February 12, 2002

The Commission’s review and comments on the Stage 2 Metro Toronto and Region RAP reflect an assessment of the document submitted in relation to the five Stage 2 requirements outlined in the introduction , consideration of the implementation of an ecosystem approach to the restoration and protection of beneficial uses, and an assessment of adequacy of public consultation.

Have in-place remedial measures been evaluated?

Although the Stage 2 RAP does not specifically contain an evaluation of in-place remedial measures, it does outline ongoing and recently completed actions on page 56 and a further listing of ongoing projects in Appendix D. The latter listing is an excerpt of a document entitled Water Quality Improvements that completed in June 1993. Evaluation of these and other remedial actions are being undertaken in updates such as the recently completed Clean Waters-Healthy Habitats Progress Report that was published in November 2001.

Have alternative additional measures to restore beneficial uses been evaluated?

Proposed remedial options have been subjected to extensive technical and public scrutiny beginning with the completion of a Draft Discussion Paper on Remedial Options in September 1988. Subsequently the Technical Advisory Committee and the Public Advisory Committee reviewed and commented on the proposed remedial options.

Have additional remedial measures to restore beneficial uses been selected?

The Stage 2 document outlines 53 recommended actions toward the restoration and protection of beneficial uses. These recommendations represent an enhancement of the draft remedial options that were previously outlined in the 1988 draft discussion paper.

Has a schedule for implementation been adopted and have persons and agencies responsible for implementation of remedial measures been identified?

The RAP document details schedules for implementation and all implementing agencies and units of government. In addition, in many cases, cost estimates have been developed for the recommended actions. This action, in particular, is useful in priority setting and planning for future required actions. As mentioned on page 29 of Clean Waters-Healthy Habitats report a recent review of the 53 recommended actions has been completed.

Has an ecosystem approach been taken to the restoration and protection of beneficial uses?

The Metro Toronto and Region RAP has clearly adopted and advocated an ecosystem approach to the restoration and protection of beneficial uses. One of the RAP’s principles outlines the need to manage the waterfront and watersheds using an ecosystem approach. The focus on ecosystem processes and the health of the watershed ecosystem in Chapter 6 of the RAP document confirms the correct adoption of an ecosystem approach to the restoration and protection of beneficial uses.

Was the public consulted adequately?

Based on the documentation provided in the RAP document, it is readily apparent the RAP Team has undertaken an admirable effort to consult with the public in the remedial action decision-making process. The RAP notes “Without public involvement, from planning to implementation, the plan has little chance of success.” Continuation of the current community-based initiative will help ensure protection of restored beneficial uses in the future.

Conclusion

The Toronto and Region Stage 2 RAP represents an excellent example of a community-based implementation effort. It is clear that a long-term effort focused on 53 recommended actions is being logically undertaken. In particular, the evolution of the approach to stormwater management is noted. The extensive watershed-based efforts of the Waterfront Regeneration Trust and the Toronto and Region Conservation Authority in cooperation with Environment Canada and the Ontario Ministry of Environment have contributed to an effective implementation structure.

The public consultation efforts that have been undertaken are impressive. Workshops and other public outreach activities continue to increase public awareness of RAP goals. The Commission looks forward to the continued reporting of progress toward the restoration of beneficial uses in the Toronto and Region Area of Concern.