July 28, 2008
The Honourable Lawrence Cannon
Minister of Transport, Infrastructure and Communities
Tower C - 330 Sparks St.
Ottawa, Ontario, Canada
K1A 0N5
Re. : Environmental Non-Government Organization (ENGO) response to proposed changes to the federal Navigable Waters Protection Act
Honourable Minister:
As member organizations and supporters of the National Water, Fisheries and Oceans Caucus (“Water Caucus”) of the Canadian Environmental Network, we are writing to you regarding our concerns on the proposed changes to Canada’s Navigable Waters Protection Act by the Standing Committee on Transport, Infrastructure and Communities.
The Canadian Environmental Network is a network of environmental non-government organizations (ENGOs) across Canada which coordinates the work of national caucuses made up of participants drawn from its affiliated member groups. The scope of the Water Caucus includes issues related to water quality and quantity, oceans and fisheries, with the main objectives of sharing information, developing joint strategies, helping each other, and providing advice to the government.
The undersigned members of the Water Caucus believe that the Standing Committee did not provide adequate consultation on the proposed amendments to the NWPA, given that organizations invited to provide submissions did not include paddling organizations – commercial or recreational. The proposed changes to the NWPA could have a profound effect on the activities of paddling organizations on Canadian waterways.
Further, we were disappointed to see that the recommendations of the few organizations that did make submissions were largely ignored. Lake Ontario Waterkeeper, for example, suggested in their submission of May 12, 2008 that three of the proposed amendments could impede free passage and have serious impacts on the protection of navigable waterways in Canada. The specific amendments of concern include changing the definition of “navigable waters” and “work,” as well as deleting the four “named” works from the Act. Lake Ontario Waterkeeper believes that these changes should not be put forward without further consultation and study. However, in their June 12, 2008 news release, the Standing Committee recommended that the government go ahead with all of the amendments to the NWPA that they believe “could be resolved quickly,” including the amendments Waterkeeper advised against pursuing.
While the Standing Committee’s news release does indicate further consultations will be made on this piece of legislation, we have reason to be concerned that future consultations and follow-up will be inadequate, given the actions of the Standing Committee to date, as outlined in this letter.
On behalf of the Canadian Environmental Network’s Water Caucus, we respectfully request a meeting with Transport Canada in order to address our concerns with public consultation regarding amendments to the NWPA.
Sincerely,
Alberta Wilderness Association, AB
Canadian EarthCare Society, BC
Concerned Citizens for a Safe and Healthy Environment, SK
Conservation Council of New Brunswick
Coureurs de Bois Club Ottawa, ON
David Suzuki Foundation
Dog Lake Association, ON
Federation of Alberta Naturalists, AB
Friends of Lily Lake, NB
Friends of the Oldman River, AB
Georgia Strait Alliance, BC
Grand Riverkeeper Labrador, Inc, Nf/Ld
Great Lakes United, ON
Lake Ontario Waterkeeper, ON
Les Amis de la Riviere Kipawa, ON
Les Intendants du Madawaska, NB
The Onoway River Valley Conservation Association, AB
Petitcodiac Riverkeeper, NB
Safe Drinking Water Foundation, AB Chapter
Shearwater Marine Services, SK
Sierra Club Canada
Soil and Water Conservation Society, BC Chapter
South Peace Environment Association, AB
Whitewater Ontario, ON
Yukon Canoe and Kayak Club, YK
cc. The Honourable John Baird, Minister of the Environment
House of Commons Standing Committee on Transport, Infrastructure and Communities
David Osbaldeston, Manager, Navigable Waters Protection Program
Krystyn Tully, Vice-President, Lake Ontario Waterkeeper
Read About: Money and The Kipawa River, Whitewater Ontario,Les amis de la rivière Kipawa,The Proposed Tabaret River diversion project, Northern Ontario Liquid Adventurers,Canadian Rivers Network The viewpoints and opinions expressed here are those of the author and are not necessarily those of Whitewater Ontario or Les Amis de la Riviere Kipawa. Those groups did not vet these comments and would not likely endorse the views expressed here or the manner in which they have been expressed.