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Category Archives: Joint

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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American Eel Engagement Workshop – Government Response Statement

As a potential next step for the Ottawa River, we recommend assessing a suitable location for a ladder at the Carillon Generating Station over the next 1-2 migration seasons coupled with a commitment to providing passage the following year. Studies conducted by Hydro QC and Milieu Inc. in 2001 and 2010 revealed that more elvers approach the southern turbines than northern ones; however, shorelines, the shipping canal, and the spillway were not assessed. It is reasonable to delay installing a permanent ladder until such assessments are completed; however, free passage should be provided by the 2019 migration season. Consideration should be given to translocating elvers captured during such assessments above the Carillon Generating Station. Continue reading


Environment and Health Groups’ Statement on Triclosan

The government’s proposed P2 Plans on triclosan are inadequate to address its continued use in consumer products and presence in the environment. Rather, the government’s proposal will ensure the on-going use of triclosan in consumer products. Unless there is a prohibition of triclosan in personal care products and other consumer products, the substance will continue to be released into the aquatic environment, including the Great Lakes and waterbodies across Canada, creating unnecessary risks to aquatic and terrestrial species. The US Food and Drug Administration (FDA) requested data demonstrating that consumer products containing antimicrobial ingredients are effective in their stated purpose – to prevent infections. The FDA did not receive such data and therefore passed its final decision to prohibit the use of triclosan and triclocarban along with 18 other antimicrobial chemicals in consumer antiseptic wash products that are rinsed off after use, including hand washes and body washes, starting in September 2017.20 The State of Minnesota passed a regulation to prohibit the use of triclosan in sanitizing or hand and body cleansing products starting in January 1, 2017.21 If regulatory measures to prohibit the use of triclosan in consumer products are not taken in Canada, it may become a dumping ground for products containing triclosan and other antimicrobial chemicals that are subject to these regulations. Continue reading


A Proposal for Addressing Algal Blooms and Funding Great Lakes Protection

The 2015 western Lake Erie algal bloom was the ‘most severe recorded this century’ according to a National Ocean and Atmospheric Administration (NOAA) report. Reducing harmful algal blooms on Lake Erie will require a combination of improved data and monitoring, the implementation of innovative practices on the ground, and stronger community engagement– all requiring additional financial resources.  Continue reading


EBR 012-9574 – A Regulation Establishing a New Bottled Water Charge

CELA stresses that, regardless of whatever water charge is required to recover actual management costs, the amount of water that is available based on long term sustainability and other goals such as meeting population growth targets, ensuring climate change resiliency, and realizing benefits to future generations is finite. As such, simply recovering the province’s water management costs must not be used as the determinant as to whether a water permit ought to be issued or a specific water use ought to be prioritized. Second, while not directly related to the new proposed charge, we believe our general comments and recommendations discussed above are important considerations to ensuring the aims of the water charges program are met.

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EBR 012-8783, Regulation Establishing a Moratorium on Issuance of Permits to Take Water – Bottled Water

 Thank you for taking the first step toward protecting Ontario’s groundwater, and for putting the needs of communities before the profits of water bottlers. We support the proposed two year moratorium on the issuance of new or increasing permits to take water for water bottling, and are encouraged by the proposal’s stated purpose:

This would allow time for the Ministry [of Environment and Climate Change] to undertake a comprehensive look at our current understanding of Ontario’s groundwater resources and the rules that govern water bottling facilities that take groundwater. 

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Response to Canada Gazette – Order Adding a Toxic Substance to the CEPA; & Management Strategy for Triclosan

 The Canadian Environmental Law Association (CELA), Chemical Sensitivities Manitoba, Ontario Rivers Alliance, Ottawa Riverkeeper, Prevent Cancer Now and Citizens Network on Waste Management are submitting the following comments in response to the Canada Gazette publications (Vol. 150, No. 48 — November 26, 2016) for the Publication of final decision after assessment of a substance — phenol, 5-chloro-2-(2,4-dichlorophenoxy) [triclosan], CAS RN (3380-34-5) and Canada Gazette (Vol. 150, No. 50 — December 10, 2016) for Order Adding a Toxic Substance to Schedule 1 to the Canadian Environmental Protection Act, 1999 (CEPA 1999). In addition, we are also offering comments on the proposed Management Strategy for triclosan.2

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Joint submission on the Federal Review of the Fisheries Act

 According to the binational Great Lakes Fisheries Commission, “The [Great Lakes] fishery is worth more than $7 billion annually to the people of the region, supports more than 75,000 jobs, sustains native fishers, and is the essence of the basin’s rich cultural heritage.”1  In Ontario alone, the commercial fishery contributes $350 million to Province’s GDP and Canadians spend $443 million per year on the recreational fishery in the Great Lakes.

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

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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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