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Category Archives: Environmental Registry

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

EBR 012-8685 – Ontario’s Crown Forests: Opportunities to Enhance Carbon Storage

Stream-side forests are crucial to the protection and enhancement of freshwater resources. They are extremely complex ecosystems that provide useful ecosystem services such as mitigating or controlling non-point-source pollution as well as providing optimum food and habitat for stream communities. As a component of an integrated management system including nutrient management and sediment and erosion control practices, stream-side forests have important effects on water quality. They remove excess nutrients, pollutants and sediments from surface runoff and shallow groundwater and they also shade streams to optimize light and temperature conditions and provide dissolved and particulate organic food for aquatic plants and animals.[1]

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EBR 012-8234 – Safe Harbour Policy under the Endangered Species Act

ORA submits that every effort should be made to avoid the killing, harming or harassment of species at risk; and that Section 7 should not apply to a proponent that was issued an Overall Benefit Permit because their activities were likely to have an adverse effect on a species at risk or their habitat.  A proponent must ensure that healthy compensatory habitat for a species at risk is maintained throughout the life of the Project.

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EBR 012-8002 – Environmental Bill of Rights Review

The EBR must protect our substantive right to a healthy environment for all Ontarians, and must guarantee our right to breath clean air, drink safe water, enjoy a nontoxic environment, and to ensure healthy ecosystems for our present and future generations. The EBR should prevent the destruction of natural habitat, and ensure sustainability and biodiversity. The EBR must also ensure a citizen’s right to apply for leave to appeal a Director or Minister’s decision before an independent and impartial tribunal, the Environmental Review Tribunal. This must all be explicitly spelled out in Ontario’s EBR.  Continue reading

EBR 012-8760- Ontario’s Proposal on Reducing Phosphorus to Minimize Algal Blooms in Lake Erie


We see this proposal as necessary step toward fulfilling the commitment the Ontario Legislature made through the Great Lakes Protection Act, 2015 to set target(s) for reducing algal blooms within two years of the legislation’s passage. Further comments about the framing of the proposed target are included below.

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EBR-012-6266 – Government Response Statement for the Spotted Gar

Spotted Gar

Spotted Gar

The Spotted Gar is listed as threatened on the Species at Risk in Ontario (SARO) list, and is also listed as threatened under the federal Species at Risk Act (SARA). Fisheries and Oceans Canada has prepared the Recovery Strategy for the Spotted Gar in Canada in 2012 to meets its requirements under SARA. This recovery strategy was also adopted under the Endangered Species Act (ESA), with several additional survey locations included. Continue reading

Managing Effects of Open Cage Aquaculture – Joint Submission

We are deeply concerned about the proposed policy initiatives, and ask that no new or expanded cage aquaculture licences be authorized until appropriate consideration is given to the wisdom of expanding such operations in Ontario’s water bodies. If it is determined that such expansion is in keeping with Ontario’s legislative direction on protecting and restoring the ecological health of the Great Lakes – St. Lawrence River Basin, we ask that rigorous standards, monitoring and reporting protocols, and compliance regimes be developed and implemented before any renewed, new or expanded operations are authorized.

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EBR 012-5634 – OWA Proposed Major Amendment to the Class EA for Waterpower

Misema River

Misema River

ORA urges the MOECC to reject all aspects of the proposed major amendment to the Class EA for Waterpower (except the minor housekeeping changes), on the grounds that waterpower is far too complex and site-specific to assume that projects under 500 kW at existing infrastructure, or that increases in efficiency of an existing waterpower facility, would be less likely to involve new environmental effects or impact on communities.  This is absolutely wrong thinking for the protection, conservation and wise management of Ontario rivers.

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EBR-012-5666 – Cap and Trade Program Design Options

Greenhouse Gas Emissions from Reservoirs

Headponds or reservoirs are crucial to maximizing hydroelectric generation during peak demand hours, and must be factored in to pay the price for any cap or tax on resulting GHG emissions.  The frequent claim by governments and industry that waterpower produces clean energy is understood in most circles to mean that it does not emit Greenhouse Gases (GHGs).  The clean and green reputation of large dams has already been in question, but scientists are now reporting that millions of smaller dams on rivers around the world make an important contribution to total global GHG emissions.

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