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Category Archives: Regulatory Submissions

Exempting dams from requiring a Permit to Take Water – ERO-019-2517

Melville Dam, Credit River, breached on 26 June 2017

ORA submits that the MECP’s priority must be the pursuit of its Statement of Environmental Values (SEV), and its vision and mandate of “an Ontario with clean and safe air, land and water that contributes to healthy communities, ecological protection, and environmentally sustainable development for present and future generations[i].  There is nothing in the MECP’s SEV that promises to “remove the regulatory burden” from industry or “provide some cost savings for dam owners and operators”.  It is not the MECP’s duty to save dam owners and operators money or ease their regulatory burden. Its duty is to fulfill its Mandate to protect the environment and to follow its promise of environmentally sustainable development for our present and future generations.  Certainly, MECP’s priority should not be to cut regulatory burden at the expense of our air, land and water.  It is a tragedy that today’s cost savings for dam owners and operators will be borne on the backs of our children and grandchildren.

[i] Statement of Environmental Values: Ministry of the Environment and Climate Change

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Bill 197 & Proposed Major Amendments to the Class EA for Waterpower

Instead of exemptions or a more streamlined Class EAW, the OWA should be proposing amendments to provide for a much more rigorous and accountable process that ensures fish friendly turbines, effective and safe fish passage, a more rigorous cumulative effects assessment, and a more comprehensive and meaningful consultation process.  We should be making our rivers more resilient in the face of climate change – not exempting waterpower projects from the Class EAW.  Instead, the OWA and the Ontario government are placing our environment and communities at risk.

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ERO-019-1060 – Proposal to amend Ontario Regulation 454/96 (Construction) to provide alternative regulatory approval requirements for repairs to existing low hazard wetland dams

The Rudd Dam’s headpond had essentially turned into a large wetland created by over 100 years of sediment accumulating behind the dam, and the shallow pond’s water temperature was no longer viable brook trout habitat.  After the removal of the Rudd Dam the water temperature was reduced and brook trout habitat was made more resilient to a warming climate.  It was also an earthen dam that had already failed once, and the dam owner’s objective was to reduce his risk and liability.

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NGO Comments on Draft Binational Screening Criteria for Nominated Chemicals of Mutual Concern – ORA Support

The government recommendation asks whether the current concentrations of the chemical “exceed” the benchmarks or guidelines. This implies that we are okay until the benchmarks or guidelines are exceeded. This is not true. Health impacts don’t suddenly start to occur when you cross that narrow threshold of meeting the threshold and move into exceeding. We are already in trouble once we are near or have met the benchmarks or guidelines.

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ERO-019-0773 – “Proposal to transfer requirements from Ontario’s industrial effluent monitoring and limits regulations into Environmental Compliance Approvals and revoke the regulations” – ORA Endorsement

Removing the regulatory baseline for 113 of Ontario’s most heavily polluting facilities in nine environmentally damaging sectors is the wrong approach if the Government of Ontario’s goal is to hold polluters accountable, as it has stated on several occasions.  In order to achieve that goal, the MISA regulations should be updated and expanded to new facilities operating in Ontario across the nine industrial sectors.

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ORA Speaks to the Legislature, Re: Omnibus Bill 132

With the warming temperatures and extreme rain and drought events that climate change is predicted to bring with increasing frequency and intensity as time passes, decision makers and legislators bear a responsibility to strengthen freshwater protection and resiliency – not weaken it.  If this proposal moves forward it will be a precipitous turning point for our future with freshwater in Ontario and beyond.

You will find ORA’s submissions regarding Bill 132 here.

Check out ORA’s speech to the Standing Committee on General Government: Continue reading


Bill 132 and Proposed Waterpower Exemption to a Permit to Take Water

With climate change impacts bearing down on us, decision makers have a responsibility to ensure the resiliency of our freshwater resources.  If this proposal moves forward it will be a precipitous turning point for our future with freshwater in Ontario and beyond.

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ERO-019-0279 – Provincial Policy Statement Review – Joint

While abandoning the historically thoughtful context of a normal PPS review is ill-advised at any time, it is irresponsible to tilt the PPS toward an excessive empowerment of development-as-usual at a time of a changing climate, threats to biodiversity, regional ecological integrity, and the gathering momentum of the sixth mass extinction.

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Improving the province’s resilience to flooding – ORA Endorsed

In closing, we urge the Ministry of Natural Resources and Forestry to recognize the necessity of managing flood mitigation at a watershed scale and the importance of natural infrastructure. There is no need to reinvent the wheel when it comes to protecting our communities from flooding. This goal can be achieved by investing in our existing agencies (eg, conservation authorities) and by protecting and restoring our natural infrastructure (eg, wetlands and forests). 

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ERO-013-5101 & 5102 – Discussion Paper – Modernizing the EA Program and EAA Act

The ORA is opposed to this proposal that would gut the Environmental Assessment Act (EAA) and the Environmental Assessment (EA) program.  Since the EAA was amended in 1996 there have been many official calls for an improved EAA and EA program, amongst those calls were the Environmental Commissioner for Ontario and the Auditor General of Ontario. Over this time, the EA program and EAA have become more and more streamlined, and this has led to increasing uncertainty for stakeholders and proponents.

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