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The Right Honourable Stephen Harper, Prime Minister, and all Members of Parliament

Dear Prime Minister Harper and Members of Parliament,

We represent First Nations and environmental, recreation and grassroots groups supported by more than half a million Canadians. We are disappointed that, despite the opposition of millions of Canadians to the attacks on nature and democracy in omnibus bill C-38, the government has again chosen to rewrite some of Canada's foundational environmental protection laws by inappropriately including amendments in another massive omnibus bill, C-45.

Again, this is a two-pronged attack on our democratic processes, as this bill seems designed to short-circuit parliamentary discussion of major legislative changes that would significantly reduce opportunities for public consultation.

Bill C-45 would further undermine the protection of Canadian nature by making substantial changes to the Navigable Waters Protection Act (NWPA, proposed to be the Navigation Protection Act), the Fisheries Act and the Hazardous Materials Information Review Act — critical laws that were once used to steward a sustainable environment, clean water and healthy oceans for all Canadians.

Together, the changes proposed in the omnibus bill would further weaken Canada's environmental laws, remove critical federal safeguards, and reduce opportunities for the public to have their say about projects that could threaten the air, water, soil and ecosystems on which all Canadians, and our economy, depend.

The proposed changes to the NWPA are disturbing on several levels. The result is that the vast majority of Canada's lakes and rivers would no longer enjoy proactive federal navigation protection under the new act. Instead, concerned citizens would be forced to spend their time and money in the courts fighting to protect their rights to unobstructed waterways. For those water bodies that remain "protected," the changes would also eliminate all automatic public participation from decision-making, allowing the minister of transport to fast-track specific projects without even notifying, let alone consulting, the public.

Changes to the Fisheries Act, also buried in the bill, would further dismantle this key environmental law by giving industry the option to request that their existing commitments to protect fish habitat be amended or cancelled, or that they be let off the hook for promised compensation for lost or damaged habitat.

The changes in Bill C-45 would also eliminate the Hazardous Materials Information Review Commission, an independent body charged with making science-based decisions to protect Canadians from toxic chemicals and hazardous materials in the workplace. This could result in less disclosure from companies about the chemical contents of their products. Canadians deserve accountability and transparency about the use and distribution of toxins, yet if the commission is eliminated no independent body will oversee industry requests to mask chemical contents of the products that industry uses or produces.

Bill C-45 further demonstrates a pattern of recklessness by the federal government that puts the long-term safety and health of Canadians in jeopardy. These are major changes that, if not stopped now, will ripple out across communities everywhere in Canada — putting our water, air, food and quality of life at risk.

We urge every Member of Parliament to stand up for nature and democracy by voting for amendments to Bill C-45 that would prevent such damaging changes from being written into law.


l'Association québécoise de lutte contre la pollution atmosphérique (AQLPA)
BC Assembly of First Nations
Canadian Parks and Wilderness Society
David Suzuki Foundation
Environmental Defence
Greenpeace Canada
Greenpeace Québec
Idle No More (Saskatchewan Grassroots Advocacy Group)
Nature Canada
Paddle Canada
Pembina Institute
Ontario Rivers Alliance
Sierra Club Canada
Union of British Columbia Indian Chiefs
West Coast Environmental Law
World Wildlife Fund

November 21, 2012