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Category Archives: Regulatory Submissions

Impact Assessment Act – Project List, Information Requirements, Timelines

ORA has fully participated in the Canadian Environmental Assessment Process review and was very hopeful with this government’s promise to “rebuild public trust, protect the environment, advance reconciliation with Indigenous peoples, and ensure good projects get built…” While there are some encouraging components, such as requiring the Minister and Cabinet to provide reasons for environmental approvals and creating a single agency to conduct assessments, it is extremely disappointing that the proposed Impact Assessment Act (IAA) further undermines credibility and trust as well as its ability to protect the environment. It is a very flawed process when after going through years of application review and examination of science-based evidence, that the Minister could make a purely political decision and prioritize economic considerations over meeting climate commitments – as it is doing now with the Trans Mountain Pipeline. 

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CELA et al. Comments on PBDE Draft Strategy – ORA Support

The proposed binational strategy on PBDEs outlines limited actions to address PBDEs levels in the Great Lakes beyond the measures that have already been committed on PBDEs by each country. It is also important that U.S. and Canada outline expected reduction targets for PBDEs in contrast to the current approach to outline intended measures. Without targets the ability to indicate successful and effective actions on PBDEs would be difficult to achieve.

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Canadian Environmental Protection Act – Review

We at the ORA fully support strengthening the Canadian Environmental Protection Act (CEPA) through the list of 87 recommendations made by The Standing Committee on Environment and Sustainable Development in its Eighth Report, tabled on 15 June 2017.  The ORA supports the right to a healthy environment.  Healthy communities, a healthy economy and a healthy environment are essential to Canada’s sustainability.   A review of the Act presents the federal government with a golden opportunity to improve the health and well-being of all people in Canada.

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Updating the Part II Order request process under the Environmental Assessment Act – EBR: 013-2099

Many individuals and groups embarking on the Part II Order process are new to it, have no legal assistance or background, and are unfamiliar with the terminology and rules; therefore, if we are truly aiming to provide help to the public it is extremely important that clear, succinct and concise instructions be provided in this policy/guidance document.

Download (PDF, 328KB)


EBR: 013-1817 – Watershed Planning Guidance

This document does not go far enough to place CAs in a central role of watershed planning and management, or in working collaboratively with other municipalities and planning authorities. The CAs have a mandate to ensure the conservation, restoration and responsible management of Ontario’s water, as well as the land and natural habitats; however, municipalities have no such mandate and are more development oriented. It is essential that municipalities are not just using this Watershed Planning Guidance purely for municipal land use planning or a stormwater management tool, but that CAs play a central role, and it is used as an integrated watershed planning and management framework.

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Hydrocarbon Pipelines Added to Table of Drinking Water Threats – EBR-013-1839 and 1840

ORA would like to point out that the proposed list does not address an in-water pipeline scenario, it only addresses pipelines above, below and under a water body. Therefore, it is extremely important that the following be added:

Recommendation 1:

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EBR-013-1476 – Draft Government Response Statement for the Recovery of the American Eel

The American Eel Needs Your Help!  You have an opportunity to support the recovery of a species that has declined by 99% of its original population, has been completely extirpated from extensive areas of its native Ontario range, and is in steep decline where it still exists.  The Ministry of Natural Resources and Forestry has prepared a Draft Government Response Station for the Recovery of the American Eel in Ontario, and you have until January 11th to sign the Petition below.  More information can be found here.  To add your own comments just click on the letter and type.  Thank you for your help! Continue reading


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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Dam Decommissioning

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