Canadian Environmental Law Association (CELA) has prepared the following analysis and recommendations in response to the four above-noted Environmental Registry of Ontario (ERO) notices, which propose dramatic changes to Ontario’s permit-by-rule framework. The undersigned environmental, conservation, and civil society organizations have endorsed CELA’s submission. Collectively, it is strongly recommended that the Ministry of Environment, Conservation and Parks not move ahead with the four proposals…
We are willing to meet and discuss CELA’s submission at your convenience.
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.
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.
When these unregulated projects come home to roost, and the environmental impacts begin to damage or destroy highly valued public interests, such as our lakes and rivers, endangered species, our drinking water, and the economy, the government will pay a very high price. Unfortunately, the damage that will result from these irresponsible and negligent actions will not easily be undone, and in many cases will not be resolved in our lifetimes.
If the government wants to incorporate “one-project, one review”, then it must be a robust EA process with fulsome public and Indigenous consultation, or it may find the process much longer than it might have intended.
The ORA offers strong support for polluters being held accountable; however, that isn’t what’s happening here. Rather than strengthening enforcement tools that hold polluters accountable, this government is systematically and persistently dismantling, weakening or bypassing all environmental policy and legislation that was designed to protect the environment and deter those industries, corporations or individuals who would pollute and/or destroy the environment.
These ERO postings consistently mislead the public, especially in the top several paragraphs and titles, which contain misleading introductions to the proposed policy the government is proposing. In fact, you can always count on these “modernization” policy changes to be a further attack on environmental policy and legislation. It is even more despicable that these attacks have largely been carried out during the government’s declared COVID Emergency, where no public consultation is required, and what consultation that does take place is meaningless when the main objective is to cut red tape and remove any roadblocks to development and pollution, in spite of the public’s strong recommendations to protect the environment.
The ORA favours conservation of Ontario’s natural resources, and most especially as it relates to fish and their habitat. ORA agrees that the Ministry should apply existing federal government guidance for fines and increase the use of contravention tickets for more types of offences. It makes sense to issue tickets rather than using the federal court process.
We, the 85 undersigned organizations, are writing to express our strong opposition to the proposed amendment to the Growth Plan for the Greater Golden Horseshoe (GGH) which would end the prohibition on aggregate extraction within the habitat of threatened and endangered species throughout the region’s Natural Heritage System.
The undersigned applaud the Ontario Ministry of Environment and Climate Change (MOECC) for its initiative in developing runoff volume control targets to reduce urban stormwater runoff and associated water pollution. We look forward to working with the Ministry on both the development and implementation of a Low Impact Development Stormwater Management Guidance Manual (which the above-noted Registry notice indicates will be drafted and consulted upon at a later date) and the further evolution of rainwater management policy and practice (both urban and rural) in Ontario. Our comments are directed only at the consultant reports attached to the Registry notice.
ORA feels this proposed Bait Policy falls short of the Ministry of Natural Resources and Forestry’s (MNRF) goal of finding options that minimize the ecological risks associated with the use, movement and harvest of baitfish, while also reducing the complexity of current management regimes and increasing business certainty to the bait industry.
Stream-side forests are crucial to the protection and enhancement of freshwater resources. They are extremely complex ecosystems that provide useful ecosystem services such as mitigating or controlling non-point-source pollution as well as providing optimum food and habitat for stream communities. As a component of an integrated management system including nutrient management and sediment and erosion control practices, stream-side forests have important effects on water quality. They remove excess nutrients, pollutants and sediments from surface runoff and shallow groundwater and they also shade streams to optimize light and temperature conditions and provide dissolved and particulate organic food for aquatic plants and animals.