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Photo by Linda HeronPhoto Credit

A Clean Electricity Standard in support of a net-zero electricity sector – Discussion Paper

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.

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ERO-019-4967 – Municipal Wastewater and Stormwater Management in Ontario – Discussion Paper

The province should not be streamlining reporting requirements. Wastewater and stormwater management are vitally important to the health and resilience of our freshwater resources and to the people of Ontario. There are numerous complex and site specific considerations for each and every outfall of sewage effluent that is unique to the area and the water body. We cannot continue to release partially treated or untreated sewage into our lakes and rivers. We must stop thinking about how we can make it easier and start thinking about how we can make wastewater treatment more efficient and effective so we can build resilience into our lakes and rivers to help prepare for a warming climate. 

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ERO 019-4108 – Expanding Administrative Penalties for Environmental Contraventions

The ORA strongly supports the proposed penalty regulations under the Environmental Protection Act and the Ontario Water Resources Act that would revoke and replace existing penalty regulations under these acts.

That being said, this regulation would have been even more beneficial if this provincial government had not spent the last 4 years (more than 2 years of which have been under a COVID Emergency) totally gutting our hard-earned protective environmental legislation (all in the name of “cutting red tape”) and degrading (in some cases eliminating) the public’s ability to have input into a Project, to be consulted, and to appeal a Minister’s decision. Proponents have no worry of polluting or protecting the environment when there is no effective legislation left to comply with.

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Agnico Eagle Upper Beaver Gold Project – Tailored Impact Statement Guidelines & Public Participation Plan

The Agency has deemed the Project to be within federal jurisdiction and required it to undergo a federal Impact Assessment, and yet Agnico Eagle (AE) is planning to move forward with their advanced exploration as soon as weather permits. ORA objects to the Project moving forward with any advanced exploration activities that would result in any damage to the environment.

AE boasts about setting the “gold standard”, “for over 60 years Agnico Eagle has been attracting investment to Canada, from those who seek a mining company committed to make mining work better for communities, shareholders and the planet”.[1]  ORA submits that Stakeholders expect AE to set the “gold standard” on this Project by undertaking the most environmentally and socially rigorous, advanced and responsible project “for communities, shareholders and the planet”. [1] Agnico Eagle Twitter Posting, 22 November 2021
ORA comments requesting a federal review under the Impact Assessment Act, 2 October 2021.
Upper Beaver Gold Project – IAAC Portal.

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ERO-019-4978 – Subwatershed Planning Guide

The ORA is very supportive of policy and legislation that provides an ecosystem approach for planning at a watershed and subwatershed scale. It is essential that we ensure a healthy environment, with clean and abundant freshwater resources, that helps to provide resilience to the extremes of climate change.  We are appreciative of the information webinar on the Subwatershed Planning Guide, and the 45-day comment period.

Overall, we are generally supportive of the draft guidelines as they seem broad ranging and comprehensive.  We are especially pleased to see the partnership approach with Indigenous peoples included in the Guide and agree that this approach will lead to a much more comprehensive subwatershed plan.

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Coniston Generating Station Upgrade – Life Extension Project

Hydroelectric is not emission-free or clean. A Washington State University study on the effects of damming conducted in a central European impounded river revealed that the reservoir reaches are a major source of methane emissions and that areal emission rates far exceed previous estimates for temperate reservoirs or rivers. It showed that sediment accumulation correlates with methane production and subsequent ebullitive release rates. Results suggested that sedimentation-driven methane emissions from dammed river hot spot sites can potentially increase global freshwater emissions by up to 7%.[1]  Hydroelectric facilities need to acknowledge and account for the associated GHG emissions they produce.

[1] Maeck, A., DelSontro, T., McGinnis, D.F, Fischer, H., Flury, S., Schmidt, M., Fietzek, P. and Lorke, A., 2013.  Sediment Trapping by Dams Creates Methane Emission Hot Spots, Environmental Science and Technology, 8130-8137, Online: http://www.dx.doi.org/10.1021/es4003907

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ERO-019-4867 – EA Requirements for Advanced Recycling Facilities – Joint

“Advanced recycling” is an umbrella term, sometimes also called “chemical” or “molecular recycling” that encompasses an ever-growing list of technologies that are speculative when it comes to recycling plastic. The reality is that there is no known commercial example of an “advanced recycling” facility anywhere in the world that turns plastic waste back into plastic products or packaging.

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Ending Plastic Pollution – A Call to Action – Joint

Canada has committed to ending plastic waste by 2030.i Reaching this goal will require ambitious actions that address the full life cycle of plastic.

Canada is a major—and growing—producer of plastics and the world’s second highest user of plastic on a per person basis.ii Production, use and disposal of plastics is an increasing contributor to climate change and habitat degradation. It also imposes disproportionate harm on those living next to production and disposal facilities, often low-income and Black, Indigenous and People of Colour communities.

We, the undersigned, therefore call on the Government of Canada to commit immediately to implement the following actions on an urgent basis:

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WWF-Canada and Nature Conservancy Support Adding Turbines to Non-powered Dams

It is challenging to understand the logic of a November 2021 CBC article that reports, “The Nature Conservancy and the World Wildlife Fund are two environmental groups that oppose new hydro dams because they can block fish migration, harm water quality, damage surrounding ecosystems and release methane and CO2. But they say adding turbines to non-powered dams can be part of a shift toward low-impact hydro projects that can support expansion of solar and wind power.” Whether it’s a new dam or an older retrofitted dam, they will result in the same negative impacts and produce the same amount of methane for 70 to 100 years or more.

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DRAFT PROJECT LIST REGULATION UNDER THE ENVIRONMENTAL ASSESSMENT ACT (ERO 019-4219) – Joint

West Credit River. Photo by Steve Noakes.

 Accordingly, we request that the Ministry revise and re-post the draft regulation for further public review/comment to ensure that it fully implements the stated purpose of the EAA, namely, the betterment of the people of Ontario by providing for the protection, conservation, and wise management of the environment. 

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