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Category Archives: ORA Submissions


Feedback on the IESO Resource Adequacy and Long-Term 2 RFP Engagement

The ORA is offering feedback on the 13 December 2023 Independent Electricity System Operator (IESO) webinar. ORA strongly objects to new hydroelectric being included as a “non-emitting” resource, eligible for the Long Term 2 (LT2) Request For Proposals (RFP). Participants were informed of an overall need for 5 TWH of energy emerging at the end of the decade and growing through the 2030s. The LT2 RFP has an anticipated installed capacity target of around 2,000 MW of non-emitting energy resources to be procured and operational by 2030.  ORA questions the IESO’s rationale for applying the non-emitting label to hydroelectric when there are numerous independent third-party peer-reviewed studies, as well as the Intergovernmental Panel on Climate Change (IPCC) reporting guidelines. This immense volume of studies indicate that hydropower reservoirs generate significant and ongoing greenhouse gas (GHG) emissions, especially methane, for the full life cycle of the dam. It is misleading the public to claim that hydroelectric is “non-emitting” in the LT2 RFP or in any other public arenas and could be considered fraudulent.

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ERO-019-7739 – Proposal to return lands to the Greenbelt

Greenbelt

ORA strongly supports the following:

  1. The new section to the Act, 14.1, to restore the Greenbelt Plan to the 15 areas of land that were removed or redesignated in 2022, while maintaining the 2022 lands that were added.
  2. The re-enactment and enhancement of section 2 of the Oak Ridges Moraine Conservation Act, 2001, to repeal the authority of the Lieutenant Governor in Council to add/remove lands from the Greenbelt.
  3. Lastly, ORA supports the new section of the Act, 26, to restore the designation of land that was redesignated in 2022.

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Hydro Impacts 101: The Trade-offs

We’ve been sold the idea that hydropower is a clean, green, and non-emitting energy source.
But this is far from the truth!💔🌱

Check out this eye-opening infographic and the full report below to learn more about the hidden environmental and socio-economic costs of these projects! 🌊💰

  • Hydro impacts 101: the trade-offs

Hydro Impacts 101 – The Trade-offs


ERO-019-7378 – Black Ash regulation – Joint

Black Ash

On behalf of the 42 undersigned organizations, we are writing to express our strong opposition to the proposed conditional exemption for the endangered Black Ash, under Ontario’s Endangered Species Act, 2007 (ESA). The proposed minimizes protections for the Black Ash at every turn and reveals a disturbing lack of intent on the part of the Ministry of Environment, Conservation and Parks (MECP to prioritize the survival and recovery of the species.

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

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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Advancing Protected and Conservation Areas – Joint

On April 1, 2021 the Ontario government announced the appointment of a working group of conservation experts to “identify opportunities to protect and conserve more natural areas” in the province, a key commitment in the government’s Made-in-Ontario Environment Plan. The working group provided a report with recommendations to the Minister of Environment, Conservation and Parks entitled, “A New Approach: Advancing Protected and Conserved Areas in Ontario.” The report was only recently made available to the public through a Freedom of Information request.

On behalf of the 124 undersigned organizations, we urge you to implement key recommendations of the report, specifically: 1) to partner with Indigenous Nations and engage the public, municipalities and interested groups to immediately implement a strategy to protect 30 percent of our lands and waters by 2030 and 2) to establish an innovation fund to support implementation. We urge you to make funding and resources available commensurate with the globally significant opportunity that is available in Ontario right now.

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ERO-019-7561 & ERO-019-7562 – Proposal to Return Lands to the Greenbelt

In response to the proposal to return lands to the Greenbelt, the ORA offers our strong support for all lands that were removed from the Greenbelt on 14 December 2022 being immediately returned to the Greenbelt, as per the proposed Amendments to the Greenbelt Plan and the Greenbelt Area Boundary Regulation O.Reg 59/05.

ORA also recommends that all lands this government added to the Greenbelt land to compensate for the December 2022 removal of Greenbelt lands remain within the Greenbelt under the protection of the Greenbelt Act, 2005, and Greenbelt Plan.

Once the land is returned to the Greenbelt, it must remain designated as Greenbelt with all the relevant land use restrictions, and any future removal must be made extremely onerous through protective amendments to the appropriate legislation.

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ERO-019-7598 – Proposed Regulatory Amendments to the Build More Mines Act, 2023

“Open-pit Cppper Mine – Mission Complex” by docentjoyce is licensed under CC BY 2.0.

Actually, this government does not deserve the trust of its constituents because it has eroded all of our environmental protections and public engagement and consultation in related policy and legislation over the last 5 years. Therefore, when it claims that “the intention is not to fundamentally change the underlying rules but rather to clarify their source and application”, it is unbelievable – no longer credible – trust has been lost.  Especially since this proposal and the entire Build More Mines Act, 2023 was a total gutting of the Mining Act.

While streamlining mining legislation and policies can bring about certain benefits such as increased efficiency and reduced bureaucracy if done correctly; excessive streamlining without adequate safeguards can impact the environment, communities and even the long-term sustainability of the mining industry.  It will also lead to environmental degradation, community displacement and conflicts, social and economic imbalances, and undermine public trust with the lack of transparency and accountability.

To avoid these negative consequences, it is essential to strike a balance between streamlining mining regulations for efficiency and ensuring that there are robust environmental, social and legal safeguards in place. Proper consultation with local communities, adherence to international best practices and strict enforcement of responsible mining standards are crucial for achieving sustainable and responsible mining practices. This is not the case with any of these amendments.

Consequently, ORA rejects this proposal to streamline the Regulation.

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

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:

  1. Potential environmental effects;
  2. Mitigation measures;
  3. Alternative ways of carrying out the undertaking, and
  4. Alternatives to the undertaking.

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

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