Latest comments and policies



Joint Letter About Proposed Ontario Offsetting Policy ERO 019-6161
We, the 56 undersigned organizations, are deeply concerned about the proposed development of a natural heritage offsetting policy in the context of current major legislative and policy changes that are eroding environmental protections across the province (e.g. , changes to the Conservation Authorities Act, the Planning Act, and the Ontario Wetland Evaluation System, removal of lands from the Greenbelt). Although the Ministry of Natural Resources and Forestry (MNRF) is proposing a net-gain approach, decades of evidence suggest that even no net loss is rarely achieved through offsetting. We urge extreme caution should MNRF choose to proceed, and request that you strike an expert panel to advise on policy options and carry out full Indigenous and public consultation on the draft policy if and when it is developed.
Request for Time Limit Extension from Marten Falls FN to the Impact Assessment Agency of Canada
WCS Canada comments on the Request for Extension Report, prepared by AECOM Canada Ltd. and Dillon Consulting Ltd. on behalf of Marten Falls First Nation as the Proponent for the purpose of the Impact Assessment (IA) of the Marten Falls First Nation All Season Community Access Road (MFCAR) Project. In summary, we support the request by the Proponent for an extension of three and a half years to July 24, 2026. Of the factors listed in Section 2, we agree in particular that COVID-19 had significant impacts on First Nations communities in the far north in Ontario and have concerns that the Proponent chose not to pause the MFCAR Project despite First Nation community requests to do so given health and safety concerns, capacity, and social crises. We continue to think this experience highlights the limitations of impact assessment as a tool for social justice in northern Ontario.
WCS Canada Comments on DFO Cumulative Effects Position Statement
We are pleased that the updated Fisheries Act (2019) has included renewed commitments to protect fish and fish habitat, strengthens the role of Indigenous knowledge informing habitat decisions, establishes a public registry, and includes recognition of principles of sustainability, the precautionary principle, ecosystem management, and consideration of cumulative effects. We share the concern with DFO that failing to adequately consider cumulative effects will lead to continued loss of fish habitat in Canada, and we are pleased that DFO is working to better address cumulative effects. However, we have an overarching concern that the draft Position Statement falls short of providing clear and actionable guidance for the implementation of considering cumulative effects under the new Fisheries Act. Therefore, this document contains: 1) a description of our concerns on the draft Position Statement and our corresponding recommended revisions to strengthen the Position Statement (p. 2), and 2) our recommendations for implementation in the Yukon and northern Ontario -- two landscapes where we have regional expertise (p. 5).
WCS Canada Comments on Dawson Region Recommended Plan
Our overall assessment is that the Recommended Plan for the Dawson Region is a much stronger plan then the Draft Plan in terms of its support for conservation values and for the protection of water, wildlife and land. There have been several changes that warrant support, including legally designating all Special Management Areas (SMAs) for protection; recognizing the United Nations Declaration of Indigenous Peoples (UNDRIP); recognizing the importance of climate change in the region; nominating Wetlands of Special Importance for protection, and; removing the different threshold levels in the Fortymile caribou corridor based on elevation. These changes are definitely a step in the right direction, but based on our expertise, we still assess that several parts of the planning region and associated issues remain 2 concerning and leave too much of a questionable future. In particular, there are three modifications that we recommend the parties to consider. . .
WCS Canada Comments on Proposed Updates to the Ontario Wetland Evaluation System (ERO No. 019-6160)
The proposed changes to the OWES are highly unlikely to meet the stated purpose by Ontario of increasing housing in Ontario. According to the ERO posting, “streamlining” the wetland evaluation process is necessary to support the construction of 1.5 million new housing units. However, a shortage of land isn’t the cause of the housing shortage in Ontario1.

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