ERO-019-7356 – Development of a Project Evaluation Policy under the Provincial Parks and Conservation Reserves Act

By Linda Heron on Sunday, August 20th, 2023

Posted in Environmental Assessment Act, Environmental Registry, ORA Submissions, Policy & Process, River Concerns

This government has been systematically removing public consultation opportunities for projects and issues of strong public interest, which goes against the spirit and intent of section 35 of the Environmental Bill of Rights (EBR).

Provincial parks and conservation areas must not be exempt from the Environmental Assessment Act as there will be no legal requirement to consider:

Potential environmental effects;

Mitigation measures;

Alternative ways of carrying out the undertaking, and

Alternatives to the undertaking.

There is also no decision-making mechanism which considers the environmental advantages/disadvantages of the undertaking.

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Draft State of Per-and Polyfluoroalkyl (PFAS) and Risk Management Scope for Per- and polyfluoroalkyl substances by ECCC and HC – Supporting

By Linda Heron on Wednesday, July 19th, 2023

Posted in Chemicals of Mutual Concern, Joint, ORA Submissions, PFAS

The State of the PFAS report and the Risk Management Scope document were released for public comments during a time when Bill S-5 (Strengthening Environmental Protection for a Healthier Canada Act) received Royal Assent on June 13, 2023. The updated CEPA includes substantial changes to the listing of toxic substances under Schedule 1 of CEPA. The findings of the State of PFAS concluding PFAS as a class meet more than one criterion under section 64 are expected to be relevant due to the changes in CEPA. A listing of PFAS as a class under CEPA should be made in Part 1 of Schedule 1 of CEPA. Based on the body of evidence collected in the State of the PFAS report demonstrating the ecological toxicity and associated impacts of PFAS as a class to health, it is critical that PFAS as a class be given the full scope of regulatory measures, particularly with a focus on prohibition, that is permitted under CEPA.

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ERO-019-6647 – IESO Pathways to Decarbonization Study

By Linda Heron on Sunday, May 14th, 2023

Posted in Algae, Campaign, Clean Energy Credits, Dams, Energy, Environmental Registry, Heavy Metal Contamination, Hydroelectric, Industry, ORA Submissions, Pumped Storage, Regulatory, River Concerns, Rivers at Risk, Species at Risk, Water Quality

Greenhouse Gas Emissions from Reservoirs

The ORA will never be in favour of streamlining the regulatory, approvals and permitting processes as they were put in place to protect our natural environment and communities, and have already been significantly undermined.

Instead, we need strong and rigorous environmental assessment and robust public, Indigenous and stakeholder consultation if we are to build climate resilience into our air, land and freshwater resources.

I will briefly address my rationale and the dangers of streamlining the regulatory regime of hydroelectric facilities in particular, as it is commonly claimed by governments and industry to be ‘clean’, ‘green’ and ‘non-emitting. However, this is misleading the public at a pivotal time when we should be following the science.

Related Information:

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ERO-019-4219 Project List Amendments; ERO-019-6693 Municipal Class EA; ERO-019-6705 Improving Timelines for Comprehensive EAs

By Linda Heron on Monday, May 8th, 2023

Posted in Energy, Environmental Assessment Act, Environmental Registry, Hydroelectric, Municipal, ORA Submissions, Regulatory, Renewable Energy on Crown Land, River Concerns, Species at Risk, Urban Development

Scanning Wabagishik for mussels.

For the reasons set out below, CELA and other aligned organizations and First Nations conclude that the various environmental assessment (EA) proposals set out in these Registry notices are highly problematic, unsupported by persuasive evidence, and contrary to the public interest purpose of the Environmental Assessment Act (EAA), namely the betterment of Ontarians by providing for the protection, conservation, and wise management of the environment.

Accordingly, we collectively recommend that these current proposals should be withdrawn and re-considered by the Ontario government.

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Bill 71, ERO-019-6715 – Proposed Building More Mines Act, 2023

By Linda Heron on Sunday, April 16th, 2023

Posted in Bill 71, Environmental Registry, Heavy Metal Contamination, Land Use, Mining, ORA Submissions, Pollution, Regulatory Submissions, River Concerns, Rivers at Risk, Water Quality

Re: Bill 71
ERO-019-6715 – Proposed Building More Mines Act, 2023
ERO-019-6749 – Consequential administrative amendments under the Mining Act
ERO-019-6750 – Proposed regulatory amendments to closure plan and rehabilitation

A very disturbing reality has been revealed, that this government is clearly moving away from evidence-based decision-making that is grounded in science and, instead, is moving fully into a total lack of regard for environmental and stakeholder protections, and Indigenous treaty rights. This government is going too far in its efforts to cut red tape and deregulate environmental protections in Ontario.

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Is hydroelectric a pathway to decarbonization?

By Linda Heron on Sunday, March 12th, 2023

Posted in Art, Dam Removals, Dams, Energy, Government, Hydroelectric, Industry, Media, ORA Submissions, Regulatory, Regulatory Submissions, River Concerns, Video

Watch our video to understand how hydroelectricity is greenwashed by Ontario Power Generation as “clean” and “non-emitting” when there are hundreds of independent third-party studies to the contrary. Read our full submission here!

Please sign and share our petition to protect Ontario Rivers and send OPG a strong message!

Hydroelectric and its “Pathway to Decarbonization”

By Linda Heron on Friday, February 10th, 2023

Posted in Clean Energy Credits, Dams, Energy, GHG Emissions, Government, Hydroelectric, Industry, ORA Submissions, River Concerns, Rivers at Risk, Species at Risk, Water Quality

Abitibi River – Twin Falls GS

Please sign and share our Petition: Hydroelectric is NOT a Pathway to Decarbonization.

The increasing role of hydroelectric reservoirs as GHG emitters and negative environmental effects has resulted in thousands of independent peer-reviewed studies laying out the facts. However, the hydropower industry and governments have done a thorough job of promoting waterpower through a powerful disinformation campaign to mislead the world into believing it is clean and non-emitting while turning a blind eye to the growing body of evidence to the contrary.

ORA strongly recommends that OPG begin the use of drone technology to detect, map and measure GHG emissions within the entire zone of influence of its hydroelectric facilities – in the upstream reservoir, turbine intake, spillway and downstream of the dam. This will ensure that those who have purchased clean energy credits from OPG are getting what is claimed – a clean and non-emitting source of electricity. All data should be placed in real-time on the OPG website and made available to researchers and the public.

In closing, the ORA requests that the Minister finally remove the label of clean and non-emitting from hydroelectric generation. Certification will mean nothing if there is no authentic and verifiable science-based method of reducing Ontario’s GHG emissions. Furthermore, it would be unethical and fraudulent to mislead the public and corporations into believing they are paying for clean and non-emitting electricity when they are actually paying to fuel climate change.

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Ministers Guilbeault and Duclos: Expand the single-use plastic ban – Joint

By Linda Heron on Thursday, January 26th, 2023

Posted in Government, Joint, Plastics, Pollution, River Concerns, Water Quality

We, the undersigned organizations and individuals, are deeply concerned about the plastic waste and pollution crisis and its devastating impacts worldwide. As responsible ministers for the Canadian Environmental Protection Act – “an Act respecting pollution prevention and the protection of the environment and human health”, we urge you to take bolder and urgent action to tackle the crisis by expanding the single-use plastics ban to include a more comprehensive list of problematic plastics and substances.

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ERO-019-6177 – Review of A Place to Grow and Provincial Policy Statement

By Linda Heron on Thursday, December 29th, 2022

Photo by Al Oman

The province claims that “Ontario needs more housing, and we need it now. That’s why the Ontario government is taking bold and transformative action to get 1.5 million homes built over the next 10 years.” This Environmental Registry of Ontario (ERO) posting is only one component of a large series of other interconnected ERO postings relating to Bill 23. Due to the short comment period at this busiest time of year for such a complex, vague, poorly considered, and destructive policy and legislative “streamlining”, it is impossible to fully understand the full scope or depth of resulting effects to provide any kind of meaningful input. It is crucial that all ERO postings are well planned, concisely written and defined in clear policy language so the public fully understands what is being proposed and its potential positive and negative effects.

The Ontario government, through Bill 23 and its multitude of complex and interconnected legislation and policy amendments, has:

Removed municipal jurisdiction from upper-tier municipalities to make policy decisions on land use planning matters that are based on local community interests.

Removed a significant financial source (permits/building fees) in which to help pay for water and wastewater services, sewers, transportation infrastructure, and community parks needed to service 1.5 million additional homes.

Prohibited Conservation Authorities all across Ontario from providing practical advice to municipalities, their ability to issue permits, or provide input into environmental concerns.

Failed to provide adequate public and Indigenous consultation relating to Bill 23 matters.

Is proposing to streamline the qualifications program for Building Practitioners (ERO-019-6433).

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ERO-019-6161 – Conserving Ontario’s Natural Heritage

By Linda Heron on Monday, December 26th, 2022

Posted in Bill 23, Environmental Registry, Fisheries, Land Use, ORA Submissions, Species at Risk, Urban Development

One prime example of ecosystem services is our fisheries which depend on strong and healthy ecosystems. In 2015 the Ontario Government launched a Provincial Fish Strategy – Fish for the Future, which indicated that Ontario’s recreational fisheries support robust sport fishing and tourism, which are a mainstay for many of the northern communities. It also reported that 1.5 million anglers spend $1.75 billion dollars in the province each year, supporting approximately 1,600 resource-based tourism businesses each and every year.[i] These are just a fraction of the ecosystem services that must be weighed against the full life cycle costs and benefits derived from any project that will impact our wetlands, wildlife, air, land or water.

^[i] Fisheries in Ontario – Information about recreational and commercial fisheries in Ontario. Online: https://www.ontario.ca/page/fisheries-ontario

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