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Binational Strategies for PCBs and HBCD – Letter of Support

 On behalf of the 47 undersigned organizations, we are providing these comments on the two draft binational strategies under Annex 3 – Binational Strategy for PCB Risk Management (February 2017, hereafter “PCB Strategy”), and Binational Strategy for HBCD Risk Management (March 2017, hereafter “HBCD Strategy”). We are offering several general observations and recommendations to the Parties for both chemical of mutual concern (CMC) strategies together. Then for each strategy document, we offer specific observations and/or recommendations for individual sections.

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EBR 012-9080 – Low Impact Development Stormwater Management Guidance Manual

 The undersigned applaud the Ontario Ministry of Environment and Climate Change (MOECC) for its initiative in developing runoff volume control targets to reduce urban stormwater runoff and associated water pollution. We look forward to working with the Ministry on both the development and implementation of a Low Impact Development Stormwater Management Guidance Manual (which the above-noted Registry notice indicates will be drafted and consulted upon at a later date) and the further evolution of rainwater management policy and practice (both urban and rural) in Ontario. Our comments are directed only at the consultant reports attached to the Registry notice.

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EBR 012-9791 – Strategic Policy for Bait Management

 ORA feels this proposed Bait Policy falls short of the Ministry of Natural Resources and Forestry’s (MNRF) goal of finding options that minimize the ecological risks associated with the use, movement and harvest of baitfish, while also reducing the complexity of current management regimes and increasing business certainty to the bait industry.

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Conservation Authorities Act, 2017 (EBR Registry Number: 013-0561) – Joint Submission

 First, we understand that the Ministry of Natural Resources and Forestry (MNRF) is working on a summary document to help the public understand the proposed amendments to the Conservation Authorities Act (CAA) contained in Bill 139. As of the date of this letter, this additional explanatory information is not publicly available and the current deadline for comments is June 30, 2017. The public will better informed about the implications of the proposed amendments with the explanatory document in hand. And, as the Environmental Bill of Rights, 1993 (EBR) provides for “means by which residents of Ontario may participate in the making of environmentally significant decisions by the Government of Ontario” (s2(3)(a)), effective public participation is facilitated by ensuring there is adequate time to consider the potential impacts of the proposed amendments.

Second, as Bill 139 contains more than simply amendments to the CAA, consideration of the impacts has the potential to be complex and warrants more than 30-days for the public to be able to effectively provide feedback. Continue reading


Canada-Ontario Action Plan for Lake Erie (EBR Registry #012-9971) – Joint Submission

The undersigned members of the Alliance are commenting on the proposed Partnering in Phosphorus Control: Achieving Phosphorus Reductions in Lake Erie from Canadian Sources (“Draft Action Plan”) to reduce phosphorus loading in Lake Erie, in order to achieve the 40 per cent phosphorus reduction target. The Draft Action Plan, once finalized, will deliver on a number of nutrient commitments made by the federal and/or provincial governments including:

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National Energy Board Modernization – Expert Panel Review

Result of an Enbridge crude oil spill of over a million gallons into the Kalamazoo River.

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


A New Vision for Impact Assessment in Canada

Upon being sworn in, the Minister of Environment and Climate Change (the Minister) received a mandate letter from the Prime Minister to review the environmental assessment (EA) processes with objectives to restore public trust in EA; introduce new and fair processes; and get resources to market. In August of 2016, an Expert Panel (the Panel) was chosen to conduct this review, and ORA presented to the Panel on the 3rd of November 2016, in Sudbury, and submitted written comments, dated, 23 December 2016. Continue reading


EBR 013-0561 – Proposed amendments to the Conservation Authorities Act as part of Bill (139) – Joint Submission

 The undersigned have prepared the following comments in response to the proposed amendments to the Conservation Authorities Act (per Schedule 4, Bill 139). These are our preliminary submissions on this matter; we reserve the right to provide more fulsome and detailed comments as Bill 139 moves through the legislative process. We appreciate the opportunity to provide our input and look forward to working with the Ministry of Natural Resources and Forestry to ensure natural resource conservation, restoration, sustainable development and wise management in Ontario’s watersheds.

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Working with Media on Environmental Issues

Generating interest and support for environmental issues is challenging but necessary. Effective media  attention can garner public support and influence whether a corporation or government will address a problem. These notes and suggestions are meant to help others put together an action plan that strengthens your relationship with local print, radio and television media – an important step in raising awareness of issues of concern. Continue reading


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