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Category Archives: Regulatory Submissions

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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ERO-013-5033 – 10th Year Review of the Endangered Species Act: Proposed Changes

If enacted, the proposed changes will effectively gut the Act, result in the loss of biodiversity in the Province, eliminate most of the current protections for species at risk, and reduce the likelihood of their recovery. These draconian changes are clearly designed to restrict the number of species that are listed as at risk, to permit large-scale developers to harm species at risk and destroy their habitat, and to delay the implementation of any protection measures that remain under the Act.

The government’s claim that the proposed changes will improve outcomes for species at risk is grossly misleading.

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Bill 66 – ERO 013-4234 – Repeal of the Toxics Reduction Act & ERO 013-4235 – Planning & reporting changes under Regs.

Pollution – website banner of toxic water as running from sewers to the environment

ORA submits that Schedule 5 of Bill 66 is a regressive, unwarranted and potentially risky proposal that is inconsistent with the public interest and does not adequately safeguard the health and safety of Ontarians. Does the MECP really want to set the stage for another Grassy Narrows mercury disaster? Instead, the MECP should be focusing on improving the TRA and its regulations to better protect communities.

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Bill 66 – Restoring Ontario’s Competitiveness Act – 2018, Schedule 10

In closing, risky development decisions made in one or more jurisdictions could have significant negative cumulative impacts on our air, land and/or water, as well as the Great Lakes and many other highly valued ecosystems.  Being “Open-for-Business” is a good thing, unless it is at the expense of public health and safety or the environment.  Do we really want to risk another Walkerton or Grassy Narrows disaster? That is precisely what the province is fostering with Bill 66. 

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