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Let’s Decommission the Hillsburgh Dam and Bridge, Town of Erin

Trout Unlimited Canada and the Ontario Rivers Alliance are requesting the County of Wellington Warden and Councillors consider supporting the decommissioning of the Hillsburgh Dam with an offline pond, which is the preferred alternative from a natural heritage perspective. This would provide positive environmental benefits to the West Credit River ecosystem, provide resilience to climate change, and support a multi-species ecosystem-based recovery initiative for the long-term.  Continue reading


NEB Modernization Review – ORA Submission

The NEB has proven to be an industry friendly structure aiming to support and promote energy markets for the oil and gas and pipeline industry – yet the NEB is also charged with regulating, approving, monitoring and enforcing compliance of this same industry. ORA submits that this is a conflict of interest, and raises real questions about the independence and objectivity of the NEB, and just how well the environment and public safety is being protected. The federal government’s reliance upon tax revenues and the need for job creation from the energy industry has led to a significant lack of environmental rigor in its decision making.

The recent NEB ruling of reasonable apprehension of bias in favor of TransCanada, came as a result of the NEB panel’s inappropriate conduct in relation to their meeting with Jean Charest while he was acting as an advisor to TransCanada. This conduct only came to light through a Freedom of Information Application. Confidence in energy projects can only come when we have an open, transparent and accountable government.  Continue reading


EBR 012-9499 – Naturally Resilient – MNRF’s Natural Resource Climate Adaptation Strategy

The focus of the Strategy’s five goals should not just be on “Natural Resources”, but rather on the resilience of the province’s natural heritage landscape, using a watershed approach, in consideration of the cumulative effects of all past, present and future development on our air, land and water. Additionally, the scope of the Strategy must be broadened to encompass a review of all policies, guidelines and legislation that do not support the resiliency, conservation and protection of our streams, rivers, lakes and wetlands in this warming climate. Continue reading


American Eel Engagement Workshop – Government Response Statement

As a potential next step for the Ottawa River, we recommend assessing a suitable location for a ladder at the Carillon Generating Station over the next 1-2 migration seasons coupled with a commitment to providing passage the following year. Studies conducted by Hydro QC and Milieu Inc. in 2001 and 2010 revealed that more elvers approach the southern turbines than northern ones; however, shorelines, the shipping canal, and the spillway were not assessed. It is reasonable to delay installing a permanent ladder until such assessments are completed; however, free passage should be provided by the 2019 migration season. Consideration should be given to translocating elvers captured during such assessments above the Carillon Generating Station. Continue reading


Environment and Health Groups’ Statement on Triclosan

The government’s proposed P2 Plans on triclosan are inadequate to address its continued use in consumer products and presence in the environment. Rather, the government’s proposal will ensure the on-going use of triclosan in consumer products. Unless there is a prohibition of triclosan in personal care products and other consumer products, the substance will continue to be released into the aquatic environment, including the Great Lakes and waterbodies across Canada, creating unnecessary risks to aquatic and terrestrial species. The US Food and Drug Administration (FDA) requested data demonstrating that consumer products containing antimicrobial ingredients are effective in their stated purpose – to prevent infections. The FDA did not receive such data and therefore passed its final decision to prohibit the use of triclosan and triclocarban along with 18 other antimicrobial chemicals in consumer antiseptic wash products that are rinsed off after use, including hand washes and body washes, starting in September 2017.20 The State of Minnesota passed a regulation to prohibit the use of triclosan in sanitizing or hand and body cleansing products starting in January 1, 2017.21 If regulatory measures to prohibit the use of triclosan in consumer products are not taken in Canada, it may become a dumping ground for products containing triclosan and other antimicrobial chemicals that are subject to these regulations. Continue reading


A Proposal for Addressing Algal Blooms and Funding Great Lakes Protection

The 2015 western Lake Erie algal bloom was the ‘most severe recorded this century’ according to a National Ocean and Atmospheric Administration (NOAA) report. Reducing harmful algal blooms on Lake Erie will require a combination of improved data and monitoring, the implementation of innovative practices on the ground, and stronger community engagement– all requiring additional financial resources.  Continue reading


EBR 012-9574 – A Regulation Establishing a New Bottled Water Charge

CELA stresses that, regardless of whatever water charge is required to recover actual management costs, the amount of water that is available based on long term sustainability and other goals such as meeting population growth targets, ensuring climate change resiliency, and realizing benefits to future generations is finite. As such, simply recovering the province’s water management costs must not be used as the determinant as to whether a water permit ought to be issued or a specific water use ought to be prioritized. Second, while not directly related to the new proposed charge, we believe our general comments and recommendations discussed above are important considerations to ensuring the aims of the water charges program are met.

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Hillsburgh Dam and Bridge Class EA – Part II Order Request

It is imperative that the Town of Erin examines every means possible to make its community more resilient to climate change, and most importantly, to protect its finite freshwater resources and its fishery.  In fact, consideration of climate change was not even mentioned within the EA documentation, and ORA sees this as a major flaw, when it should have been included as a key consideration in the Scoring Matrix.

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EBR 012-8783, Regulation Establishing a Moratorium on Issuance of Permits to Take Water – Bottled Water

 Thank you for taking the first step toward protecting Ontario’s groundwater, and for putting the needs of communities before the profits of water bottlers. We support the proposed two year moratorium on the issuance of new or increasing permits to take water for water bottling, and are encouraged by the proposal’s stated purpose:

This would allow time for the Ministry [of Environment and Climate Change] to undertake a comprehensive look at our current understanding of Ontario’s groundwater resources and the rules that govern water bottling facilities that take groundwater. 

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