Adam Weir (Ontario Federation of Anglers and Hunters) on April 30, 2020

1. Do you support Lake Simcoe Watch’s recommendation that the Government of Ontario should develop a plan to reduce Lake Simcoe’s phosphorus pollution to 44 tonnes per year by 2026? If no, do you support the achievement of the 44 tonne per year target by a later date? If yes, please specify the date.

The OFAH supports a strategy to reduce Lake Simcoe’s phosphorus pollution to 44 tonnes per year; however, a recommendation to reach the target load reduction by 2026 may be unachievable. The 2010 Phosphorus Reduction Strategy (PRS) is believed to be an “ambitious and aggressive” plan, and it outlines actions and directives to be undertaken to reach the same target, but by 2045. The Government of Ontario worked with the Lake Simcoe Region Conservation Authority, stakeholder groups, municipalities and other partners, and though we would like to see phosphorus reduced as soon as possible, the outcomes of these collaborations determined that 2045 is a realistic time to achieve the goals and objectives outlined in the PRS. Attempting to have the same results by 2026 is likely setting the goal up for failure; therefore, we recommend aligning with the PRS and reaching the target by 2045.

2. Do you support Lake Simcoe Watch’s proposed actions to reduce Lake Simcoe’s phosphorus pollution? If no, please explain why not and outline alternative actions that you believe should be taken to reduce Lake Simcoe’s phosphorus pollution?

The OFAH supports Lake Simcoe Watch’s proposed actions to reduce Lake Simcoe’s phosphorus pollution; however, it may be beneficial to elaborate on exactly what Lake Simcoe Watch is requesting. For example, the first action in the discussion paper recommends that the OMAFRA develop programs and financial incentives for agricultural producers to adopt BMPs to help with phosphorus reduction, but this approach is open-ended and doesn’t provide specific examples of grants and funding mechanisms. The Lake Simcoe Watch should consider listing broad-based environmental stewardship programs that could be improved upon or developed, and past initiatives that worked well that could be re-administered and that align with the BMPs listed in the discussion paper. Additionally, it may be critical to target more organizations for this action item and include, for example, Lake Simcoe Region Conservation Authority, Ontario Federation of Agriculture, Ministry of the Environment, Conservation and Parks, and Environment and Climate Change Canada.

3. Do you agree that the Development Charges Act should be amended to permit the Government of Ontario and Lake Simcoe municipalities to levy development charges to recover 100% of their costs of reducing Lake Simcoe’s phosphorus pollution? If no, please explain why not and outline how you believe the pollution reduction measures should be paid for.

In general, the OFAH is in agreement with a developer pays system to protect and conserve the environment, but presently, we are not optimistic that this approach will work. Schedule 3 of the More Homes, More Choice Act (Bill 108) makes amendments to the Development Charges Act to reduce development costs. Because the Government of Ontario is currently loosening restrictions and reducing red tape for developers, it may be important to investigate alternative methods for revenue generation. The Lake Simcoe Watch is proposing legislative changes to the Development Charges Act, that alone would likely take several years to implement (if feasible), which would also conflict with the proposed target load reduction by 2026.

4. Please provide any other comments about Lake Simcoe Watch’s report: Cleaning Up Lake Simcoe: A Discussion Paper.

Due to the COVID-19 pandemic, and the associated economic downturn we have and will experience into the future, there will be even less funds available from municipalities, conservation authorities, and government. Considering that the current government is taking action against over-regulation, cutting red tape, and has launched the “Open for Business” action plan, the Lake Simcoe Watch should consider additional innovative solutions and ideas to fund phosphorus reduction initiatives. According to the Lake Simcoe Region Conservation Authority, the annual value of the watershed’s key ecosystem services is estimated to be $922.7 million. It may be of interest to strategically focus on the economics of Lake Simcoe, as a business case, to garner more political interest: investing in communities and businesses in the Lake Simcoe region equates to economic growth and prosperity. This situation may not be ideal, but it’s important to have a plan that reflects the current political and social climate in order for the Lake Simcoe Watch’s goals to be reached.

We would also like to highlight ALUS Canada, a national charitable organization that supports the delivery of the ALUS program across the country. The OFAH administers ALUS Peterborough, one of the OFAH’s Fish and Wildlife conservation programs. It’s designed to support and guide farmers wishing to convert marginal farmland to functioning ecosystems, who are then recognized via management payment support for providing ecological services to the community. This model and approach to conservation has been successfully operating nationally for over a decade. At this point, it is our understanding that there isn’t a chapter for the Lake Simcoe region, and could be an excellent, innovative opportunity for approaching phosphorus reductions.