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
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
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
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
Idle No More (Saskatchewan Grassroots Advocacy Group)
Ontario Rivers Alliance
Sierra Club Canada
Union of British Columbia Indian Chiefs
West Coast Environmental Law
World Wildlife Fund
View the letter, backgrounder and media release online:
For immediate release: November 21, 2012
Environmental groups, First Nations join in opposition to omnibus Bill C-45
Massive bill before Parliament further undermines Canadian democracy and
environment, groups say in open letter
TORONTO –First Nations and environmental, recreation and grassroots groups supported by more than
half a million Canadians today issued an open letter opposing the federal government’s controversial
second omnibus bill, C-45, as the proposed legislation enters final rounds of debate in Parliament this
“The changes proposed in this omnibus bill would further weaken Canada’s environmental laws, remove
critical federal safeguards, and reduce opportunities for the public to have their say about major
industrial projects that could threaten the air, water, soil and natural ecosystems on which all Canadians,
and our economy, depend,” they said in the letter.
The signatories include the BC Assembly of First Nations, the Union of British Columbia Indian Chiefs,
leading environmental organizations, including the David Suzuki Foundation, Ecojustice, Équiterre, and
the World Wildlife Fund, and groups from different sectors, nationwide (see below).
The organizations are speaking out against Bill C-45’s deregulation of some of Canada’s key
environmental laws, including major changes being proposed to the Navigable Waters Protection Act
that would see just 97 of Canada’s approximately 32,000 major lakes protected by the stripped-down
act. Major pipelines would also be exempted under the new law, meaning that the scope of impacts
considered during environmental reviews will be narrower.
“Simply put, lakes, rivers and streams often stand in the path of large industrial development,
particularly pipelines. This bill, combined with last spring’s changes, hands oil, gas and other natural
resource extraction industries a free pass to degrade Canada’s rich natural legacy,” said Devon Page,
executive director of Ecojustice.
The latest omnibus legislation would further undermine the protection of Canada’s environment by
making changes to the Fisheries Act and the Hazardous Materials Information Review Act — critical laws
that are used to steward a sustainable environment, clean water and healthy oceans for all Canadians.
Meanwhile, organizations argue the bill represents a two-pronged attack on Canada’s democratic
processes, seemingly designed to short-circuit parliamentary discussion of major legislative changes that
would significantly reduce opportunities for public consultation.
“This week may be the last time that Members of Parliament will be able to prevent the further loss
of environmental protection and public participation that this bill contemplates,” said Jessica Clogg,
executive director and senior counsel, West Coast Environmental Law.
“That’s why we’re asking our elected officials to stand up, for Canada’s environment and their
constituents who depend on it, and oppose this bill.”
Tabled in October, Bill C-45 follows a drastic overhaul of Canada’s federal environmental laws in the
spring omnibus budget bill, C-38. The negative impacts of C-38 are already being seen on the ground and
in massive staffing cuts to federal environmental departments.
In their open letter, the groups argue that 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.”
The signatories are:
l’Association québécoise de lutte contre la pollution atmosphérique (AQLPA),
BC Assembly of First Nations, Canadian Parks and Wilderness Society, David Suzuki Foundation,
Ecojustice, Environmental Defence, Équiterre, 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.
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View the letter, backgrounder and media release online:
French (available after 5:30am Eastern time):
For more information, please contact:
Devon Page, Executive Director, Ecojustice: 604-685-5618 ext 233; 778-828-5512;
Jessica Clogg, Executive Director and Senior Counsel, West Coast Environmental Law Association: (604)
601-2501; mobile: 778-327-8964; Jessica_Clogg@wcel.org
Karel Mayrand, Directeur général, Foundation David Suzuki (Montreal); 514-871-4932;
How Bill C-45 weakens our environmental laws and democracy?
Questions & Links to Answers:
Where can I find more about Bill C-45 weakening of the Navigable Waters Protection
For a detailed backgrounder on the Act published by Ecojustice, go to:
What other environmental legislation has been weakened or is threatened by the
federal government and where can I find more about this other legislation?
The Canadian Environmental Assessment Act (CEAA), Fisheries Act, Species At Risk Act
and National Energy Board Act have all either been weakened or are at risk. On C-45’s
weakening of the CEAA, see West Coast Environmental Law’s Nov. 7th submission to the
House of Commons Standing Committee on Environment and Sustainable Development:
For further information about C-45’s impacts on other environmental laws and about
other legislation now at risk, see Ecojustice backgrounders:
What amendments to Bill C-45 are you recommending?
For specific amendments recommended by one environmental law organization, see
this submission to the Standing Senate Committee on Energy, the Environment and
Natural Resources, November 20, 2012:
Who initiated this open letter?
A group of Canada’s leading environmental organizations: Canadian Parks and
Wilderness Society, David Suzuki Foundation, Ecojustice, Environmental Defence,
Equiterre, Nature Canada, Pembina Institute, Sierra Club Canada, West Coast
Environmental Law and World Wildlife Fund.
What other links to recent media would you recommend?
Blog on C-45 and changes to NWPA:
Globe and Mail op-ed on C-45 and changes to NWPA:
Could you recommend other media releases about Bill C-45?
For the Oct.18, 2012 response of Canada’s leading environmental organizations to
announcement of Bill C-45, click here:
For the Oct.18 response by Ecojustice, go to:
For the Oct.19 response by West Coast Environmental Law, go to: http://wcel.org/