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Category Archives: ORA Submissions

Canada Water Agency – Discussion Paper

ORA supports objectives that involve clean, healthy, safe and sustainable freshwater management. Our lakes and rivers flow across many borders, including municipal, regional, provincial and country-wide borders. Therefore, it is necessary to consider a Canada Water Agency that uses an integrated watershed and basin approach in its core mission and mandate, acting as an oversight agency.

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Media Release: Wastewater Treatment Plant Spells Doom for West Credit Brook Trout – Request for a federal review under the Impact Assessment Act

The Coalition for the West Credit River is calling on Johnathan Wilkinson, (Minister of Environment and Climate Change Canada) for a federal review of the Environmental Study Report (ESR) for the Erin Wastewater Treatment Plant (Erin WWTP), under the Impact Assessment Act.

The Erin Wastewater Treatment Plant (Erin WWTP) will discharge over 7 million litres of effluent daily, releasing a toxic plume of chloride, ammonia and decreased oxygen into the West Credit River, directly upstream of native Brook Trout spawning nursery and habitat, and endangered Redside Dace.

Please sign the Cut the Crap, Keep the Credit petition.

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ERO-019-2826, Statement of Environmental Values for the Ministry of Environment, Conservation and Parks

If the SEV is not being taken seriously now, why would we believe it will be taken seriously when this new SEV is adopted? The MECP should respect and fulfill its SEV in all areas of its purpose, which is its promise to Ontario taxpayers. Rather than focusing so heavily on the economy the MECP must apply its SEV in the protection and conservation of the environment. 

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Add “Plastic Manufactured Items” to Schedule 1 of CEPA – Joint

Immediate action on plastics is necessary. The government’s Science Assessment on Plastic Pollution, referenced in the Regulatory Impact Assessment Statement, confirmed that plastic pollution is widespread in Canada, causing a range of adverse effects on wildlife and ecosystems. Furthermore, there is strong public support for federal action. Recent polling found that 95 per cent of Canadians are concerned about plastic pollution and 86 per cent support a federal ban on single-use plastics. Every day Canada fails to act, another 7,900 tonnes of plastic waste end up in our landfills and environment. 

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Bradford Bypass – Request for designation under s.9 of the Impact Assessment Act – Support

A highly controversial environmental assessment study under the Ontario Environmental Assessment Act was completed 23 years ago. It concluded that the project would cause adverse effects to fish habitat including severe stormwater and groundwater impacts. The environmental assessment did not evaluate the impacts on species at risk, migratory birds or climate change. This study has not been updated. 

The provincial regulatory process is grossly inadequate.

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ERO-019-2811 – Planning Act provisions regarding enhanced Ministerial authority as part of a Minister’s Zoning Order – Joint

 We, the 70 undersigned organizations, are deeply concerned about both the “sharp increase” in the use of Minister’s Zoning Orders (MZOs) over the past year and the enhanced powers granted to the Minister of Municipal Affairs and Housing through amendments to the Planning Act, without public consultation, through Schedule 17 of Bill 197. 

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Proposal to increase set fines for recreational and commercial fishery offences

The ORA favours conservation of Ontario’s natural resources, and most especially as it relates to fish and their habitat. ORA agrees that the Ministry should apply existing federal government guidance for fines and increase the use of contravention tickets for more types of offences. It makes sense to issue tickets rather than using the federal court process.

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ERO-019-2636 – More damaging amendments to undermine the Endangered Species Act – Joint

“Blandings Turtle” by tcmurray74 is licensed under CC BY-NC 2.0

Overall, the material presented makes clear that the Fund mechanism will make it easier for habitat destruction to occur at the hands of industry and developers. Indeed, according to the proposal the main purpose of the Fund is to give operators a quicker and less cumbersome alternative to completing actions to provide an overall benefit for the species negatively impacted by their activities. The Fund is a part of a package of damaging amendments to the Endangered Species Act, 2007 (ESA), passed in June 2019 that, taken together, represent a gross weakening of the ability of the Act to fulfill its purpose to recover Ontario’s at-risk species. Our primary concerns with the Fund are outlined below.

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Reject Schedules 6 and 8 of Bill 229 to Protect Conservation Authorities and Species at Risk

Bill 229 is just the most recent in a long list of omnibus bills containing devastating amendments, exemptions and streamlining of key environmental policy and legislation designed to protect our environment and communities and provide the public and stakeholders with meaningful input.  These government actions have created a deep erosion of public trust and confidence.  It is unacceptable that it would mislead its citizens and bypass the norms by taking advantage of a world-wide health emergency to aggressively push their destructive agenda through.

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Exempting dams from requiring a Permit to Take Water – ERO-019-2517

Melville Dam, Credit River, breached on 26 June 2017

ORA submits that the MECP’s priority must be the pursuit of its Statement of Environmental Values (SEV), and its vision and mandate of “an Ontario with clean and safe air, land and water that contributes to healthy communities, ecological protection, and environmentally sustainable development for present and future generations[i].  There is nothing in the MECP’s SEV that promises to “remove the regulatory burden” from industry or “provide some cost savings for dam owners and operators”.  It is not the MECP’s duty to save dam owners and operators money or ease their regulatory burden. Its duty is to fulfill its Mandate to protect the environment and to follow its promise of environmentally sustainable development for our present and future generations.  Certainly, MECP’s priority should not be to cut regulatory burden at the expense of our air, land and water.  It is a tragedy that today’s cost savings for dam owners and operators will be borne on the backs of our children and grandchildren.

[i] Statement of Environmental Values: Ministry of the Environment and Climate Change

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