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Category Archives: ORA Submissions

ERO-019-6177 – Review of A Place to Grow and Provincial Policy Statement

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

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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Delayed Decision to List American Eel Under the Species at Risk Act (SARA) – Joint

OLYMPUS DIGITAL CAMERA

 We are a coalition of Indigenous Peoples and conservation and environmental non-governmental organizations concerned with the conservation of American Eel and write to ask that the Department of Fisheries and Oceans take all necessary steps to immediately list this important species under the Species at Risk Act (SARA). 

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

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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Environmental Accountability in Ontario – Consultation Paper

Big Falls – Victory – stopped a proposed hydroelectric project on a sacred site!

The current government has gutted multiple key pieces of environmental legislation and policy that have taken decades to assemble. We are in a perilous state now where the requirement to consult with the public and Indigenous communities has been minimized, and the red tape cutting has gone to such extremes that public health and safety and the natural environment will be at increased risk as the climate continues to warm. 

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

“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

“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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Bill 23 – ORA Comments to the Standing Committee on Heritage Infrastructure and Cultural Policy

The ORA is concerned that Bill 23 will have far-reaching negative effects on the environment and communities. This major streamlining of development is irresponsible and a recipe for disaster. Bill 23 works against sustainability and the watershed approach at a time when Government decision-making should be focused on protecting the environment and building climate resilience into Ontario’s communities and infrastructure.

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ERO 019-5816 – Development of a Clean Energy Credit Registry

The total amount of GHGs emissions from a hydroelectric facility is dependent upon many factors, including the impounded reservoir, terrain, amount of organic matter, air-water temperature, reservoir depth and size, vegetation (algae and plant/tree litter), pH values, oxygen levels, flow velocity, water level fluctuations, wind speeds, precipitation, wetlands within the impoundment zone, and facility operating strategy (cycling and peaking to maximize power generation).  Every hydroelectric facility is unique in its complexity and must be carefully studied and continually assessed and monitored to determine the total daily, seasonal and annual GHG emissions per MWh emanating from the system.

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