October 17, 2003
Port Hope Area Initiative
P.O. Box 118,
110 Walton Street
Port Hope, ON L1A 3V9
RE: Baseline Characterization Study Criteria
Dear Ms. Stickley,
Further to your letter of October 1, 2003 regarding the upcoming Expo ?03, we would like to voice our concern that some key indicators have not been included in your baseline criteria. You indicate in your letter that the list of Valued Ecosystem Components (VECs) is a working list. We therefore request that you update this list to reflect the following information for both Port Hope and Port Granby:
- Under the Aquatic component, contaminants in tissues of aquatic biota will be studied. Your VECs should be revised to include an assessment of the local subsistence fishery; your current list includes sport fishery and we are concerned that you will only study catch-and-release activities. As you are aware, the Ganaraska River is famous for its fish; indeed, the prominence of the fish cleaning station at the mouth of the river attracts many fishers to the area. Lake Ontario Waterkeeper represents the many people who are eating fish from the Ganaraska River and Lake Ontario: this is a highly valued component of the ecosystem and should be included in your baseline studies.
- Under the Terrestrial component, it is not clear whether or not the term wildlife includes birds. It is imperative that contaminants in birds especially migratory birds be studied, and that hunters be included in your list of VECs. Like fish, many of the birds in the Port Hope area are being consumed; contaminants in migratory birds are of particular concern because the birds travel thousands of kilometres to be consumed in communities far from Port Hope.
Lake Ontario Waterkeeper has observed species such as Canada Geese, mallards, black ducks, green wing teals, wood ducks, pintails, greater and less scaulp, whistlers, old squaw, and widgeons in the Port Hope area. Further, there is no consumption restriction program for migratory birds as exists for fish; we represent families on Lake Ontario that consume wild duck on a weekly basis and we need to ensure they are protected from potential contamination in the Port Hope area.
We first raised concerns about potential impacts of contamination on people who consume birds and fish from the Port Hope area in our April 2002 comment. Referring to the 1990 RAP reports, we argued that the Ganaraska is in fact a highly popular fishing area and noted that contamination in migratory birds would have negative impacts in communities outside of Port Hope. This information counters the 1990 statements suggesting only ?some? fishing occurs in the area and ?hunting is not permitted? so risk of environmental impact is minimized.
As Environment Canada stated in a comment on the Toronto Port Authority's Fixed Link EA, Baseline environmental conditions are generally characterised using observational data. We trust that the assessment process in Port Hope will examine actual conditions in the existing environment instead of favouring risk assessment projections. The legal standards for protection of fish and migratory birds are clearly set out in the Fisheries Act and the Migratory Birds Treaty Regulations.
We expect that you will make the appropriate revisions to your baseline characterization studies.