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Category Archives: ORA Submissions

Modernization of the National Energy Board – ORA Comments

ORA supports the Panel’s broad strokes Vision in general, and applauds it for the recommendations of an accessible, inclusive, open, transparent and user-friendly process. However, there are several areas where we feel the recommendations fall short of its goals…

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Request for Additional Intervenor Funding for the EE Pipeline Review

Earlier this year a new Hearing Panel (Panel) was assigned to review the Energy East and Eastern Mainline Applications. At that time both applications were voided, including all decisions made by the previous Panel. It is our understanding that the Panel must now determine whether the Applications are complete, and a new list of issues created – in effect, the process is starting over. Additionally, there is no longer a list of valid participants, although persons and groups that have already submitted Applications to Participate (ATP) and have been approved, are not required to refile. The Panel will also reconsider each ATP filed to date, including those groups that were previously denied standing.

The Ontario Rivers Alliance (ORA) is requesting that the National Energy Board (NEB) significantly increase the amount of funding available to participating intervenors in the Energy East Pipeline review. 

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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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Energy East Pipeline – Draft List of Issues and Draft Factors and Scope

If the federal government is serious about its commitment to hold the increase in the global average temperature to well below 2 degrees Celcius above pre-industrial levels and to pursue efforts to limit the temperature increase to 1.5oC, then it is imperative that the NEB provide meaningful consideration to the contribution that major fossil fuel energy projects, and their upstream and downstream GHG emissions would have on our environment.

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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


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.   Including updates: 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


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