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Photo by Linda HeronPhoto Credit

ERO-019-4978 – Subwatershed Planning Guide

The ORA is very supportive of policy and legislation that provides an ecosystem approach for planning at a watershed and subwatershed scale. It is essential that we ensure a healthy environment, with clean and abundant freshwater resources, that helps to provide resilience to the extremes of climate change.  We are appreciative of the information webinar on the Subwatershed Planning Guide, and the 45-day comment period.

Overall, we are generally supportive of the draft guidelines as they seem broad ranging and comprehensive.  We are especially pleased to see the partnership approach with Indigenous peoples included in the Guide and agree that this approach will lead to a much more comprehensive subwatershed plan.

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Coniston Generating Station Upgrade – Life Extension Project

Hydroelectric is not emission-free or clean. A Washington State University study on the effects of damming conducted in a central European impounded river revealed that the reservoir reaches are a major source of methane emissions and that areal emission rates far exceed previous estimates for temperate reservoirs or rivers. It showed that sediment accumulation correlates with methane production and subsequent ebullitive release rates. Results suggested that sedimentation-driven methane emissions from dammed river hot spot sites can potentially increase global freshwater emissions by up to 7%.[1]  Hydroelectric facilities need to acknowledge and account for the associated GHG emissions they produce.

[1] Maeck, A., DelSontro, T., McGinnis, D.F, Fischer, H., Flury, S., Schmidt, M., Fietzek, P. and Lorke, A., 2013.  Sediment Trapping by Dams Creates Methane Emission Hot Spots, Environmental Science and Technology, 8130-8137, Online: http://www.dx.doi.org/10.1021/es4003907

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ERO-019-4867 – EA Requirements for Advanced Recycling Facilities – Joint

“Advanced recycling” is an umbrella term, sometimes also called “chemical” or “molecular recycling” that encompasses an ever-growing list of technologies that are speculative when it comes to recycling plastic. The reality is that there is no known commercial example of an “advanced recycling” facility anywhere in the world that turns plastic waste back into plastic products or packaging.

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Ending Plastic Pollution – A Call to Action – Joint

Canada has committed to ending plastic waste by 2030.i Reaching this goal will require ambitious actions that address the full life cycle of plastic.

Canada is a major—and growing—producer of plastics and the world’s second highest user of plastic on a per person basis.ii Production, use and disposal of plastics is an increasing contributor to climate change and habitat degradation. It also imposes disproportionate harm on those living next to production and disposal facilities, often low-income and Black, Indigenous and People of Colour communities.

We, the undersigned, therefore call on the Government of Canada to commit immediately to implement the following actions on an urgent basis:

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WWF-Canada and Nature Conservancy Support Adding Turbines to Non-powered Dams

It is challenging to understand the logic of a November 2021 CBC article that reports, “The Nature Conservancy and the World Wildlife Fund are two environmental groups that oppose new hydro dams because they can block fish migration, harm water quality, damage surrounding ecosystems and release methane and CO2. But they say adding turbines to non-powered dams can be part of a shift toward low-impact hydro projects that can support expansion of solar and wind power.” Whether it’s a new dam or an older retrofitted dam, they will result in the same negative impacts and produce the same amount of methane for 70 to 100 years or more.

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DRAFT PROJECT LIST REGULATION UNDER THE ENVIRONMENTAL ASSESSMENT ACT (ERO 019-4219) – Joint

West Credit River. Photo by Steve Noakes.

 Accordingly, we request that the Ministry revise and re-post the draft regulation for further public review/comment to ensure that it fully implements the stated purpose of the EAA, namely, the betterment of the people of Ontario by providing for the protection, conservation, and wise management of the environment. 

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ERO 019-4219 – Moving to a project list approach under the EAA

West Credit River Brook Trout – Photo by Steve Nokams

When these unregulated projects come home to roost, and the environmental impacts begin to damage or destroy highly valued public interests, such as our lakes and rivers, endangered species, our drinking water, and the economy, the government will pay a very high price.  Unfortunately, the damage that will result from these irresponsible and negligent actions will not easily be undone, and in many cases will not be resolved in our lifetimes.

If the government wants to incorporate “one-project, one review”, then it must be a robust EA process with fulsome public and Indigenous consultation, or it may find the process much longer than it might have intended.

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Is it Renewable Energy if it Degrades the Environment?

Is it really renewable energy when it degrades the environment and impacts on communities in a negative way?

There are 241 hydroelectric dams in Ontario, and only 3 facilities have provided any form of fish passage.

The effects of dams and waterpower facilities on fisheries have been well documented over the past century, and include the loss or serious decline of many iconic fish species, which are resources of importance to Ontario’s economy, biodiversity, and natural and cultural heritage. 


Bradford Bypass – Designation Request for a federal Impact Assessment – 63 groups

We are 63 environmental, farm and community organizations, many of which supported the February 3, 2021 designation request for a federal impact assessment of the Bradford Bypass highway (400-404 extension link) under the Impact Assessment Act. We are writing to indicate our support for the November 9, 2021 designation request made by three local community groups: Forbid Roads Over Green Spaces, Stop the Bradford Bypass and Concerned Citizens of King Township. Like them, we believe the proposed highway will result in adverse social and environmental impacts within federal jurisdiction. 

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Response to MECP Decision on Application for Investigation

Photo by Steve Noakes.

We were very disappointed in Ms. Paul’s decision to deny our Application for Investigation; however, we were also not surprised. This provincial government has systematically dismantled much of Ontario’s environmental policy and legislation with an ambitious goal of “cutting red tape”, and “modernizing”. They have successfully carried out their mission through specious explanations that mislead the public and deflect concern over important Environmental Registry postings and massive omnibus Bills. This method has allowed them to proceed with sweeping cuts to numerous pieces of important legislation without much public fuss – all during their declared COVID Emergency. The decision on our Application for Investigation is simply another example of bypassing key legislation to facilitate a Project that has strong community opposition.

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