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Category Archives: Regulatory

draft Great Lakes Binational Strategy for Mercury Risk Management – NGO comments

On behalf of the 58 undersigned groups, we are providing these comments on the draft Great Lakes Binational Strategy for Mercury Risk Management (April 2018, hereafter “Mercury Strategy”). Note that these comments expand on comments submitted by Canadian Environmental Law Association, National Wildlife Federation and Toxics Free Great Lakes Network on this matter on May 25, 2018. 

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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.

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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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Parkhill Hydro Generating Station, Grand River

In September of 2016, the Grand River Conservation Authority (GRCA) received a Feed-in-Tariff Power Procurement Contract from the IESO to sell power to the grid.  In June 2017, the GRCA initiated a Class Environmental Assessment to evaluate the construction of a waterpower project, the Parkhill Hydro Generating Station located at the existing Parkhill Dam in the City of Cambridge. If approved and constructed, this waterpower project would have a nameplate capacity of 500 kW. The project is subject to the provisions of the Ontario Waterpower Association “Class Environmental Assessment for Waterpower Projects.” Pursuant to the Class EA, this project is considered to be associated with existing infrastructure. Continue reading


Press Release: Conservationists Urge Federal Government to Protect American Eel

OTTAWA, Mar. 19, 2018 – Increased federal action to protect and recover American Eel is urgently needed, say the Canadian Wildlife Federation (CWF) and nine other partners in conservation including the Algonquin to Adirondacks Collaborative, the Lanark County Stewardship Council, Nature Québec, Ontario Nature, and the Ontario Rivers Alliance.

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