The ORA strongly objects to any approach that eliminates the opportunity for public and Indigenous consultation and input regarding any sewage and stormwater infrastructure projects, especially any expansions or upgrades when they could have a negative environmental impact on the riverine environment and communities.
This ERO proposal describes the GRSs as providing “stringent protections for species at risk and their habitats under the Endangered Species Act”, but how stringent are these protections when the legislation can be so easily set aside? This means that protection and recovery under the ESA is uncertain for all species at risk.
The wording in this Environmental Registry posting is very misleading when it claims that “Ontario is committed to providing strong protections for species at risk and improving outcomes by modernizing and improving the effectiveness of the Endangered Species Act, as committed to in our Made-in-Ontario Environment Plan”. This proposal is not improving the effectiveness of the Endangered Species Act (ESA), it is even doubtful it will increase the profits of private corporations. It will however be to the detriment of species at risk.
Please note that the Ontario government decision is to continue with the forestry industry exemption of the Endangered Species Act when logging in Crown forests: “A decision for this proposal has been published as a Bulletin under ERO 019-1995 on June 29, 2020.”
“Ontario has extended the temporary approach for forest operations conducted in Crown forests under the Endangered Species Act for an additional year. This will help avoid additional regulatory burden and economic strain on the forestry sector while a long-term approach is being considered.”
ORA is very concerned about the extreme deregulation that occurred with the recent waterpower exemption to the Permit to Take Water, and in this new Mercury Regulation where new and significantly redeveloped electricity producing dams have not been addressed. These important legislative requirements were designed to ensure hydroelectric facilities are held accountable for environmental and socio-economic impacts and risks to communities and riverine ecosystems.
In effect, this overbroad exemption means that for the duration of the regulation residents of Ontario, including Indigenous community members, will not have knowledge of, nor a means to participate in, provincial decisions which may have significant effects on the environment.
ORA also objects to Ontario ratepayers and/or taxpayers having to subsidize electricity pricing and capital expenditures for industry and private corporations. This Strategy focuses only on the economic benefits of doubling the harvest, without looking at the trade-offs or balancing that with equal measures to maintain a healthy environment. This is the only way to maintain the claim of sustainable forest management in Ontario.
The Rudd Dam’s headpond had essentially turned into a large wetland created by over 100 years of sediment accumulating behind the dam, and the shallow pond’s water temperature was no longer viable brook trout habitat. After the removal of the Rudd Dam the water temperature was reduced and brook trout habitat was made more resilient to a warming climate. It was also an earthen dam that had already failed once, and the dam owner’s objective was to reduce his risk and liability.
With the warming temperatures and extreme rain and drought events that climate change is predicted to bring with increasing frequency and intensity as time passes, decision makers and legislators bear a responsibility to strengthen freshwater protection and resiliency – not weaken it. If this proposal moves forward it will be a precipitous turning point for our future with freshwater in Ontario and beyond.
You will find ORA’s submissions regarding Bill 132 here.
Check out ORA’s speech to the Standing Committee on General Government: Continue reading
With climate change impacts bearing down on us, decision makers have a responsibility to ensure the resiliency of our freshwater resources. If this proposal moves forward it will be a precipitous turning point for our future with freshwater in Ontario and beyond.
In ORA’s view, MNRF has been streamlined and restricted to the point where it becomes very challenging to effectively monitor and enforce any Bait Management Policy. It is also imperative that penalties are a sufficient deterrent and that funding is in place for sufficient staffing to effectively monitor and enforce the policy.