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Category Archives: ORA Submissions

ERO-019-1749, Developing GRSs for nine Species at risk under the Endangered Species Act, 2007

This ERO proposal describes the GRSs as providing “stringent protections for species at risk and their habitats under the Endangered Species Act”, but how stringent are these protections when the legislation can be so easily set aside? This means that protection and recovery under the ESA is uncertain for all species at risk.

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Town of Erin Wastewater Treatment Plant – Concerns over Brook Trout and Fish Habitat on the West Credit River

Finally, the West Credit River is a headwaters tributary of the Credit River and is considered the crown jewel of coldwater brook trout fisheries in Ontario. This fishery significantly adds to the economic and social fabric of the province, with Ontario fisheries contributing a total of approximately $2.5 billion annually to the provincial economy.  MNRF’s own documents predict that climate change will reduce the number of watersheds in Ontario with brook trout by 50% by 2050.

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ERO-019-1620 – Proposed amendment to a regulation under Endangered Species Act, 2007 relating to Forest Operations in Crown Forests

The wording in this Environmental Registry posting is very misleading when it claims that “Ontario is committed to providing strong protections for species at risk and improving outcomes by modernizing and improving the effectiveness of the Endangered Species Act, as committed to in our Made-in-Ontario Environment Plan”. This proposal is not improving the effectiveness of the Endangered Species Act (ESA), it is even doubtful it will increase the profits of private corporations. It will however be to the detriment of species at risk.

Please note that the Ontario government decision is to continue with the forestry industry exemption of the Endangered Species Act when logging in Crown forests:  “A decision for this proposal has been published as a Bulletin under ERO 019-1995 on June 29, 2020.

Ontario has extended the temporary approach for forest operations conducted in Crown forests under the Endangered Species Act for an additional year. This will help avoid additional regulatory burden and economic strain on the forestry sector while a long-term approach is being considered.”

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Monitoring of Mercury Near Dams – LRIA, Ontario Regulation 102/20

ORA is very concerned about the extreme deregulation that occurred with the recent waterpower exemption to the Permit to Take Water, and in this new Mercury Regulation where new and significantly redeveloped electricity producing dams have not been addressed. These important legislative requirements were designed to ensure hydroelectric facilities are held accountable for environmental and socio-economic impacts and risks to communities and riverine ecosystems.

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Mattagami River – Little Long Dam Safety Project

The effects of dams and hydroelectric facilities on fish populations and fisheries have been well documented over the past century and include the loss or serious decline of many iconic fish species, which are resources of importance to Ontario’s economy, biodiversity, and natural and cultural heritage.

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112 Organizations offer Support for Conservation Authorities in Ontario

We, the 112 undersigned organizations, call on the Government of Ontario to retain the current mandate of the province’s 36 Conservation Authorities in protecting, restoring and managing the watersheds where 95 percent of Ontarians reside. Their functions and responsibilities with respect to land use planning and permitting, monitoring, stewardship and education must be maintained, for the reasons outlined below.

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ERO-019-1599 – Temporary exemption of Proposals from EBR during Emergency – CELA – ORA Support

In effect, this overbroad exemption means that for the duration of the regulation residents of Ontario, including Indigenous community members, will not have knowledge of, nor a means to participate in, provincial decisions which may have significant effects on the environment.

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Fright & Flight Zone, by Laurent Robichaud

Since 1963 the Little Long Generating Complex on the Lower Mattagami River in Northern Ontario has been the source of an environmental crisis of immeasurable proportions. Thousands of Lake Sturgeon have been entrained through spillway gates and left stranded waiting to be captured and relocated back to their adopted man-made habitat, leaving waters not fit for survival. Adam Creek Spillway is well known province-wide as a thorn in hydro electric energy and should not be defined or qualified as GREEN energy.

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ERO-019-0880 Ontario’s Forest Sector Strategy (Draft)

ORA also objects to Ontario ratepayers and/or taxpayers having to subsidize electricity pricing and capital expenditures for industry and private corporations.  This Strategy focuses only on the economic benefits of doubling the harvest, without looking at the trade-offs or balancing that with equal measures to maintain a healthy environment. This is the only way to maintain the claim of sustainable forest management in Ontario.

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ERO-019-1060 – Proposal to amend Ontario Regulation 454/96 (Construction) to provide alternative regulatory approval requirements for repairs to existing low hazard wetland dams

The Rudd Dam’s headpond had essentially turned into a large wetland created by over 100 years of sediment accumulating behind the dam, and the shallow pond’s water temperature was no longer viable brook trout habitat.  After the removal of the Rudd Dam the water temperature was reduced and brook trout habitat was made more resilient to a warming climate.  It was also an earthen dam that had already failed once, and the dam owner’s objective was to reduce his risk and liability.

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