We’ve Commented on Bill 66- The Proposed Great Lakes Protection Act, 2015

The commenting period for the Proposed Great Lakes Protection Act (GLPA) is now closed but Sierra Club of Canada Foundation made a submission last week during the public hearings before the Standing Committee on General Government. Submission below:

Bill 66 (proposed Great Lakes Protection Act)

Submission to the Standing Committee on General Government

23 September 2015


Grant Crack, Chair

Standing Committee on General Government

99 Wellesley Street West, Room 1405

Whitney Block, Queen’s Park

Toronto, ON

M7A 1A2


Sylwia Przezdziecki, Clerk

Tel: 416-325-3515

Fax: 416-325-3505



Cc :  Ellen Schwartzel, Acting Environmental Commissioner of Ontario

We thank you for this opportunity to appear before the Standing Committee on General Government to depute on Bill 66, The Great Lakes Protection Act. 

The Sierra Club of Canada Foundation is Canada’s largest grass roots environmental organisation with antecedents going back to the 1890s.  For many decades the Ontario Chapter of the Sierra Club has been prominent in advocating for the integrity of the Great Lakes –St Lawrence River Basin Ecosystem.  The Great Lakes Project, in co-operation with McMaster University has generated useful research on wetlands in Georgian Bay.  We have participated fully in the activities of the Great Lakes Protection Act Alliance but we have chosen to present a separate more focussed brief to this Committee because we wish to call attention to a few issues that are crucial to the success of this enabling legislation. 

Our submission will be brief.   First and foremost, The Sierra Club of Canada Foundation and its Ontario Chapter are particularly disappointed that Bill 66 provides Cabinet with broad exemption powers from Bill 66.  This provision vitiates the spirit and purpose of The Great Lakes Protection Act.    Para 38(1)(l)  should be removed.

Second,   we consider Bill 66 to be a significant step forward towards protecting human health and ecological integrity in the Great Lakes – St Lawrence Basin.  Healthy Great Lakes are essential to the economic health of this Region.  Bill 66 will not be enough unless it is implemented in a timely fashion with sufficient budget support.  This Bill has been years in the making and it is reasonable to expect quick implementation, particularly with respect to urgent issues such as increasing nutrification in L. Erie and the near shore of all the Basin, the effects of climate change, and habitat loss especially wetlands.

Third, with respect to wetlands protection,  In PART IV TARGETS [section 3],  Bill 66 gives  The Minister of Natural Resources and Forestry the authority to establish one or more qualitative or quantitative targets in respect of “preventing the net loss of wetlands” in all or part of the Great Lakes-St. Lawrence River Basin.   This language will not protect the remaining wetlands in the Basin because it allows the creation of artificial wetlands to make up for the loss of natural wetlands.  We strongly recommend the deletion of the word “net” so that the text reads “preventing the loss of wetlands”.   

Fourth, we particularly support the provision for increased citizen participation, the development of geographically focussed initiatives, regular progress reports to the Ontario Legislature and the continuing development of the Great Lakes Strategy.

In conclusion, we urge the Legislature to pass Bill 66 without delay with an amendment to remove para 38(1) (1) and to expedite its timely and meaningful implementation.

Respectfully presented

Lino Grima, Chair, Water Committee and Co-Chair, Binational Great Lakes Committee

Dan McDermott,  Director Ontario Chapter

Christine Elewell, Chair, Executive Committee, Ontario Chapter

Mary Muter, Great Lakes Project, Sierra Club of Canada Foundation