Lake Ontario St. Lawrence River Plan 2014

Ecosystem Health

The IJC concludes that Plan 2014 will provide the best balance between environmental concerns and other interests including navigation, hydropower, domestic and industrial use, recreational boating and coastal development. This conclusion is consistent with the opinions offered by the U.S. Department of Interior, the U.S. Environmental Protection Agency and Conservation Ontario.  Most non-governmental environmental organizations in New York, Ontario and Quebec that responded during the 2013 hearings supported Plan 2014 because of its environmental benefits. Opponents of Plan 2014 argued that the environmental benefits were not as certain or important as suggested by IJC studies, and that negative environmental impacts of the plan were not adequately considered. 

Comment Received

IJC Response

Plan 2014 is central to the long-term success of the Great Lakes Restoration Initiative and overall restoration of this important ecosystem. It will set the stage for the restoration of 64,000 acres (26,000 hectares) of wetlands, easily the largest Great Lakes restoration effort to date.

The IJC agrees and notes that Plan 2014 appears to be consistent with the goals of the 2012 Great Lakes Water Quality Agreement to restore habitat and biodiversity.

Plan 2014 will restore a diverse wetland community that provides critical ecosystem functions such as buffering storm water and filtering non-point source pollution.


IJC agrees that Plan 2014 will restore the diversity of plant life and the health of tens of thousands of acres of coastal wetlands on Lake Ontario and the upper St. Lawrence River. This will improve the habitat for a wide range of native birds, fish, reptiles, amphibians and mammals. We also note that other efforts, such as sustaining programs to control and remove invasive plant species are important to realize the full potential provided by more natural hydrology. Healthy wetlands provide a variety of beneficial functions, but the IJC has not quantified differences in storm impacts or water quality improvement. 

Scientific research conducted during the LOSLR study clearly establishes the many environmental benefits from the plan, including improvements for key wetland habitats, muskrats, migrating and nesting wildfowl, and indicator species like the northern pike. It is important to note, each of these performance indicators is an indicator representing a much broader segment of the ecosystem.

The IJC agrees and notes that the environmental performance indicators were selected, in part, because they had broader implications beyond the success of a single species. For example, Plan 2014 demonstrably increases muskrat house density in the upper St. Lawrence River. Muskrats help harvest cattails and in doing so, create micro habitat areas that support other species. The success of northern pike also indicates favorable conditions for other cool water fish that spawn in nearshore areas.

Plan 2014 gives the environment too high a priority. The infrastructure, commerce and tax base of our community should not be risked for the welfare of a few birds, muskrat and fish.


The IJC is addressing the interest that people have in healthy ecosystems. This interest was not recognized when Plan 1958DD was developed but is clearly articulated in the laws, policies and decisions of Canada and the United States since then. Plan 2014 does not fully address the environmental damage caused by Plan 1958DD, but carefully balances environmental restoration with other societal needs.

If it is important to save the muskrats, why is there no bag limit on hunting them in northern New York?

The Muskrat is not a listed species; the goal here is to increase their numbers in coastal wetlands because they reduce the dominance of cattails and support Black Tern nesting, not to keep the general population from extinction. Field surveys indicated low house densities in wetlands of the Upper St. Lawrence River, which affects those wetlands negatively. The Black Tern is designated as vulnerable by Ontario Ministry of Natural Resources and Forests (OMNRF) and Endangered by New York State Department of Environmental Conservation (NYSDEC). The North American Bird Conservation Initiative considers the Lower Great Lakes/St. Lawrence plain critical to the natural cycle of the Black Tern.  Studies show that Plan 2014 could make a significant contribution to improving habitat for a variety of native species.

The IJC’s environmental studies are flawed. Wetlands have been degraded by development, polluted runoff and a variety of other factors besides the regulation plan.

The vast majority of, but not all, coastal wetlands will helped by more natural water level fluctuations.  The Study Board acknowledged that some wetlands are degraded by factors other than hydrology. The environmental studies for Plan 2014 are supported by extensive field data, on-site demonstrations, and peer-reviewed literature. The hypothesis is that the pattern of more natural water level fluctuations will favor certain plant species over others, depending on the plants’ water needs. The correlation between water-level fluctuations and plant diversity is backed up by extensive field work in 32 wetlands on Lake Ontario and the upper St. Lawrence River, which were selected to avoid those impacted by development or polluted runoff. Portions of the findings have been replicated in diked wetlands on Lake Ontario where water levels are artificially controlled. In addition, the study findings were published in peer-reviewed scientific journals and are supported by a body of literature on water-level regulation in other freshwater lakes. The IJC is confident that water-level regulation has led to large-scale degradation of coastal wetlands in Lake Ontario and the upper St. Lawrence River.

Why not restore wetlands through other means such as harvesting cattails mechanically?

Addressing the fundamental hydrologic requirements of coastal wetlands is critical.  Resource managers in both countries report that engineering projects to restore wetlands are expensive, and their success is limited by the unnatural regulation of Lake Ontario water levels under Plan 1958DD.

Increased flooding from Plan 2014 will cause hundreds of septic-tank overflows and runoff of sediment and nutrient loadings. The IJC has not studied these environmental impacts on water quality.

Septic systems that will be vulnerable to flooding under Plan 2014 are already vulnerable to flooding under Plan 1958DD .

Increased erosion rates from Plan 2014 will impact conservation areas and the nests of species such as Bald Eagle, Cliff Swallows, and Piping Plover habitat.

Plan 2014 might result in some habitat impacts, but they will be small compared to the impacts of erosion and flooding that will occur under any regulation plan. Some have suggested that the lower levels of Plan 2014 will help nourish beaches, improving the habitat for Piping Plover. The Study Board and the IJC note that the hardening of the shoreline may have reduced the potential for this sort of beach nourishment, but did not rule it out.

Is there a risk that higher water levels on Four-Mile and Six-Mile creeks would flood the Ordnance Works that was used to store radioactive waste?

No; an increase in Lake Ontario levels will not influence creek levels that far from the lake. If there is a risk of flooding of radioactive waste, it is not affected by lake level regulation.