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Category Archives: Regulatory Submissions

Renomination of Radionuclides as Chemicals of Mutual Concern Under the Great Lakes Water Quality Agreement

Five years ago, in March 2016, 110 groups submitted an application under the Great Lakes Water Quality Agreement (GLWQA) to designate radionuclides as Chemicals of Mutual Concern (CMCs) under Annex 3 of that Agreement. We submitted our nomination in reply to Environment and Climate Change Canada’s (ECCC) and the U.S. Environmental Protection Agency’s (EPA) call for nominations from the public. 

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Hydroelectric Program Development and Assessment – IESO Small Hydro Program

First, it was enlightening to be provided with a clear definition of small and large hydro facilities in the Hydroelectric Program Development and Assessment webinar, as well as a total amount of power generated by these categories. You informed that the definition of small hydro would have a scope of installed capacity of 10 MW and under, with 30 companies representing 50 facilities generating a total of 120 to 150 MW, and large hydro having a scope of installed capacity of over 10 MW, with 3 companies representing 22 facilities producing a total of 1,000 MW. 

The increased number of small hydro facilities making such a small contribution to our electricity grid impacts on multiple Ontario riverine ecosystems, whereas the 22 facilities producing 1,000 MW of power on presumably fewer rivers has a much lower trade-off value. Additionally, larger rivers have a greater capacity to buffer some of the worse effects of hydroelectric. 

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Bill C-28, An Act to amend the Canadian Environmental Protection Act, 1999 – Joint Support

“Banksy Toxic Waste” by Noodlefish is marked with CC BY-NC-SA 2.0.

The undersigned organizations and experts support the following Submission to the Ministers of Environment and Climate Change and Health on Bill C-28, An Act to Amend the Canadian Environmental Protection Act, 1999, etc. submitted by the Canadian Environmental Law Association in February 2022. This submission is relevant for Bill S-5 (An Act to amend the Canadian Environmental Protection Act, 1999, to make related amendments to the Food and Drugs Act and to repeal the Perfluorooctane Sulfonate Virtual Elimination Act) released on February 9, 2022. 

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A Clean Electricity Standard in support of a net-zero electricity sector – Discussion Paper

When people refer to hydroelectric as clean, it’s usually in the context of GHG emissions; however, governments and utilities often use the term categorically and without caveat or qualification. Using the word “clean” in this context is misleading. Just because hydroelectric facilities are not spewing out smoke does not mean they are clean or renewable.  In fact, waterpower has resulted in significant and ongoing impacts on water quality, water quantity, ecological processes, fish and wildlife populations and habitat, and to aboriginal communities. Hydroelectric also makes a significant daily contribution to the earth’s accumulation of greenhouse gases (GHG) in our atmosphere.

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Agnico Eagle Upper Beaver Gold Project – Tailored Impact Statement Guidelines & Public Participation Plan

The Agency has deemed the Project to be within federal jurisdiction and required it to undergo a federal Impact Assessment, and yet Agnico Eagle (AE) is planning to move forward with their advanced exploration as soon as weather permits. ORA objects to the Project moving forward with any advanced exploration activities that would result in any damage to the environment.

AE boasts about setting the “gold standard”, “for over 60 years Agnico Eagle has been attracting investment to Canada, from those who seek a mining company committed to make mining work better for communities, shareholders and the planet”.[1]  ORA submits that Stakeholders expect AE to set the “gold standard” on this Project by undertaking the most environmentally and socially rigorous, advanced and responsible project “for communities, shareholders and the planet”. [1] Agnico Eagle Twitter Posting, 22 November 2021
ORA comments requesting a federal review under the Impact Assessment Act, 2 October 2021.
Upper Beaver Gold Project – IAAC Portal.

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ERO-019-4978 – Subwatershed Planning Guide

The ORA is very supportive of policy and legislation that provides an ecosystem approach for planning at a watershed and subwatershed scale. It is essential that we ensure a healthy environment, with clean and abundant freshwater resources, that helps to provide resilience to the extremes of climate change.  We are appreciative of the information webinar on the Subwatershed Planning Guide, and the 45-day comment period.

Overall, we are generally supportive of the draft guidelines as they seem broad ranging and comprehensive.  We are especially pleased to see the partnership approach with Indigenous peoples included in the Guide and agree that this approach will lead to a much more comprehensive subwatershed plan.

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Response to MECP Decision on Application for Investigation

Photo by Steve Noakes.

We were very disappointed in Ms. Paul’s decision to deny our Application for Investigation; however, we were also not surprised. This provincial government has systematically dismantled much of Ontario’s environmental policy and legislation with an ambitious goal of “cutting red tape”, and “modernizing”. They have successfully carried out their mission through specious explanations that mislead the public and deflect concern over important Environmental Registry postings and massive omnibus Bills. This method has allowed them to proceed with sweeping cuts to numerous pieces of important legislation without much public fuss – all during their declared COVID Emergency. The decision on our Application for Investigation is simply another example of bypassing key legislation to facilitate a Project that has strong community opposition.

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Agnico Eagle Upper Beaver Gold project – ORA Comments

The ORA strongly urges the Impact Assessment Agency of Canada (IAAC) to determine that a federal Impact Assessment is required to ensure that the ecological, social, and cultural effects of this proposed Project are rigorously assessed and mitigated. A federal IA would ensure that the potential ongoing cumulative effects of this Project on the environment, Indigenous communities and the public are fully addressed to ensure a more environmentally and socially sustainable outcome. 

Upper Beaver Gold Project – IAAC Portal.

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EBR Application for Investigation of Town of Erin – Proposed Erin Wastewater Treatment Plant – Joint

West Credit River Brook Trout. Photo by Steve Noakes.

The Belfountain Community and Planning Organization and Linda Heron are filing an Application for Investigation of the Corporation of the Town of Erin, under Part V, of the Environmental Bill of Rights, 1993. We are very concerned that the Town is moving forward to the construction phase of the Project when it has not yet fulfilled key commitments it made in its Town of Erin Urban Centre Wastewater Servicing Class Environmental Study Report.  The Ministry will investigate whether the Town contravened or violated Section 38 of the Environmental Assessment Act. 

Please click on this Google Drive link to view or download the Application for Investigation and Appendix A.  Continue reading


Comments on the draft of Canada’s Great Lakes Strategy for PFOS, PFOA and LC-PFCAs Risk Management (April 26, 2021) – Joint

The draft Strategy should include stricter fish consumption advisory that will protect the health of people in the Great Lakes basin to reflect stringent levels of PFOS concentration in fish adopted by the Great Lakes Consortium for Fish Consumption Advisories Best Practice for PFOS Guidelines.

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