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Category Archives: Regulatory Submissions

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.

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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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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


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