Gazette Part 1 consultation process on the proposed Ballast Water Regulations are currently being considered. |
Hamilton Harbour A commenter recommended actions that could help reduce exhaust from vessels and vehicles in and around Hamilton Harbour, including banning the use of ‘dirty’ fuel in vessels that causes polluting exhaust and allowing faster ship speeds to reduce vessel and vehicle exhaust. The commenter also recommended addressing the issue of floating debris being dumped by vessels. |
Exhaust pollution and dumping are regulated by through Government of Canada through Transport Canada under the authority of Part 9 of Canada Shipping Act, 2001 and the Vessel Pollution and Dangerous Chemicals Regulations. These regulations set requirements for the control of emissions and the discharge of garbage, including cargo residues. The Burlington Canal Regulations set the speed limit for vessels transiting in the Canal. |
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Coordination and cooperation Commenters recommended COA include additional opportunities to collaborate with municipalities. A commenter recommended that Canada and Ontario advance remediation of AOCs through informed, effective collaboration amongst governments, communities, First Nations, and individuals. |
The Government of Canada looks forward to continued collaboration with the Great Lakes community through the implementation of the Agreement. Through COA, the Governments of Canada and Ontario are committed to undertaking a process to engage communities, local governments, First Nations, Métis and the public in remediation and decision-making related to Areas of Concern. |
A commenter recommended Canada and Ontario work with First Nations on developing a decision-making process related to AOCs prior to signing the new COA. Commenters recommended reforming the process to delist AOCs to address issues of concern to First Nations, such as governance, Traditional Ecological Knowledge and capacity. |
The Government of Canada recognizes the need to engage with First Nations in efforts related to Areas of Concern. Through COA, the Governments of Canada and Ontario have committed to working together with First Nations to develop and implement a process to engage with First Nations on the remediation of Areas of Concern and related decision-making processes. To fulfill this commitment, First Nations within each of the remaining Canadian Area of Concern will be engaged in the development and delivery of this process. |
Toronto and region AOC A commenter recommended a commitment could be for the Toronto Remedial Action Plan team and Aquatic Habitat Toronto to provide financial and technical support to priority actions to advance progress towards achievement of delisting criteria for Loss of Fish and Wildlife Habitat and Degradation of Fish and Wildlife Populations. The commenter further noted that the Ashbridge’s Bay Treatment Plant upgrades will be an additional key action for addressing the beach closures and eutrophication BUIs. |
The Government of Canada is committed to working with the Government of Ontario and local partners in order to make significant progress on restoring water quality and ecosystem health in the Toronto and Region Area of Concern within the timeframe of the Agreement. As stated in COA, the Governments of Canada and Ontario are committed to providing technical and financial support for habitat restoration projects to improve fish and wildlife habitat and restore fish populations to achieve delisting criteria. The Government of Canada has added to the Agreement recognition of the Ashbridges Bay Treatment Plant upgrades, given the project’s role in contributing to addressing the beach closures and eutrophication and undesirable algae beneficial use impairments. |
A commenter noted the new COA provides an opportunity for Canada and Ontario to collaborate with Toronto by providing financial support to accelerate the completion of the Don River and Central Waterfront Project (DRCW) by 2030 (current planned completion date is 2038). When completed, the DRCW will achieve significant reductions in combined sewer overflows (CSOs) and significant water quality improvement in Toronto's Don River and central waterfront. This will ultimately lead to the delisting of the Toronto AOC, co-benefit results in other COA annexes (e.g. Annexes 1, 2, 3, 6, 8), and support waterfront revitalization. |
The Government of Canada recognizes the contribution the Don River and Central Waterfront Project will make towards reducing combined sewer overflows, improving water quality and achieving delisting criteria for the beach closings and eutrophication or undesirable algae beneficial use impairments. Since COA is negotiated based on existing resources and programming, the Government of Canada cannot commit to providing financial resources to accelerate the completion of this project, but has committed to continued promotion of funding for this project. |
A commenter recommended stronger commitments by Canada and Ontario to restore BUIs to delist the Toronto and Region AOC (similar to ones for the Hamilton AOC). These commitments should identify funding support for municipal infrastructure projects such as the DRCW that address CSOs as a primary source of pollution and impairment of water quality and beneficial uses in the Toronto AOC. The commenter recommended:
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In recognition of the contribution the Don River and Central Waterfront Project will have towards the achievement of delisting criteria in the Toronto and Region Area of Concern, the Governments of Canada and Ontario have added a specific reference to the project within COA, including a commitment to continue promoting funding for the project. |
A commenter recommended COA expand sewage debris cleanup programs in the Toronto Harbour, pending completion of infrastructure upgrades that eliminate sewage spills in the area. A commenter recommended the opening of beaches to help Toronto’s population connect with the lake, restoring the number of recreational water areas in the city to at least 25. |
The Governments of Canada and Ontario have supported significant work with local partners to achieve delisting criteria for the previous aesthetics beneficial use impairment in the Toronto and Region Area of Concern. Activities to reduce sewage debris in Toronto are ongoing by local stakeholders. While the Government of Canada continues to work with partners to address the issue of beach closings in the Toronto and Region Area of Concern, decisions regarding the opening of public beaches and recreational water areas rests with municipal governments. |
St. Lawrence River AOC A commenter recommended Canada and Ontario specifically commit to ensure consistent communication with their US counterparts on actions and activities to be undertaken in binational AOCs. |
The Government of Canada works in close collaboration with the Government of the United States to make progress toward the restoration of water quality and ecosystem health in binational Areas of Concern. In response to this comment, the Governments of Canada and Ontario have added commitments in COA to communicate as needed with federal and state agencies of the United States on matters that advance restoration and delisting of binational Areas of Concern. |
Severn Sound A commenter requested funding be re-established to ensure the continuation of the commitment to ongoing monitoring in the delisting agreement / Stage 3 Report Severn Sound. |
The Government of Canada will consider the need for monitoring in Severn Sound through the lakewide management process. |
General Commenters recommended maintaining an ongoing commitment to delisting Areas of Concern (AOCs) as well as to monitoring, community engagement and maintenance following delisting. |
The Government of Canada remains committed to the delisting of remaining Canadian and binational Areas of Concern. Within the timeframe of this Agreement, the Governments of Canada and Ontario have committed to complete all actions required to achieve delisting criteria and restore beneficial uses in the Nipigon Bay, Peninsula Harbour, Niagara River, Port Hope Harbour, Bay of Quinte and St. Lawrence River Areas of Concern; continue to make progress in the Thunder Bay, St. Marys River, St. Clair River, Detroit River, Hamilton Harbour, and Toronto and Region Areas of Concern; and, continue to monitor the restoration of beneficial uses in the Jackfish Bay and Spanish Harbour Areas of Concern in Recovery, including to support the confirmation of delisting in Spanish Harbour. Activities after the delisting of an Area of Concern will be considered on case-by-case basis in consultation with the community. Any post-delisting work will be captured in the Remedial Action Plan Completion Report. Ongoing monitoring will be considered and addressed through the work of other COA Annexes after the delisting of an Area of Concern, or addressed through ongoing federal or provincial programs, if applicable. Engagement of the local community will continue through the process to develop and implement Lakewide Action and Management Plans. |
Geographically focused initiatives A commenter suggested that Canada an Ontario approach restoration through a watershed approach and support “geographically focused initiatives”, which more communities and partners will identify with than AOCs. |
Areas of Concern are specific to legacy issues at the local level. Other efforts under COA, such as the lakewide action and management plan process, the nearshore framework, and federal work to assess the resilience of Great Lakes coastal wetlands, consider a broader scale and include geographically focused areas beyond Areas of Concern. |
Remedial Action Plan implementation teams Commenters recommended Canada and Ontario provide adequate resources to Remedial Action Plan (RAP) offices. A commenter suggested the addition of new general commitments to provide resources to support activities of RAP implementation teams as well as to provide support for community input, consultation and participation in RAP projects. |
The Governments of Canada and Ontario have committed to providing the resources required to implement COA, including work under the Areas of Concern Annex. Through the Government of Canada’s Great Lakes Protection Initiative, local groups have the opportunity to submit applications for funding to support the coordination of activities identified in the Remedial Action Plans, remediation projects, or monitoring efforts that contribute to meeting delisting criteria, re-designating beneficial use impairments and delisting an Area of Concern. |
Hamilton Harbour A commenter recommended COA provide, encourage and support efforts to reduce sewage pollution in Hamilton to improve recreational water quality in the harbor. |
The Government of Canada is committed to working with the Government of Ontario and local partners in order to make significant progress on restoring water quality and ecosystem health in the Hamilton Harbour of Concern within the timeframe of the Agreement. To address the specific issue of sewage pollution, the Governments of Canada and Ontario have committed to promoting infrastructure funding to reduce phosphorus inputs from the Dundas sewage treatment plant to Cootes Paradise, as well as the completion of tertiary upgrades to the Woodward Avenue wastewater treatment plant to advance progress towards achievement of delisting criteria for the Eutrophication or Undesirable Algae beneficial use impairment. Additional commitments to reduce sewage and stormwater pollution are identified in the Wastewater and Stormwater Annex (Annex 3). |
Port Hope A commenter recommended ensuring the Port Hope low-level radioactive waste cleanup program meet all of Ontario’s air and water quality objectives. |
The Port Hope harbour low-level radioactive waste cleanup program is required to meet all air and water objectives as defined in their licenses and permits that have been approved by the appropriate regulatory body, including the Government of Ontario Ministry of the Environment, Conservation and Parks and the Canadian Nuclear Safety Commission. |
Thunder Bay A commenter recommended Canada and Ontario pay careful attention to ensure Fort William First Nation is satisfied with the course of action to address creosote clean up and storage from Thunder Bay Harbour. |
Creosote was the contaminant associated with the Northern Wood Preservers Alternative Remediation Concept site, which has been remediated since 2003. A monitoring update by the Government of Ontario’s Ministry of the Environment, Conservation and Parks is anticipated in 2020. |
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Local hotspots A commenter recommended that actions should be encouraged in local hotspots in addition to Lakewide Action and Management Plans (LAMPs). |
The Lakewide Management Annex addresses water quality and ecosystem health issues at the lakewide scale. However, the Government of Canada understands that many water quality issues are addressed through local actions throughout the watershed. Through the Agreement, the Governments of Canada and Ontario are committed to completing an assessment of the Canadian Great Lakes nearshore waters, which will help to identify the geographically specific areas that experience, or may become subject to, high stress and require local action. The most degraded hotspots in the Canadian Great Lakes have been designated as Areas of Concern, which are the focus of coordinated and targeted remedial actions and monitoring by the Governments of Canada and Ontario, in collaboration with many local partners. |
Erosion A commenter recommended that commitments in the Annex feature erosion more prominently. |
Although erosion is not specifically addressed through COA, it is understood as being related to shoreline alterations and their impacts on water quality as well as nutrients, habitat and contaminants issues. These issues are considered through the development and implementation of Lakewide Action and Management Plans. |
Drinking water A commenter suggested that Canada and Ontario add a commitment to work with municipalities to take action to support the implementation of source protection plan policies to protect sources of drinking water in the Great Lakes. |
Drinking water is an area of provincial jurisdiction; however, Government of Canada commitments under COA related to the management of nutrients, wastewater and stormwater and related monitoring, as well as environmental legislation that prevents pollution (e.g. Canadian Environmental Protection Act, the Fisheries Act) will contribute to protecting the Great Lakes as a source of high quality drinking water. |
Nearshore assessments A commenter recommended that nearshore assessments be completed in collaboration with Conservation Authorities because many have already conducted significant monitoring on nutrient inputs and algal growth. |
The overall assessment of nearshore waters is a screening level cumulative assessment conducted on a lake by lake basis. Once complete, organizations and communities will be able to use the results of the assessment to set their own priorities and take action. The Government of Canada will also share tools and approaches to assist communities in identifying causes of stress and assessing risk and threats to their nearshore areas. |
Tributaries and wetlands A commenter recommended that tributaries and wetlands be assessed under the LAMPs, in addition to the Great Lakes and their connecting channels. |
Lakewide Action and Management Plans (LAMPs) are meant to examine, restore and protect water quality and ecosystem health at the lakewide scale. The LAMPs also consider inputs from tributaries but do not evaluate the tributaries themselves, except for connecting rivers. Ongoing monitoring of coastal wetlands will continue under the Agreement, and will be combined with other data to inform the assessment of the Canadian Great Lakes nearshore. |
Resources Commenters recommended that Canada and Ontario add a commitment to ensure sufficient resources are provided to fulfill all LAMP requirements on a timely basis. A commenter recommended that Canada and Ontario leverage community support for the nearshore framework and LAMPs through establishing new funding programs, such as the former Great Lakes Guardian Community Fund. |
The Governments of Canada and Ontario commit to providing the resources required to implement COA under Article VIII (Resources). |
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Research A commenter recommended that COA should include support for research on the effects of climate change on global distribution and movement of aquatic invasive species. |
The Governments of Canada and Ontario are committed to advancing research to identify potential changes in species distribution and risks of new aquatic invasive species in the Great Lakes resulting from the effects of climate change. |
Phragmites Commenters recommended that COA should classify phragmites as a priority invasive species to be eradicated because delaying efforts will be more costly. A commenter recommended that Canada and Ontario should recognize and fund coordinated efforts to eradicate phragmites such as treating vector pathways in the region. |
The Aquatic Invasive Species Annex is designed to be inclusive of all invasive species of concern, including Phragmites, in the Great Lakes. While not specifically referenced in the Agreement, the Government of Canada will continue to work with the Province of Ontario and conservation partners to coordinate the prevention, management and research activities to help address the threat of Phragmites, while promoting public education on negative impacts. |
Managing established aquatic invasive species A commenter recommended that COA include commitments to support and fund activities that manage established aquatic invasive species, such as developing technologies to better control mussels. |
As stated in COA, the Governments of Canada and Ontario are committed to promoting research and the development of control tools to better respond to and manage aquatic invasive species. |
Lake of the Woods A commenter recommended that COA address early detection of aquatic invasive species being transported from the Great Lakes to the Lake of the Woods. The commenter recommended that COA include a commitment to install a mandatory wash station on Highway 7 to prevent the introduction of aquatic invasive species from the Great Lakes to the Lake of the Woods. |
The Government of Canada works to minimize the introduction and spread of aquatic invasive species nationally. This particular project falls outside the geographic scope of COA, and would also fall under the jurisdiction of the Government of Ontario. |
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Phragmites A commenter recommended that the preamble to the Habitat and Species Annex incorporate text that acknowledges the threat of Phragmites. A commenter recommended that COA include a commitment to support the eradication of phragmites. |
While not specifically referenced in the Agreement, the Government of Canada will continue to work with the Province of Ontario and conservation partners to coordinate the prevention, management and research activities to help address the threat of Phragmites, while promoting public education on negative impacts. |
Land use planning and management A commenter recommended Canada and Ontario consider strengthening the long-term protection of biodiversity and the restoration of ecosystems through reviewing and establishing land use planning and management approaches. |
The Government of Canada recognizes the importance of land use planning for biodiversity protection and is committed to protecting 17% of terrestrial lands and inland waters throughout the country. As stated in COA, the Governments of Canada and Ontario are committed to strengthening the long-term protection of biodiversity and restoration of ecosystems through a network of aquatic and terrestrial protected areas. Building this network of protected areas will require consideration of the larger landscape, such as the need for providing connectivity between protected areas and consideration of other effective area-based conservation measures. |
Funding Commenters recommended that Canada and Ontario provide adequate funding to local communities and organizations to ensure the effectiveness of efforts to protect native species and habitats and to raise awareness of the benefits of conservation and protection actions. |
The Government of Canada is committed to working with others to restore and protect native species and habitats. In 2018, the Government of Canada announced an investment of $1 billion in the Canada Nature Fund, which includes federal funding of $500 million over 5 years plus an anticipated $500 million through leveraged partnership support from foundations, provinces, territories, the corporate and not-for-profit sectors, and others. In collaboration with partners, the Canada Nature Fund will make it possible to secure private land, support provincial and territorial species protection efforts, and help build Indigenous capacity to conserve land and species, for the benefit of current and future generations. While national in scope, the Canada Nature Fund will support efforts such as those focused on protecting and recovering species at risk, expanding wildlife areas and managing protected areas around the Great Lakes Basin. |
UNESCO Biospheres Commenters recommended that COA recognize the critical role of UNESCO Biospheres in protecting biodiversity and ecosystem health. |
The Government of Canada recognizes that UNESCO biospheres as important centres of biodiversity. However, there are many areas within the Great Lakes region, such as parks, reserves, RAMSAR wetlands and important bird areas, which are of high ecological significance to the Great Lakes basin ecosystem. Keeping language at a high level ensures the Agreement encompasses all areas of importance. |
Climate change A commenter recommended that the Annex include language that recognizes climate change stressors on habitat as well as the need to protect habitat to reverse species loss and provide optimal resilience against climate change effects. |
The Government of Canada acknowledges there are climate-related impacts on ecosystem structure and function as well as the need to enhance habitat resilience in the face of climate change impacts and other stressors. This is addressed in the Agreement, including through commitments to improve the understanding of climate-related vulnerabilities and resilience of Great Lakes coastal wetlands. |
Baseline habitat survey A commenter recommended that the Great Lakes baseline habitat survey include a survey of coastal and inland wetlands and the terrestrial areas of their basins. |
The Governments of Canada and Ontario are jointly developing a baseline survey methodology to capture key habitat components. Wetland and coastal terrestrial habitats are considered in the baseline survey. |
Natural heritage mapping A commenter recommended that COA include a new commitment to create Natural Heritage mapping for Great Lakes Basins that delineates a mosaic of Naturally Connected Habitats for protection. |
While there is no specific commitment to create natural heritage mapping for the Great Lakes basin under the Agreement, information related to natural habitats is available through the Government of Canada’s Canadian Protected and Conserved Areas Database as well as the Government of Ontario’s Natural Heritage Information Centre, which includes a web application for building natural heritage maps. |
Wetlands Commenters recommended that COA improve the understanding of climate-related vulnerabilities and resilience of Great Lakes coastal, near coastal and inland wetlands. |
Inland wetlands are not within the scope of the Government of Canada’s science-based assessment of Great Lakes coastal wetlands to climate-related impacts. |
Connectivity Commenters recommended that COA broaden its commitment to restore and improve connectivity to Great Lakes tributaries for migratory fish to also include Great Lakes terrestrial and inland wetland habitats. |
Terrestrial and inland wetland habitats fall outside the scope of COA. |
Aquaculture A commenter recommended that Canada reverse the exemption given to open net cage aquaculture operations in Georgian Bay and the North Channel from the section of the Federal Aquaculture Regulations Act 2015, which forbids the harmful alteration, disruption or destruction of fish habitat. |
The Government of Canada’s Aquaculture Activity Regulations apply to all aquaculture operations in Canada that deposit into fish-bearing waters. The Regulations manage impacts to allow compliance with Sections 35 and 36 of the Fisheries Act. The environmental impacts of net pen aquaculture are assessed through the licensing process and must comply with the Application Guidelines for Cage Aquaculture Facilities, which are designed to minimize risk to the environment. The Class Environmental Assessment for Resources Stewardship and Facilities Development Projects have requirements that the Government of Ontario must follow during the review of applications for net pen aquaculture licenses. |
Endangered species A commenter recommended that COA include a provision to protect endangered species that rely on the Great Lakes for habitat. |
Species listed in the federal Species at Risk Act are considered and addressed in COA. Similarly, the Government Ontario’s Endangered Species Act automatically protects species and their habitats throughout the province, including in the Great Lakes region. |
Watersheds A commenter recommended that COA include a commitment to recognize the importance of the conditions in the watersheds in addition to high quality habitats in the offshore and nearshore areas. |
In recognition of the division of jurisdiction over waters, the Government of Canada’s focus for this Agreement is on the binational waters of the Great Lakes to achieve Canada’s commitments under the Canada-United States Great Lakes Water Quality Agreement. |
Genetic inventory A commenter recommended that COA include a commitment to fund the complete genetic inventory of all organisms in the Great Lakes region to determine present baseline biodiversity and relative abundance. |
Advances in genetic techniques and approaches, such as the use of environmental DNA, offer promise in providing a more fulsome understanding of all the organisms in the Great Lakes. These tools are not yet fully developed; however, many federal and provincial agencies are actively involved in work to support or incorporate those tools that are available through the delivery of COA. |
Georgian Bay A commenter recommended that COA include a commitment to recognize the unique wetlands of the eastern Georgian Bay coast and support research, monitoring and restoration of eastern Georgian Bay wetlands. |
There are many unique regions within the Great Lakes basin of high ecological significance. The Agreement keeps language at a high level to ensure due consideration is given to all areas of importance. |
Conservation of habitat A commenter recommended that COA also commit to conserving habitat of lower quality that still provides important functions and ecosystem services. |
The Government of Canada is committed to restoring, protecting and conserving Great Lakes aquatic and terrestrial habitats that support aquatic dependent species and provide other ecosystem services, while ensuring sustainable social, ecological and economic benefits. The Agreement does not preclude the Governments of Canada and Ontario from conserving habitat of lower quality. |
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Partnering with conservation authorities A commenter recommended that, as groundwater-dependent ecosystems are mapped in the Great Lakes, that Conservation Authorities support the collection of local data (e.g. habitat patch, species distribution) as well as the assessment of groundwater exposure and sensitivity to variation and other stressors. |
The Government of Canada is committed to working with the Great Lakes community, including Conservation Authorities, in a cooperative, coordinated and integrated manner to improve environmental quality in the Great Lakes. Opportunities to enhance the collaboration will be explored during the implementation of the Agreement. |
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Preamble A commenter recommended adding text to the preamble of the Annex that recognizes additional issues linked with climate change, including air quality, forest fires, crop changes, extreme weather events, and health impacts. |
The preamble to the Climate Change Impacts and Resilience Annex recognizes many of the issues linked with climate change, such as extreme weather events and health impacts. The preamble does not specifically list the issues of air quality, forest fires and crop changes because they fall outside the scope of the Agreement. |
Conservation authorities and flood mapping Commenters recommended adding text that recognizes the role of Conservation Authorities in flood mapping. |
The Government of Canada recognizes the importance of flood mapping and the role that Conservation Authorities have historically played in relation to flood mapping and prevention. |
Inter-annex communication A commenter recommended that climate and climate change related data and information be shared across COA Annexes. |
The Government of Canada recognizes the importance of cross-Annex collaboration, as well as the impacts of climate change on other Annexes of the Agreement. The COA commitment to share information on climate change impacts, risks and vulnerabilities includes the sharing of information across COA Annexes, as applicable. |
Climate change impacts on public health A commenter recommended Annex 10 make a stronger link between the impacts of climate change and public health. While the impacts on people, public health, communities and infrastructure in the Great Lakes basin are described in the preamble, the commenter expressed that results and commitments should also reflect these potential impacts. |
The impacts of climate change on public health falls outside the scope of COA. |
Enhance knowledge and build resiliency A commenter recommended that Canada and Ontario undertake initiatives to advance knowledge of climate change impacts, assess climate change risks and vulnerabilities to the Great Lakes basin and better prepare communities to adapt and build resilience. |
As stated in COA, the Governments of Canada and Ontario have made a number of commitments to enhance knowledge and understanding of existing and future climate change impacts in the Great Lakes, to assess existing and future climate change risks and vulnerabilities of the Great Lakes, and help communities better prepare to adapt to climate change and build resilience. |
National efforts A commenter recommended that the Agreement explore national efforts (e.g. Natural Resources Canada’s Adaptation to Climate Change Program). |
As stated in COA, national efforts, such as the Government of Canada’s Adaptation to Climate Change program, complement the commitments under the Climate Change Impacts and Resilience Annex. |
Water levels / flood prevention A commenter recommended that governments examine through their flooding advisor and work with the International Joint Commission to ensure water levels are appropriate given the storms and spring melt off that Ontario municipalities are experiencing. A commenter recommended that Canada and Ontario take further action to address the needs of shoreline communities facing the impacts of climate change, such as high water levels. |
The issue of water levels falls outside the scope of the Agreement. |
Green infrastructure A commenter recommended COA include green infrastructure as a key tool for building climate change resiliency. |
The Government of Canada recognizes the role green infrastructure plays in building community climate change resiliency. Canada is investing $26.9 billion in green infrastructure as part of its $180 billion (over 12 years) long-term infrastructure plan, Investing in Canada. This funding will support projects that protect communities from the effects of a changing climate and provide communities with more reliable water and wastewater systems. In September 2016, Canada and Ontario announced a bilateral agreement that will make more than $1.1 billion in combined funding available under Investing in Canada to improve water and wastewater infrastructure across the province. Wastewater infrastructure funding will contribute to meeting commitments under the Canada-United States Great Lakes Water Quality Agreement, including reducing nutrients causing toxic and nuisance algae, and supporting healthy beaches. |
Shoreline resiliency priority zones A commenter recommended that Canada and Ontario commit to establishing and funding shoreline resiliency priority zones to identify and address significant threats from climate change impacting natural and built infrastructure on Great Lakes shorelines, emphasizing naturalization and green infrastructure solutions. The commenter recommended Canada create a climate data sub-portal for the zones within the Canadian Centre for Climate Services portal. It was further recommended that Canada and Ontario provide ongoing guidance and funding to all shoreline municipalities and Indigenous communities to support actions to make their shorelines more climate resilient. |
While the Agreement is negotiated based on existing resources and programming, the concept of shoreline resiliency priority zones could be further explored during COA implementation. |
| Summary of comment | Response |
|---|---|
Increase public engagement Commenters recommended that Canada and Ontario enhance opportunities and work with others (e.g. municipalities, nongovernmental organizations, etc.) to engage Great Lakes communities in protection efforts. |
The Government of Canada recognizes the importance of engaging with the Great Lakes community, including First Nations and Métis, municipal governments, conservation authorities, and the public and private sectors, to facilitate collaborative action on Great Lakes issues and priorities. Through COA, the Government of Canada has committed to providing meaningful opportunities for the Great Lakes community to discuss, advise and participate directly in Great Lakes activities and priority setting. The Agreement will provide enhanced engagement opportunities for the public in the development and implementation of Lakewide Action and Management Plans, as well as in the clean-up of Areas of Concern. The Government of Canada will also continue to support public engagement through citizen science under the Great Lakes Protection Initiative. |
Green infrastructure A commenter recommended prioritizing green infrastructure when providing funding support to community projects. |
As reflected in the new Agreement, the Government of Canada supports the use of green infrastructure to help address threats to water quality, including through funding for projects that prevent toxic and nuisance algae in Lake Erie under the Great Lakes Protection Initiative as well as through the Investing in Canada infrastructure program. |
Biosphere Reserves A commenter recommended an additional commitment be added to recognize the Biosphere Reserves in Ontario and their conservation and sustainability efforts. |
The Government of Canada recognizes there are many critical ecosystems within the Great Lakes, including biosphere reserves. Keeping language in the Agreement at a high level ensures consideration of all critical ecosystems. |
Leveraging partnerships A commenter recommended COA include a commitment to partner with municipalities, nonprofit organizations, ratepayer/cottager associations and conservation authorities to leverage their direct contact/concerted expertise in engaging/educating Great Lakes communities. |
The Government of Canada will continue to leverage partnerships through the implementation of the Agreement. |
| Summary of comment | Response |
|---|---|
Recognition of Métis connection A commenter recommended Canada and Ontario incorporate into Annex 12 the strong spiritual connection of Métis citizens / communities to the Great Lakes. |
The Government of Canada recognizes that Métis in the Great Lakes basin have a strong spiritual connection to the lakes, which has been recognized through the addition of a new recital in the Agreement:
|
Independent Métis Nations A commenter recommended that Canada and Ontario meet with independent Métis nations. |
The engagement of independent Métis nations will be addressed through the implementation of the Agreement. |
Consultation plan and Annex goals A commenter recommended that Canada and Ontario develop a consultation plan and broad goals to support the delivery of Métis and the Great Lakes Annex. |
The development of a consultation plan to support the delivery of the Métis and the Great Lakes Annex will be considered during the implementation of the Agreement. |
Opportunities to enhance participation A commenter recommended Canada and Ontario support opportunities to enhance Métis participation in Great Lakes restoration and protection efforts, such as Métis-specific regional initiatives as well as streamlined communications and long-term partnerships. |
Métis led regional initiatives are eligible for funding under the Government of Canada’s Great Lakes Protection Initiative. Capacity support is also available through the federal Indigenous Habitat Participation Program, a funding program that could provide support for Great Lakes-related activities if selection criteria are met. Long-term partnerships and streamlined communications will be considered through the implementation of the Agreement. |
| Summary of comment | Response |
|---|---|
Recognition of rights A commenter recommended Annex 13 recognize First Nations as rights holders. |
The Government of Canada recognizes the section 35 rights under the Constitution Act, 1982 of First Nations in the Great Lakes basin. Recognition of rights is acknowledged in a new recital:
|
Engagement A commenter recommended Canada and Ontario undertake further work to engage First Nations in COA, including through discussions on how to engage First Nations effectively, and that engagement of First Nations be consistent across annexes. Commenters recommended capacity funding be included in COA, thereby ensuring ongoing and predictable funding to support First Nations participation in COA and its associated processes. |
The Government of Canada provides support to the Chiefs of Ontario to support First Nations engagement in COA. The COA Executive Committee co-chairs also meet annually with First Nations organizations and communities to discuss issues and opportunities for further engagement. To support further engagement with First Nations in COA, a new commitment has been added to invite First Nations representatives to participate in COA Executive Committee meetings. First Nations are invited to participate in all existing sub-committees that coordinate the delivery of Annexes under the Canada-United States Great Lakes Water Quality Agreement. For information on how to join these sub-committees, please contact ec.grandslacs-greatlakes.ec@canada.ca. The Government of Canada provides capacity support and project funding to First Nations under the Great Lakes Protection Initiative. Specific resource levels are not included in Agreement text. COA was negotiated based on existing resources. The Government of Canada is committed to providing the resources needed to implement its commitments under the Agreement. |
First Nations issues A commenter recommended that COA acknowledge First Nations issues, such as flood claims and relocations. |
Issues related to flood claims and relocations falls outside the scope of the Agreement. |
Tripartite Agreement Commenters recommended that COA become a tripartite agreement with First Nations. |
COA is an administrative agreement between federal departments and provincial ministries to coordinate activities for the delivery of Canada’s commitments under the Canada-United States Great Lakes Water Quality Agreement. The Government of Canada is committed to enhancing its engagement with First Nations on a good governance basis through the implementation of COA, including in decision-making as it relates to lakewide management as well as Areas of Concern. |
Nation-to-Nation relationship Commenters recommended COA reflect First Nations’ desire to work collaboratively on joint priority issues related to water, and their right to be involved in the decision-making process from its inception, consistent with the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP) and the principle of free, prior and informed consent. |
The Government of Canada recognizes the desire of First Nations to work collaboratively on joint priorities in the Great Lakes. Recognition of First Nations rights, as well as the federal government’s commitment to implementing the UNDRIP are articulated through new recitals in the Agreement. Canada and Ontario are committed to working with First Nations to develop and implement processes to engage with First Nations on decision-making as it relates to Areas of Concern and lakewide management. Canada and Ontario have also included a new commitment to invite First Nations representatives to participate in COA Executive Committee meetings, to enhance First Nations’ role in direction setting under the Agreement. |
Appendix I
Input was received from:
- Frank Wang
- Brigitte Bonner
- Amanda Marles
- John Hartig, University of Windsor
- Historic Saugeen Métis
- Judy Smith
- Mary Belleghem
- Association of Municipalities of Ontario
- Toronto and Region Conservation Authority
- City of Toronto
- Severn Sound Environmental Association
- Conservation Ontario
- Green Infrastructure Ontario
- Lower Trent Conservation
- Ontario Good Roads Association
- Ontario Headwaters Institute
- Georgian Bay Association
- Burlington Green Environmental Association
- Essex Region Conservation Authority
- Lake Carriers' Association
- Chemistry Industry Association of Canada
- Regional Municipality of York
- Township of the Archipelago, Georgian Bay Land Trust, Georgina Bay Association and Georgian Bay Forever
- Jonathan Brown
- Swim Drink Fish Canada
- Canadian Environmental Law Association and Environmental Defence Canada*
- Ontario Rivers Alliance
- Ducks Unlimited
- St. Lawrence River Institute of Environmental Sciences
- Georgian Bay Forever
- Great Council Treaty #3
- Regional Public Works Commissioners of Ontario
- Great Lakes St. Lawrence Cities Initiative
- Chiefs of Ontario
- Métis Nation of Ontario
*Submission was endorsed by 21 organizations and 1 citizen: Toxics Free Great Lakes Network, Grand River Environmental Network, Ontario Nature, McMaster University, Rescue Lake Simcoe Coalition, Sierra Club Ontario, Local Enhancement and Appreciation of Forests, EcoSuperior, Earthroots, Wellington Water Watchers, World Wildlife Fund, Burlington Green, Georgian Bay Association, Citizens Environment Alliance, Association for Canadian Educational Resources, Bay Area Restoration Council, Freshwater Alliance, Freshwater Future Canada, Simcoe County Greenbelt Coalition, Alliance for the Great Lakes, Georgian Bay Forever, Natalija Vojno
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