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Category Archives: ORA Submissions


ERO 013-3738 – Bill 4, Cap & Trade Cancellation Act, 2018

It is important to first state that although the Cap and Trade program was not perfect, it brought significant revenue into the provincial coffers, and funded important innovation, efficiencies and low-carbon programs.  The few cents added to our gas fill-up was hardly noticeable. That being said, this is a great opportunity for the Province to come up with an effective Greenhouse Gas reduction strategy that will not just reduce carbon and result in cleaner air, but at the same time create well-paying jobs.

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Riverside Dam Class EA – Part II Order Request – ORA & Partners

The full Capital and Life Cycle Costs of Rebuilding Riverside Dam were not realistically represented in the ESR and could well end up costing the taxpayers more than double what was presented to the public and City Council.  A Rebuilt dam would be considered a new dam, not a repair or expansion of an existing weir, with an assessed High Hazard Potential, and is located within the City of Cambridge in a location that could place multiple residences and businesses at risk in the event of severe flooding or a dam breach.  ORA and Partners submit that this Project goes far beyond the screening process provided by a Schedule B, Class EA.  Consequently, we submit that this is a major project that should fall into a higher level of assessment.

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Approach to a key regulation under the proposed Fish and Fish Habitat Divisions of the Fisheries Act

ORA is very supportive of Fisheries and Oceans Canada’s efforts to strengthen the Fisheries Act Regulations and are pleased to provide our comments on the proposed amendments to the existing Applications for Authorization under Paragraph 35(2)(b) of the Fisheries Act Regulations.

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Screening Assessment Tool for Coal Tar Sealants – Joint

The presence and impacts of PAHs in the Great Lakes has been noted in the Canada-ˇOntario Agreement for over three decades. The Ontario provincial government and the Canadian federal government conducted a report, The Status of Tier 1 and Tier 2 chemicals in the Great Lakes basin under the Canada -ˇOntario Agreement, which noted that, “in some cases, the levels of PAHS in open surface water are still above the Canadian Council of Ministers of the Environment (CCME) Canadian Water Quality Guidelines. These exceedances are associated with known industrial sources.”

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Draft Great Lakes Binational Strategy for Mercury Risk Management – NGO – ORA Support

On behalf of the 58 undersigned groups, we are providing these comments on the draft Great Lakes Binational Strategy for Mercury Risk Management (April 2018, hereafter “Mercury Strategy”). Note that these comments expand on comments submitted by Canadian Environmental Law Association, National Wildlife Federation and Toxics Free Great Lakes Network on this matter on May 25, 2018. 

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Impact Assessment Act – Project List, Information Requirements, Timelines

ORA has fully participated in the Canadian Environmental Assessment Process review and was very hopeful with this government’s promise to “rebuild public trust, protect the environment, advance reconciliation with Indigenous peoples, and ensure good projects get built…” While there are some encouraging components, such as requiring the Minister and Cabinet to provide reasons for environmental approvals and creating a single agency to conduct assessments, it is extremely disappointing that the proposed Impact Assessment Act (IAA) further undermines credibility and trust as well as its ability to protect the environment. It is a very flawed process when after going through years of application review and examination of science-based evidence, that the Minister could make a purely political decision and prioritize economic considerations over meeting climate commitments – as it is doing now with the Trans Mountain Pipeline. 

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CELA et al. Comments on PBDE Draft Strategy – ORA Support

The proposed binational strategy on PBDEs outlines limited actions to address PBDEs levels in the Great Lakes beyond the measures that have already been committed on PBDEs by each country. It is also important that U.S. and Canada outline expected reduction targets for PBDEs in contrast to the current approach to outline intended measures. Without targets the ability to indicate successful and effective actions on PBDEs would be difficult to achieve.

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Riverside Dam Class EA – Update to Preliminary Preferred Alternative – Joint Submission

ORA understands the pressure municipalities are under when communities rally to maintain or rebuild their beloved mill ponds.  However, it is up to all authorities and municipalities to take a leadership role that places public safety and landscape scale ecological integrity above local individual or group interests.

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