August 7, 2020
On July 17th Barrie-Innisfil MPP Andrea Khanjin released the Minister of the Environment’s Ten Year report on Lake Simcoe and made a $581,000 funding announcement for Lake Simcoe research. The Minister was nowhere to be seen. Also missing were a credible science monitoring report and the 2018 and 2019 Ministers reports on Lake Simcoe.
We should take this investment to mean that the province is very aware that there are people like you and me who are going to make them wear the impacts of their decisions and actions on Lake Simcoe. We are a strong constituency, and we need to keep it that way. Public pressure is the Lake’s best defence.
I will focus my questions and comments on Lake Simcoe, but the Lake does not exist in a geographical or policy vacuum. Recent and proposed changes to the Growth Plan are going to perpetuate suburban sprawl until 2051 and beyond. The changes virtually guarantee that the scarce remaining farmland in southern Ontario will be bought by land speculators, threatening the viability of local food production. Recent policy changes and proposals also threaten the protection of more natural areas as aggregate extraction will soon be permitted in habitats of endangered species and other natural features outside the Greenbelt and possibly the Lake Simcoe watershed. The Environmental Assessment process is a shell of what it used to be. I could go on. The point is that the environmental policy regime in Ontario has been shattered. This will naturally affect Lake Simcoe.
Now, to the substance of the Minister’s Ten Year Report on Lake Simcoe. The Ten Year Report is far rosier than it should be. There are more unknowns, strange changes, and looming disasters than the report lets on. While I agree that the remedial actions have been helping the lake, there is an obvious editorial slant towards the bright side. I find this problematic because this report forms the backdrop to the review of the Lake Simcoe Protection Plan. I worry that it will lead readers to think that the Lake is doing well and needs less protection.
Indeed, fishing and swimming is the way most people use the lake, and the Ten Year Report underreports downward trends and / or existing poor conditions at beaches and regarding fish health. People who use Lake Simcoe have a right to know the truth, warts and all.
If I authored the report it would highlight:
- Phosphorus loads have skyrocketed in recent years; new development and its impacts are increasing pressure on the lake, and the remedial actions are not keeping up with the need to drive down phosphorus loads;
- The nearshore area is a mess of invasive species, and the nearshore ecology has undergone massive changes in the past ten years; impacts are yet inadequately studied;
- We don’t know why dissolved oxygen levels have gone up (good) while phosphorus loads have gone up (bad). This result is the opposite of what lake modelling told us to expect. The most likely explanations involve positive changes brought on by invasive species absorbing, consuming and / or moving phosphorus from one part of the lake to another. The long-term consequences of this are unknown;
- We are not achieving the Lake Simcoe Protection Plan’s natural heritage targets for forests, wetlands and shorelines, which are, essentially, to protect what we have and increase the size and quality of natural heritage features. Instead, we have lost wetland and forest cover across the watershed. The legal mechanisms in place will not achieve the Lake Simcoe Protection Plan’s natural heritage targets;
- Remedial actions are working but they are not compensating for the impacts of development and climate change. The Lake’s health will not improve without limits to growth, a strong emphasis on restoration, natural heritage protection, and invasive species control.
The most important point, however, is one of transparency. One should not blend science and politics in such an impenetrable way. The Minister of Environment, Conservation and Parks is a politician, not a scientist. Yet the Minister’s report says, “This consolidated report, which addresses both five-year and annual reporting requirements under the Lake Simcoe Protection Act, 2008, describes the collaborative efforts taken to implement the Lake Simcoe Protection Plan, as well as results of monitoring programs and progress towards the plan’s objectives.” It reports on the results of monitoring and progress towards objectives inconsistently and inadequately. If the province intended to produce more scientific reports to support the review of the Lake Simcoe Protection Plan, which we now understand they will do, they should have been clear about that when the Minister’s report was released.
Here’s what is expected: The Lake Simcoe Protection Act, 2008, which has legal effect, lays out some reporting requirements requiring “the Minister of the Environment to prepare a report that, describes the results of any monitoring programs; and describes the extent to which the objectives of the Lake Simcoe Protection Plan are being achieved at least once every five years.” 1 The Lake Simcoe Protection Plan says, less forcefully, that the “Ministry of the Environment in partnership with other ministries will produce a report that describes the results of monitoring programs as well as the extent to which the objectives of the Plan are being achieved.”
The Minister’s combo Science and Politics report of 2020 simply does not provide the analysis needed to evaluate the extent to which the objectives of the Plan are being achieved, and does not meet the reporting requirements of the Lake Simcoe Protection Act.
It is not appropriate to put all of this information into one report with little to no citations, and with no editorial input from the Lake Simcoe Science Committee. There is a totally unscientific catch-all reassuring the reader that, “Each priority area is supported by data and trends collected from several provincial monitoring programs, and supplemented with data from partners such as the Lake Simcoe Region Conservation Authority.” I do not mean to diminish the work of these conservation professionals. But the Minister’s report is not a science report without citations. In the absence of any other public explanation, the reader concludes that the province is trying to take the shortest route possible to meet the reporting requirements of the Lake Simcoe Protection Act and Plan by jamming it all into one inadequately sourced document.
The last comprehensive monitoring report on Lake Simcoe was released in 2014. It had been discussed and developed by the Ministry of the Environment and Climate Change in collaboration with the Lake Simcoe Science Committee over many months. The Minister’s 2014 Five Year Report on Lake Simcoe appropriately followed the Five Year Comprehensive Monitoring Report. It highlighted the good news, like the Minister of the Environment, Conservation and Parks in 2020, but at least it referenced an independent science report. The 2014 Comprehensive Monitoring Report has authors, citations, and references listed. It includes standard “science stuff” like clearly identifying progress against targets, which is inconsistent at best and deliberately misleading at worst in the 2020 report.
For instance, although the overall watershed trend is a LOSS of forests and wetlands (1% loss each over a ten year time period) what is highlighted in the press release of July 17 is, “The 10-year report on Lake Simcoe shows the restoration of more than 15 kilometres of degraded shorelines, the planting of more than 55,000 trees and shrubs, and the creation and restoration of 120 hectares of wetlands…” 2. Highlighting successes without context is misleading, and is the reason why blending politics and science in one report is problematic.
Related to the loss of natural heritage is development, the only growing source of phosphorus loading at Lake Simcoe. Ten years ago the province acknowledged that approved development to 2031 in the watershed would ADD up to 15.3 Tonnes per year Phosphorus to the lake. 3 The provincial Lake Simcoe Science and Coordinating Committees’ formal advice to the Minister cautioned that development threatens the Lake’s health, advising, “Ensure that the assimilative capacity and ecosystem health of the watershed are considered prior to any amendments to future growth projections.” 4 In contrast, the province has recently inflated growth projections using market demand and land needs assessment methodologies that have been called speculative and flawed by critics. The province has allowed municipalities to expand their settlement boundaries more easily and more often, and has allowed developers to build fewer homes per acre. This new growth will double the watershed’s population by 2041 and add stress to the lake via phosphorus loads from construction in the watershed, and from land converted to urban uses. Therefore we absolutely need to maintain the development and construction policies, practices and offsets programs that reduce the pollution from development at Lake Simcoe.
This is a relatively minor point but I am truly puzzled by this one. The Minister’s 2020 remarks end with: “I want to thank the local conservation authorities, Indigenous communities, municipalities, agricultural and commercial sectors and residents who have worked tirelessly on implementing actions to protect and restore the ecological health of Lake Simcoe. I also want to thank the Lake Simcoe Coordinating Committee and the Lake Simcoe Science Committee for their advice on where our efforts need to be focused. This ongoing work requires collaboration and I look forward to continuing this important partnership with you.”
I just do not believe this. It’s polite to thank everyone, it’s true, but this is disingenuous considering what has happened under this administration. To date, the Conservation Authorities budgets’ have been slashed and their powers are expected to be severely curtailed in yet unreleased regulations; there is no Indigenous representation on the Lake Simcoe Science and Coordinating committees, and local Indigenous communities are poised to oppose the new Upper York Sewage System going into Lake Simcoe; the Lake Simcoe Science and Coordinating committees have not met since the current provincial government came to power; municipalities have less ability now to collect development cost charges from developers on some growth-related costs; farmers are furious with the province for basically putting housing development ahead of farmland protection; and frankly, to date commercial and residents have not been publicly engaged by the province.
Lake Simcoe is not a political pawn. It’s a living thing that heals when the right conditions are in place. We need to engage experts in determining what the Ten Year monitoring results mean before contemplating any changes to the Lake Simcoe Protection Plan.
TAKE ACTION: If you share my concern that the government’s LSPP Ten Year Review this fall will leave the lake more vulnerable, you can take action now through this 1-click letter campaign.
Claire Malcolmson is the Executive Director of the Rescue Lake Simcoe Coalition. She has worked and volunteered on Lake Simcoe issues since 2001. Claire sat on provincial committees established to develop and then implement the Lake Simcoe Protection Act and Plan from 2008 – 2018.
The Rescue Lake Simcoe Coalition represents 26 groups around the Lake Simcoe watershed, and spearheaded the campaign to get the Lake Simcoe Protection Act in 2008. www.rescuelakesimcoe.org
- S. 12. 2. Lake Simcoe Protection Act
- Ontario newsroom. July 17, 2020. Ontario Taking Action to Further Protect Lake Simcoe. https://news.ontario.ca/ene/en/2020/07/ontario-taking-action-to-further-protect-lake-simcoe.html
- Ontario, 2010. Lake Simcoe Phosphorus Reduction Strategy. https://www.ontario.ca/page/lake- simcoe-phosphorus-reduction-strategy
- Minister’s Ten Year Report on Lake Simcoe, 2020 https://www.ontario.ca/page/ministers-10-year-report- lake-simcoe