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Re: Remedying Negligence in the 2019 Rouge National Urban Park Management Plan
I am disappointed and upset that the 2019 Rouge National Urban Park (RNUP) Management Plan proposes to delay or avoid the implementation of existing “due diligence” plans for combating pollution, climate change, flooding and biodiversity loss. The RNUP Management Plan disregards the legal imperatives outlined by the Canadian Environmental Law Association and the following input by Dr. Mandrak, a University of Toronto professor and scientist:
“Environment Canada’s recommendations for more than 60% forest and wetland cover were largely incorporated within existing Rouge Park, Watershed and Federal Green Space Master Plans … The timely implementation of these conservation recommendations and plans is essential to address federal mandates under the RNUP Act, Great Lakes Water Quality Agreement, Paris Climate Change Accord, and International Convention on Biodiversity.”
Contrary to federal laws and public mandates, the RNUP Management Plan fails to prioritize ecological integrity and it demonstrates shocking negligence by:
- Proposing to delay or avoid science-based plans for increasing forest and wetland cover from 38% to 60%;
- Disregarding Toronto Remedial Action Plans for improving Great Lakes water quality and health;
- Disregarding federal commitments to “meet or exceed” existing Greenbelt and Rouge Park requirements;
- Disregarding the reforestation of the Ontario Greenbelt and Rouge Park “main ecological corridor”;
- Disregarding Treasury Board rules for responsible and best-public-value land management.
Pollution and climate change are inflicting an increasingly heavy toll on people, property, infrastructure and nature. Scientific research and the Insurance Bureau of Canada’s report “Combating Canada’s Rising Flood Costs” confirm that forest and wetland restoration is a cost-effective way to mitigate pollution, climate change, flooding and biodiversity loss.
Since the involvement of the Federal Government, the rate of forest and wetland restoration in RNUP has fallen by 80%, despite a $16 million park budget increase. If this inefficiency and negligence persists, Canadians will suffer an additional $100 million in liabilities each year due to unmitigated pollution, climate change and flooding impacts, and reduced watershed, ecosystem and public health.
To remedy this negligence, will you urge the Federal Government and Parks Canada to:
1. Increase forest and wetland habitat in RNUP to 50% within 10 years, and 60% within 25 years;
2. Reforest the park’s “main ecological corridor” between Lake Ontario and the Oak Ridges Moraine;
3. Require land management and private lease conditions which facilitate the implementation of forest and wetland restoration plans, best public value, and ecologically compatible farming;
4. Expand the park from 79 to 100+ square kilometres by adding surrounding public lands.
Contrary to Treasury Board rules, approximately half of the public lands in RNUP have been leased for less than 40% of their fair market value, due to the absence of a transparent and competitive leasing process. These public lands are privately leased to grow pesticide dependent cash crops, such as GMO corn and GMO soybeans, for fuel additives, export and cattle feed – NOT local food. Cash cropping utilizes pesticides and fertilizers. These chemicals can harm water quality, people, pollinators, and fish and wildlife – contrary to the goals of a national park.
Many of the people leasing public land in RNUP are not heritage farmers; they are simply people with favourable government connections. If taxpayer-subsidized cash cropping continues on the public lands in RNUP, the federal government will be creating unfair competition for private land farmers, contrary to fair trade agreements, and Canadians will not obtain “best value” for the public lands in this national park.
Approximately 50% of the public lands in RNUP are not currently leased for farming, therefore, forest and wetland cover should be increased to 50% by 2029. The restoration of 60% forest and wetland habitat by 2044 will leave 40% of the park’s public lands available for ecologically compatible farming leases. This constitutes a generous accommodation of private leases on public lands in this national park in Canada’s most populous and under-protected region – the Carolinian Forest Zone – home to more than 20% of Canada’s endangered species.
I look forward to your timely and clear response to each of the four questions in this letter.
[Your Name and Municipality]
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