An Opportunity to Comment – A Review of the 2020 Draft Canada-Ontario Agreement for the Great Lakes

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Posted by April Weppler, Engagement Coordinator – Healthy Great Lakes on August 30, 2019

The Canada-Ontario Agreement on Great Lakes Water Quality and Ecosystem Health (COA) is the key agreement that outlines how the provincial and federal governments will work together to conserve, protect and restore the waters and wetlands of the Great Lakes – St Lawrence Basin. In a time of climate and biodiversity crisis, we look to tools such as the COA to guide our region in creating resilient communities and healthy ecosystems for people and nature to thrive.

The agreement is renewed every five years, and earlier this summer the two governments released the COA 2020 draft. CELA and Environmental Defence co-hosted a webinar that explains the role of COA and outlines the strengths and weaknesses of this most recent version.

Subsequent to the webinar, and building on the valuable discussion amongst webinar participants, CELA and Environmental Defence conducted a detailed review of the COA 2020 draft, and submitted comments to the governments of Ontario and Canada. 22 organizations signed onto the submission.

Our region is facing serious threats from climate change, harmful algal blooms, plastic pollution and ecological break down at an increasing rate. To address these increasingly severe threats, this version of COA must be stronger than it has ever been. This next iteration of the COA is our opportunity to show leadership in the protection of the Great Lakes – St Lawrence ecosystem, and we hope the two governments will approach this task with that responsibility top of mind.

Comments on the Draft 2020 COA

Overall, we are looking for a renewed agreement that sets clear targets, investments, actions and timelines. Decisions around policy, restoration, and protection of the Great Lakes – St Lawrence River ecosystem should integrate the knowledge and expertise of federal, provincial, and indigenous governing bodies.

We are supportive of many aspects of the draft, including the focus on key environmental issues such as reducing plastic pollution, road salt use, untreated and undertreated wastewater, and nutrient loading in Lakes Erie and Ontario. We also appreciate the clear focus on action and increased transparency regarding Areas of Concern.

We recommend improving the draft COA by recognizing Indigenous governance, setting ambitious goals, providing adequate investment, clarifying reporting and accountability measures, committing to transparency, and enhancing public engagement.

Indigenous governance: We are disappointed that the draft COA does not incorporate Indigenous governance. Reconciliation requires active recognition of the role of Indigenous Peoples’ governance in the Great Lakes – St Lawrence Region. We must turn our focus to the entirety of the ecosystem and integrate perspectives from northern to southern Ontario, including, particularly, values and worldviews of Indigenous Peoples.

  • Ambitious Goals: Although the agreement purports to “remain accountable to citizens by establishing clear results and commitments”, the draft agreement contains very few results and activities that are specific, measurable and time-bound. In the absence of clearly defined and measurable outcomes, the public and decision makers will not be able to effectively determine the level of progress on the commitments in the draft COA.
  • Adequate Investment: We are concerned that the draft COA does not include any specific funding commitments, and that the funding itself will not be sufficient to achieve the purpose of COA. Investments under past COAs have been disproportionate to the scale of the challenges facing the region. We recommend that funding commitments by both Canada and Ontario be explicitly stated in the draft COA. Specifically, we recommend $100 million per year investment under COA.
  • Accountability Measures: The draft COA does not provide comprehensive reporting requirements, which is an essential component of an effective, transparent and accountable agreement. Furthermore, data and information collected under COA, such as through monitoring activities, should be publicly available – this would greatly assist efforts across the Great Lakes region to identify and address priority issues.
  • Public Engagement: We are concerned about the minimal level of public engagement in the development of this draft COA and the lack of express commitments in the draft to public consultation and engagement. Particularly, we recommend a mechanism or mechanisms for public involvement in the monitoring, oversight, and implementation of the entire agreement.
  • Nutrients: The draft COA includes some positive proposals for action on nutrient pollution to address harmful algal blooms not only in Lake Erie, but now in Lake Ontario. The commitment to develop and implement phosphorus management plans for priority watersheds in Lake Erie is a welcomed commitment in this draft. We hope to see this commitment strengthened further with timelines and measurable goals.
  • Harmful Pollutants: Plastic pollution is a welcome addition to harmful pollutants, and we are pleased to see the governments’ acknowledge the urgency of this threat to the Great Lakes – St Lawrence River Basin. We are also very pleased to see that actions to address chloride pollution from excessive road salt use have been included, and we have some specific suggestions including setting an explicit provincial objective.

Areas of Concern: This is the strongest and most accountable aspect of the draft agreement. The approach taken, to advance remediation and commitment to complete assessment reports, is positive and encouraging. The commitments are discrete and measurable, and we strongly encourage the governments to draft other portions of the agreement with such clarity and specificity.