Breaking down silos in the North

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In 2007, the ECO undertook an extensive analysis of the environmental implications of various land use policies and allocation decisions in Ontario’s northern boreal landscape. The following articles are included:

The Canadian Council of Forest Ministers committed to a bold vision for our country’s forests in 1998. They stated, “Our vision of sustainable forest management includes integrated land use and forest management plans for important values at appropriate scales from the whole landscape to the local site, for short- and long-term goals. It will require research, continual learning and adaptation, using ecologically sound and scientifically advanced tools and practices, to realize the concept.” This vision also stressed that biodiversity and essential ecological process must be maintained.

The evidence presented in this section of the ECO Annual Report brings into serious question whether this type of vision has been applied to northern Ontario. Northern Ontario has a unique and varied ecology, which the ECO believes necessitates at least the same standard of planning that applies to the rest of the province. The status quo is not sustainable.

It is evident that the Ontario government approaches issues in the north in a highly compartmentalized fashion, with potentially severe environmental consequences. A silo mentality is evident not only at the ministry level, but also in individual programs within ministries. This is a failure in governance. The National Round Table on the Environment and the Economy noted in 2005 that this type of unwieldy division of responsibilities in the boreal causes “planning and decision-making processes [to] remain isolated from one another, inhibiting efforts to set landscape-level objectives and manage the cumulative effects of development across all sectors.” Indeed the Royal Commission on the Northern Environment came to a similar conclusion in 1985.

Currently, the contributions of many key ministries in planning for the north is most notable by their absence. MOE has cast itself in a very narrow role with respect to the north, despite its mandate to ensure ecological protection and sustainable development across the province. Its presence is mainly manifest in its issuance of certificates of approval. Often, these isolated approvals by the ministry relate to large projects, but fail to address the cumulative impacts on the environment. MOE also appears to have retreated to being merely an administrator of the Environmental Assessment Act, rather than trying to ensure that other ministries stringently adhere to the EA process.

Other ministries, such as ENG, appear not to comprehend the impact of their policy choices on northern Ontario. ENG’s role may not be as prominent as that of other ministries. However, the few decisions that it makes with respect to northern Ontario have enormous environmental consequences. For example, it is illogical that any approvals process for a hydro transmission line stretching from Manitoba to central Ontario could occur without being considered as part of a larger land use planning exercise.

Without a comprehensive land use planning system in place for the north, the current system of forest management planning ends up being the de facto land use planning system. In focusing on forest management, MNR treats the management of all other components of Crown land, such as conserving biodiversity, as a lesser priority. MNR is poised to push this system further northward through its Northern Boreal Initiative. The forest management process is intended to be “sustainable,” but it is not intended to comprehensively plan for all values across the landscape. Indeed, some ecological values that are fortunate enough to be considered in a forest management process, like woodland caribou, still face very perilous futures.

Moreover, Ontario’s existing regulatory structure for mineral development is the antithesis of a comprehensive land use planning system. The Mining Act causes public land to be treated as freely open to mineral exploration. It assumes that mineral development is the preferred form of land use in almost all circumstances. MNDM itself states that “prior consent to stake or prior notification of the owner of the affected land is not required.”

Under such a system, the protection of ecological values or the consideration of other interests is relegated to being an afterthought and the cumulative impacts of development are not well addressed. The Ontario government reinforces this approach in choosing to take a “one-window approach” through MNDM on large-scale mineral developments in the north. The consequence of these policy choices is that environmental and land use planning concerns are a low priority, if one at all.

Not only is planning in the north undermined by the silo approach taken by ministries, but it is also being compromised by the geographic piecemeal approach to planning for the north. Under the NBI, planning is to be conducted separately for each of the regions in the NBI area, as determined by each of the lead First Nation communities. Without landscape-level guidance, this approach renders it difficult for the province to meet important land use planning objectives. For example, a landscape-level approach is needed to create protected areas that are sufficiently large to maintain ecological integrity.

The Ontario government can choose a different path. In the past, the government has targeted particular regions of the province in developing progressive and innovative land use planning systems. On a smaller scale, it has done so through laws such as the Niagara Escarpment Planning and Development Act and the Oak Ridges Moraine Conservation Act, 2001. On a larger scale, it has done so through initiatives such as Ontario’s Living Legacy.

In 1997, the Ontario government initiated a process to determine a strategic direction for the management of 45 per cent of the province, encompassing all Crown lands within the AOU. The then-Minister of Natural Resources stated, “We will build consensus on the protection and use of our resources. We are responding to the public’s demand for a comprehensive system of managing our valuable natural resources.” It became the most extensive land use planning process in the history of the province, with the public submitting more than 40,000 comments. The result was Ontario’s Living Legacy in 1999, which essentially provides land use direction for the middle third – approximately 39 million hectares – of the province.

The boreal forest and tundra above the AOU are approximately the same size as the AOU – one-third of the province. However, there are two fundamental differences between these two areas: the northern third of the province is, as of yet, relatively unimpaired by development, and it has not been subject to any comprehensive land use planning process. The need for a new approach for northern Ontario is all the more urgent as the region represents a rare opportunity to find solutions before problems become unmanageable. The same public interest found in Ontario’s Living Legacy exists for developing an ecologically sensible planning system for all of the north.



Recommendation 5:

The ECO recommends that MNDM reform the Mining Act to reflect land use priorities of Ontarians today, including ecological values.





This is an article from the 2006/07 Annual Report to the Legislature from the Environmental Commissioner of Ontario.

Citing This Article:
Environmental Commissioner of Ontario. 2007. "Developing Priorities: The Challenge of Creating a Sustainable Planning System in Northern Ontario." Reconciling our Priorities, ECO Annual Report, 2006-07. Toronto, ON : Environmental Commissioner of Ontario. 69-71.

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