ERO-019-6951, 6963, 6928 & 6853 – Proposed Streamlining to Permit-by-Rule, Waste Management, Stormwater Management and Site Dewatering Activities – ORA Support

By Linda Heron on Monday, October 30th, 2023

Posted in Environmental Bill of Rights, Environmental Compliance Approval, Joint, Land Use, Mining, Ontario Water Resources Act, Policy & Process, Provincial Policy Statement, Quarries, Regulatory, River Concerns, Rivers at Risk, Sewage, Species at Risk, Stormwater, Urban Development, Waste Water Treatment Facilities, Water Quality, Watershed Planning

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.

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Accordingly, we collectively recommend that these current proposals should be withdrawn and re-considered by the Ontario government.

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Embro Dam Class Environmental Assessment – Alternatives

By Linda Heron on Thursday, February 9th, 2023

Posted in Brook Trout, Climate Change, Dam Removals, Dams, Fisheries, GHG Emissions, Impacts, ORA Submissions, Removal, River Concerns, Spring Creek, Urban Development

There are very few thriving Brook Trout populations left in southern Ontario, and it is especially surprising to find them present as far south as London, Ontario. Brook Trout are a sentinel species – the canary in the coal mine. In southern Ontario, Brook Trout populations have seen an 80% decline in their numbers over the last 50 years. Their populations have been under increasing pressure from a warming climate as well as agricultural, urban, rural and industrial development.

Removing the Dam and headpond to create a free-flowing and healthy coldwater Brook Trout fishery would be the perfect place for a family to go for walk, play or picnic in the Embro Conservation Area. It would provide a healthy riverine ecosystem and a beautiful natural environment for the entire community to enjoy!!

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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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ERO-019-6216 Proposed Amendments to Greenbelt Plan & ERO-019-6217 – Proposed Amendments to the Greenbelt Area boundary regulation – Joint

By Linda Heron on Thursday, December 1st, 2022

Posted in Bill 23, Environmental Bill of Rights, Environmental Registry, Greenbelt, Joint, Municipal, Urban Development

West Credit River. Photo by Steve Noakes.

We, the 78 undersigned organizations, are strongly opposed to the Ontario Government’s proposal to remove 7,400 acres of land from the Greenbelt. Opening these lands to development would destroy vital wildlife corridors, negatively impact woodlands, wetlands and watercourses, and result in the loss of over 5,000 acres of farmland. The government’s rationale – that these lands are needed for housing – is unfounded and untrue. We urge you not to proceed with this proposal for the reasons outlined below…

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ERO-019-6160 – Proposed Updates to the Ontario Wetland Evaluation System – Joint

By Linda Heron on Thursday, November 24th, 2022

Posted in Bill 23, Environmental Registry, Flooding, Joint, Planning Act, Provincial Policy Statement, Regulatory, River Concerns, Species at Risk, Urban Development, Water Quality, Wetlands

“Blandings Turtle” by tcmurray74 is licensed under CC BY-NC 2.0

As you know, the OWES is a science-based ranking system that provides a standardized approach to determining the relative value of wetlands. OWES assessments are necessary to designate Provincially Significant Wetlands (PSWs). This designation in turn results in a high level of protection under provincial law and policy such as the Provincial Policy Statement (sections 2.1.4, 2.1.5 and 2.1.8). Yet the complete overhaul of the OWES, as proposed, will ensure that very few wetlands would be deemed provincially significant in the future and that many if not most existing PSWs could lose that designation. As a result, very few of Ontario’s wetlands would benefit in the future from the protection that PSW designation currently provides. We urge you not to proceed with the proposed changes to the OWES, for the reasons outlined below.

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ERO-019-6141 – Legislative & Regulatory proposals affecting Conservation Authorities

By Linda Heron on Thursday, November 24th, 2022

Posted in Bill 23, Conservation Authorities Act, Endangered Species Act, Environmental Registry, Industry, Municipal, MZOs, Ontario Water Resources Act, ORA Submissions, Planning Act, Provincial Policy Statement, Regulatory Submissions, River Concerns, Rivers at Risk, Species at Risk, Urban Development, Water Quality, Watershed Planning

“Consider This” by Storm Crypt is licensed under CC BY-NC-ND 2.0.

The Ontario government’s own 2020 report, “Protecting People and Property: Ontario’s Flooding Strategy,” which resulted from the 2019 flooding disaster, states very clearly that “Flood risk management is achieved through multiple provincial acts, regulations, policies and technical guides and a wide range of provincial programs and services. Successful implementation relies on partnerships between provincial ministries, municipalities, Indigenous communities, conservation authorities, stakeholder organizations and the federal government.” 1

Instead, this proposal seeks to do the very opposite. It proposes to exempt the CAs from their authority under ten crucial Acts and their associated regulations; it blocks the CA partnership with municipalities and stakeholders and takes the authority of CAs away from permitting so they cannot properly fulfill the recommendations of this report that was commissioned by the Ontario government only a few short years ago. Now, where is the wisdom in that?

[1] Protecting People and Property: Ontario’s Flooding Strategy, 10 March 2020. P-7/42

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Erin WWTP – Environmental Compliance Approval – Joint

By Linda Heron on Wednesday, August 24th, 2022

Posted in Environmental Compliance Approval, Erin WWTP, Joint, ORA Submissions, Regulatory, Rivers at Risk, Urban Development, Waste Water Treatment Facilities, West Credit River

Photo by Steven Noakes – West Credit River Brook Trout

The Coalition for the West Credit River (Coalition) remains very concerned with the potential environmental impact of the Erin Water Resource Recovery Facility (WRRF) and, in particular, the temperature of its treated effluent harming the sensitive coldwater Brook Trout habitat of the West Credit River.

As your Ministry is aware, the approved sewage treatment plant proposes to discharge large flows of sewage effluent into the relatively small flow of the West Credit River. The lack of significant dilution will greatly magnify the thermal impact of warm effluent on this coldwater stream.

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Environmental Compliance Approval Number 7877-CALRZU – Erin Water Resource Recovery Facility – Joint

By Linda Heron on Friday, June 3rd, 2022

Posted in Aquatic Life, Brook Trout, Erin WWTP, Fisheries, Joint, Regulatory, River Concerns, Rivers at Risk, Sewage, Urban Development, Waste Water Treatment Facilities, Water Quality, West Credit River

Photo by Steven Noakes

First, the Coalition for the West Credit River (Coalition) would like to express our deepest appreciation that you and your staff worked with our Technical Team over the last several months to incorporate some of our recommendations into the Environmental Compliance Approval (ECA). However, we are concerned that our key recommendations for improvements to the draft ECA, received by you on 2 May, were not reflected in the ECA approved on 3 May 2022.

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