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Category Archives: Regulatory Submissions

EBR 013-0644 Statement of Environmental Values

 However, the SEV must also set the tone for climate-resilient development within communities. This approach would require that decision-makers and practitioners integrate climate considerations directly into development activities across multiple sectors, keeping the focus on achieving development goals despite a changing climate. It would encourage a commitment to understand and plan for climate shocks like fires, droughts, hurricanes and floods. Ensuring flood planes are free of development and wetlands are left to do their important work.

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Open Statement on NAFTA, Environment and Climate

 Since the North America Free Trade Agreement (NAFTA) was signed more than two decades ago, our awareness of climate change has dramatically changed and our window of time for addressing it has shortened. NAFTA and other agreements that are part of the global trade regime have been used to undermine critical actions needed to respond to the climate crisis that help rebuild local economies, regulate corporations and stop damaging extractive projects.

We need a fundamental shift in how we approach trade – one that puts the needs of people and the planet first. 

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Review of Environmental and Regulatory Processes – ORA Comments

There is little in this Discussion Paper that would rebuild trust in the federal environmental assessment or project approvals process. This proposal would leave the National Energy Board (NEB) in charge of hearing reviews and project approvals, when it clearly has lost the confidence of the public, stakeholders and Indigenous peoples. The Canadian Environmental Assessment Act (CEAA) and the National Energy Board Act (NEBA) have failed to serve the public interest in sustainability and environmental protection, and should therefore be repealed and replaced.

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Binational Strategies for PCBs and HBCD – Letter of Support

 On behalf of the 47 undersigned organizations, we are providing these comments on the two draft binational strategies under Annex 3 – Binational Strategy for PCB Risk Management (February 2017, hereafter “PCB Strategy”), and Binational Strategy for HBCD Risk Management (March 2017, hereafter “HBCD Strategy”). We are offering several general observations and recommendations to the Parties for both chemical of mutual concern (CMC) strategies together. Then for each strategy document, we offer specific observations and/or recommendations for individual sections.

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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


Energy East Pipeline – Draft List of Issues & Scope – ORA Comments

 The Ontario Rivers Alliance (ORA) is a registered Intervenor in the review of the Energy East Project and Asset Transfer. ORA is writing in response to the National Energy Board’s (NEB) request for input on the Draft List of Issues (List) and Draft Factors and Scope (Scope) on the Application for the Energy East Project and Asset Transfer (Project).

ORA makes the following recommendations for your consideration:

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COMMENTS ON BUILDING A COMMON GROUND, A NEW VISION FOR IMPACT ASSESSMENT IN CANADA

 Upon being sworn in, the Minister of Environment and Climate Change (the Minister) received a mandate letter from the Prime Minister to review the environmental assessment (EA) processes with objectives to restore public trust in EA; introduce new and fair processes; and get resources to market. In August of 2016, an Expert Panel (the Panel) was chosen to conduct this review, and ORA presented to the Panel on the 3rd of November 2016, in Sudbury, and submitted written comments, dated, 23 December 2016.

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Additional Financial Support for the Energy East Pipeline Review Intervenor Funding – ORA Comments

 The Ontario Rivers Alliance (ORA) is requesting that the National Energy Board (NEB) significantly increase the amount of funding available to participating intervenors in the Energy East Pipeline review. 

Access to adequate levels of intervenor funding is essential to hire high quality independent expert and legal assistance to help inform our project review and allow for meaningful participation in the hearing process.

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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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