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Category Archives: ORA Submissions

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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MECP Minister’s Decision on Part II Order Request – Riverside Dam

On September 28, 2018, you requested, on behalf of the Ontario Rivers Alliance and other partners, that the City be required to prepare an individual environmental assessment for the replacement of Riverside Dam.  I am taking this opportunity to inform you that I have decided that elevating the project to an individual environmental assessment is not required.

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ERO-013-5101 & 5102 – Discussion Paper – Modernizing the EA Program and EAA Act

The ORA is opposed to this proposal that would gut the Environmental Assessment Act (EAA) and the Environmental Assessment (EA) program.  Since the EAA was amended in 1996 there have been many official calls for an improved EAA and EA program, amongst those calls were the Environmental Commissioner for Ontario and the Auditor General of Ontario. Over this time, the EA program and EAA have become more and more streamlined, and this has led to increasing uncertainty for stakeholders and proponents.

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ERO-013-5018 & 4992 – Conservation Authorities Modernization Operations & Permitting – Bill 108, Schedule 2 – Joint

We strongly encourage the Ministries to hold fulsome and meaningful public consultations, aimed at ensuring that the proposed budgetary, legislative, and any future regulatory changes meet the desired vision of improving Ontario’s resilience to climate change. Until such time as a full assessment of the proposed changes is complete, we call on the government to delay enacting Bill 108, Schedule 2. 

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ERO-013-5033 – 10th Year Review of the Endangered Species Act: Proposed Changes

If enacted, the proposed changes will effectively gut the Act, result in the loss of biodiversity in the Province, eliminate most of the current protections for species at risk, and reduce the likelihood of their recovery. These draconian changes are clearly designed to restrict the number of species that are listed as at risk, to permit large-scale developers to harm species at risk and destroy their habitat, and to delay the implementation of any protection measures that remain under the Act.

The government’s claim that the proposed changes will improve outcomes for species at risk is grossly misleading.

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The Community Fisheries and Wildlife Involvement Program – Joint

In 1982, the Bill Davis government implemented the Community Fisheries Involvement Program (CFIP) and Community Wildlife Involvement Program (CWIP) to support community members and volunteers in efforts to initiate environmental projects that benefitted fisheries and wildlife in Ontario. In the first year alone, 3000 volunteer work days were donated to 22 projects across the province. Due to the success of the program, the Mike Harris government increased the funding to these programs to $1,000,000.00, which according to the Ontario Federation of Anglers and Hunters (OFAH) lead to 35,000 anglers, hunters, conservationists and outdoor enthusiasts donating 200,000 hours to 600 on the ground projects in the program’s final year.

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ERO-013-4143 – Review of the Endangered Species Act, 2007 – Joint Submission

We note, with deep concern, that environmental deregulation – making it easier for industry and development proponents to proceed with activities that harm species at risk and their habitats – appears to be the overall focus and intent of the options put forward for consideration. Reassuring statements that the review is intended to “improve protections,” “improve effectiveness” and provide “stringent protections” (p. 2) are misleading, in light of the actual proposed changes that MECP is inviting the public to consider. These include options that would undermine the very cornerstones of the law: science-based listing (including Indigenous Traditional Knowledge), mandatory habitat protection, and legislated timelines for planning and reporting. 

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Bala Falls Small Hydro Project – Permit to Take Water

Area just below the Falls

Since this project was first proposed, a large percentage of the community of Bala Falls have been opposed to it.  Citizens have lobbied, marched, picketed, petitioned and railed against this abomination being built in the heart of their town.  Immediately downstream of the dam is a favourite public swimming and picnic area that draws local residents and tourists from far and wide.  This project will pose a public safety risk; however, there is no Public Safety Plan – it wasn’t included in the initial Environmental Report, nor was it adequately addressed.  It was unacceptable in 2012, and it’s still unacceptable – it should never have been approved in the first place.

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