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Minister of the Environment a =i, Ministre de l'Environnement
Ottawa, Canada K1A 043
SEP 10 2014
‘The Honourable Brad Duguid, M.P.P.
Minister of Economic Development, Employment
and Infrastructure
Government of Ontario
Hearst Block, 8th Floor
900 Bay Street
Toronto ON M7A 2E1
Dear Minister:
| am writing in response to your letter of September 3, 2014, regarding Bill C-40
and the Government of Canada’s unprecedented commitment to the area that
will become the Rouge National Urban Park.
| was disappointed to learn of your decision to recommend to your colleagues not
to support the transfer of provincial land into the Rouge National Urban Park.
This decision is surprising as there has been no previous indication from your
Ministry that the policies or legislation for the Rouge National Urban Park would
prevent your support for the transfer of the provincial land.
‘As you know, our governments have engaged in many positive and productive
meetings over the past three years as we have worked collaboratively towards
the creation of the Rouge National Urban Park. Federal and provincial officials
have met on dozens of occasions to discuss plans for the Rouge National Urban
Park. All conversations to date have been positive, including one | personally
had during a tour of the Rouge in February of this year with Minister David
Orazietti, former Minister of Natural Resources. Indeed, your predecessor and
current Environment Minister Glen Murray made an impassioned speech in
support of the Rouge National Urban Park last summer during your government's
announcement on the provincial land transfer and stated the creation of the park
“will be one of the most significant environmental projects ever undertaken in
Ontario.”
| was particularly disappointed to lear of your decision via the media. In sharing
the letter with the Toronto Star at the same time it was provided to my office, | am
concerned that productive discussions have suddenly come to an end. This
action very publicly calls into question the commitment of the Government of
Ontario to work with us to protect the Rouge Watershed. For our part, the
Government of Canada remains committed to the creation of the Rouge National a)
Urban Park that will provide the Rouge Valley the highest level of legal protection &
in its history.
J2
Canada-2-
Bill C-40 was crafted to go well beyond the existing provincial legislation and
policies, which govern a patchwork of lands that make up the future park. As
crafted, the legislation provides a well constructed, cohesive federal law to
protect the Park's rich natural heritage, and also extend this protection to culture
and agriculture. As you know, these same goals are explicit in 2005 Greenbelt
Act, the main piece of provincial legislation exclusively covering the main areas
of the future park.
I have appended a summary of the areas where Bill C-40 meets or exceeds
provincial plans and policies, (Annex A). | will briefly highlight a few to illustrate
our government's commitment to increasing the level of protection in the Rouge.
For example, for the first time, the entire park will prohibit mining and hunting on
all lands. Additionally, the 23 species at risk that live within its boundaries will be
protected to the fullest extent of federal law under the Species at Risk Act. The
proposed park would strengthen and support the Greenbelt and Oak Ridges
Moraine plans by including an ecological link between Lake Ontario and the Oak
Ridges Moraine, protecting prime agricultural areas, and connecting natural
heritage features, as well as hydrological and landform features (e.g. wetlands,
species at risk and fish habitat, significant valley lands, woodlands, and wildlife
habitat).
Furthermore, the legislation contains a provision to allow the adoption of
provincial regulations where harmonization makes the most sense. The
Government of Canada remains open to discussions with Ontario on the
adoption of some provincial regulations, which could avoid confusion amongst
citizens related to park management.
In short, our legislation will provide more protection for a larger portion of the
Rouge Valley, with mechanisms in place to add lands that would eventually make
the park 25% larger than the current protected area, roughly 16 times the size of
Central Park. Furthermore, our government has committed a significant amount
of long-term funding to support the operation, management, and protection of this
park. Because of this financial commitment, the Rouge will now have year round
dedicated enforcement officers — a level of protection that the province does not
currently provide.
In light of your comments regarding meeting ecological integrity targets, | will
note that none of the provincial policies have ecological integrity as their stated
first objective — and some fail to include the term all together (e.g. The Greenbelt
Act). Further, our joint Federal-Provincial agreement makes no mention of
ecological integrity; therefore it is surprising to have this issue raised as a
concern at this time.
d33.
In practical terms, the concept of ‘ecological integrity’ as it applies to Canada’s
national parks is simply unachievable in an urban setting. For instance,
ecosystems have integrity when their native components remain intact. Because
ecosystems are constantly changing, conservation strategies which have
ecological integrity as their goal must allow processes that reflect the
ecosystem's natural condition. That means ecological processes such as fire and
flooding would need to be allowed to run their natural course. This is how Parks
Canada manages our country's national parks.
The Rouge National Urban Park is in a densely populated urban area within the
Greater Toronto Area and is fragmented by highways, roads, rails, hydro lines,
residential communities and infrastructure. The principle of ecological integrity is
incongruent with these infrastructure realities and the future infrastructure
projects that you envision. The Government of Canada is meeting all of the terms
of our MOU, including Ontario's request to include a provision in our legislation to
remove land from the park for infrastructure projects, like expanding hydro lines,
transit or highways. If ecological integrity were applied to the Rouge, the
Government of Ontario's request to take land out of the future park for future
infrastructure projects would become impossible to accommodate.
Furthermore, if we were to manage the Rouge as we do in National Parks, it
could mean evicting farmers who have been responsible stewards of the land for
over a century. In addition, applying the concept of ecological integrity as it is
applied in National Parks would mean allowing natural ecological processes like
wildfires and pest outbreaks to occur. Obviously this is neither desirable nor
realistic.
That's why we decided, in discussion with all current public landholders, to create
a new category of federally protected area — a national urban park.
In meeting the intent of the land transfer agreement, our main policy instrument
will be the Rouge National Urban Park Management Plan, We will begin formal
‘open houses on the management pian starting in the next week and will be
making revisions over the coming months to reflect the feedback received. We
are open to discussions with you and your government on elements you would
like to see within the plan. | have appended to this letter a copy of the draft
management plan (Annex B) for your review and would invite your officials to
work with Parks Canada to ensure that input from the province is considered.
Our government is actively listening, and working hard to accommodate a wide
range of views and perspectives so that the future park conserves the Rouge's
rich natural, cultural and agricultural heritage in an inclusive and respectful
I4-4-
manner. We have met with nearly 150 organizations and received comments
from more than 10,000 residents in the area to develop the concept for the
Rouge National Urban Park, which serves as the basis for our legislation.
The message we have received from Canadians is loud and clear - they strongly
support our plan to protect and celebrate the Rouge's natural, cultural and
agricultural heritage, resources and landscapes. The urban context of Rouge
National Urban Park brings unprecedented accessibility for Canadians to learn
about the park and all of Canada’s protected areas.
In the interest of residents living in the Greater Toronto Area, itis time to move
forward on creating Canada’s first national urban park and one of the largest
urban parks in the world. We believe it is important to protect the lands in this
area that fall under federal jurisdiction. Our approach is one that encourages a
thriving ecosystem, respects local farmers and invests in opening new
opportunities for the millions of Canadians who live near the Park. The Rouge
National Park Act goes beyond existing provincial policies and would provide the
Rouge with the highest level of legal protection in its history.
Should your government be prepared to honour its commitments arrived at over
many years of careful and cooperative negotiation we will remain open to
expanding the park through the transfer of Ontario's provincial lands.
Sincerely,
Ci BAG
The Honourable Leona Aglukkaq, P.C., M.P.
Minister of the Environment