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Absent targets

By Leah Wong,
Novae Res Urbis GTHA Edition,
March 15 2017

The Ontario Ministry of Natural Resources and Forestry has wrapped up public consultations on its climate adaption strategy, but not without criticism from environmental organizations. While acknowledging the ministry’s “good intentions,” environmental groups cite an absence of targets and timelines and limited opportunities to hear from the public.

In January MNRF posted its strategy, entitled Naturally Resilient, to the provincial environmental registry for public review. The draft document aims to establish a five-year framework to guide ministry ‘s efforts to address climate change risks relates to natural resource management, such as the protection and recovery of species at risk.

The strategy is supposed to complement the province’s recently adopted Climate Change Strategy and Action Plan.

One of the document’s shortcomings, Ontario Nature executive director Caroline Schultz told NRU, is its failure to set specific targets and timelines for the strategy’s implementation. “If we don’t get serious on setting some clear targets and committing the time and resources to achieving those targets, it’s nice words on paper in terms of intentions,” said Schultz. “But, we’re going to be in big trouble if we don’t actually get more practical and real about it.”

Without targets, Schultz said it is difficult to hold the ministry accountable for proposed actions identified in the strategy. For example, one of the actions calls for collecting data on climate change impacts. Ontario Nature suggests the actions need to be more specific than currently stated, such as monitoring the response of climate indicator species to changes in the earth’s temperature.

Her organization also notes that the strategy makes no reference
to the Ontario Biodiversity Strategy that was released in 2005 and renewed in 2011.

Schultz said the biodiversity strategy sets specific targets, such as a commitment to protect 17 per cent of the province’s lands and waters by 2020.

“There’s no reference to the biodiversity strategy [in Naturally Resilient]. And many of the [targets] in the biodiversity strategy are related to increasing and enhancing resilience … which very much relate to climate change adaption,” said Schultz. “There’s no linkage between the documents whatsoever.”

In its submission to the natural resources and forestry ministry, Ontario Nature calls for a better alignment between Naturally Resilient and the Ontario Biodiversity Strategy and emphasizes the need for clear timelines and targets on implementation.

Meanwhile, the Canadian Environmental Law Association is concerned that the draft document seems to suggest the government is only
maintaining the status quo in its approach to address climate change.

“We were expecting a new way of doing things,” the association’s Healthy Great Lakes special projects counsel Anastasia Lintner told NRU. “My assessment of the approach they’ve taken is to look across their current mandates, decide which are at greatest risk due to climate change and then… make some plans about what they are going to do.”

Given the provincial government’s pledge to tackle climate change, Lintner suggests removal of the bureaucratic silos between ministries to assess possible adjustments in their mandates. For example, as protection of the Great Lakes falls within the mandates of several ministries, the government could identify any overlap in efforts among them.

Citing the expert panel on climate change adaptation, she said “they talked about the importance of not siloing and having a central agency that thinks about [climate change] and figuring out [if] each ministry needs to make adjustments.”

Lintner adds: “[For example] for recommendations on the Great Lakes, it doesn’t even speak to specific ministries. It speaks to the issues that need to be tackled.”

The Canadian Environmental Law Association is one of several organizations dismayed at the consultation process. In early March the association wrote to the ministry asking for a halt to the consultations to allow for a cross-ministerial approach to climate change.

Ontario Headwaters executive director Andrew McCammon told NRU that
the approach used by the ministry was a major shift from previous models for ministries when handling complex files.

With the Great Lakes Strategy, for example, the ministry introduced a white paper before holding public consultations. A directions paper followed, based on feedback to the white paper, thereby enabling comments from stakeholders. In the consultation phase, McCammon said stakeholders noticed that the white paper failed to mention that the policy would be founded on watershed management principles.

“[This is] the reason why public consultation can in some instances inform the government and in other [cases] allow the stakeholder group to have their fears alleviated about what words means,” said McCammon.

In its submission to the ministry signed by eight environmental organizations including the Coalition on the Niagara EscarpmentCredit River Alliance and York Region Environmental Alliance, Ontario Headwaters requested a revision in the current consultation format. McCammon said he could understand if the government had used the draft document internally to facilitate collaboration between Natural Resources and Forestry and Environment and Climate Change, but he said the government’ intentions on the strategy are a “complete mystery.”