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Category Archives: Regulatory 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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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


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



EBR 012-7583 – Conservation Authorities Act Review

Autumn at Big Falls – Trout Lake River

In addition to our submission regarding the Conservation Authorities Act Review Discussion Paper, dated 19 October 2015, ORA is very pleased to provide our recommendations on what has been identified as the five priorities for updating the Conservation Authorities Act…. Continue reading


Decision Notice: Alterations, Improvements & Repairs to Existing Dams, LRIA

Misner Dam, Port Dover

In November of 2015, Ontario Rivers Alliance (ORA) commented on EBR 012-5093,  regarding a Technical Bulletin for the Alterations, Improvements and Repairs of Existing Dams.  You can find our submission on our Blog here.  On March 24, 2016, ORA received a Decision Notice, as well as the approved Technical Bulletin. Continue reading




EBR 012-5444 – A Blueprint for Change – Aggregate Resources Act

ORA is writing in response to the province’s blueprint of proposed changes to modernize and strengthen the policy framework for managing Ontario’s aggregate resources.   ORA’s primary concerns are related to the potential impacts of aggregate extraction on private wells, aquifers, wetlands, lakes and rivers; however, we are also concerned with the loss of prime farmland, and in particular, Class 1 agricultural soil.

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Ontario Wetland Conservation Discussion Paper – EBR 012-4464

Sustainable management of natural resources such as forests, soils, water, wetlands and fisheries are at the heart of conservation, and these resources are the building blocks for green cities, energy production, agriculture, water supply and sanitation systems.  Relatively stable ecosystems and species dynamics are indicative of sustainable resource use, and conservation science has been broadening this knowledge to buffer ecosystems and species from negative climate change impacts.

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