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Category Archives: Regulatory

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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Bill 132 – Proposed Waterpower Exemption to a PTTW & Related Amendments to LRIA

These proposals are bad for communities and great for the waterpower industry. The proposed changes do not improve or strengthen the delivery of the government’s mandate to stakeholders and the public, instead it places the protection of the environment, safety and best interests of communities in the hands of the for-profit waterpower industry and individual waterpower facility owners.  The proposed changes may cut red tape but at the same time they compromise safeguards that protect public health and wellbeing, safety and the environment.

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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-019-0518 – Ontario’s Sustainable Bait Management Strategy – Draft 2019

In ORA’s view, MNRF has been streamlined and restricted to the point where it becomes very challenging to effectively monitor and enforce any Bait Management Policy. It is also imperative that penalties are a sufficient deterrent and that funding is in place for sufficient staffing to effectively monitor and enforce the policy.

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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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Consultation: Improving the province’s resilience to flooding

As a basic, the province must have a comprehensive approach to watershed management through flood mapping, mitigation and hazard planning and protection, including services such as wetland protection, climate change adaptation and resilience, biodiversity health and land use planning.  In other words, we must be beefing up our public safety and environmental protection efforts, rather than gutting and streamlining key policy and legislation, as well as funding for our regulators.

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