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Category Archives: ORA Submissions

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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Draft State of Per-and Polyfluoroalkyl (PFAS) and Risk Management Scope for Per- and polyfluoroalkyl substances by ECCC and HC – Supporting

The State of the PFAS report and the Risk Management Scope document were released for public comments during a time when Bill S-5 (Strengthening Environmental Protection for a Healthier Canada Act) received Royal Assent on June 13, 2023. The updated CEPA includes substantial changes to the listing of toxic substances under Schedule 1 of CEPA. The findings of the State of PFAS concluding PFAS as a class meet more than one criterion under section 64 are expected to be relevant due to the changes in CEPA. A listing of PFAS as a class under CEPA should be made in Part 1 of Schedule 1 of CEPA. Based on the body of evidence collected in the State of the PFAS report demonstrating the ecological toxicity and associated impacts of PFAS as a class to health, it is critical that PFAS as a class be given the full scope of regulatory measures, particularly with a focus on prohibition, that is permitted under CEPA.

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ERO-019-6647 – IESO Pathways to Decarbonization Study

Greenhouse Gas Emissions from Reservoirs

The ORA will never be in favour of streamlining the regulatory, approvals and permitting processes as they were put in place to protect our natural environment and communities, and have already been significantly undermined.

Instead, we need strong and rigorous environmental assessment and robust public, Indigenous and stakeholder consultation if we are to build climate resilience into our air, land and freshwater resources.

I will briefly address my rationale and the dangers of streamlining the regulatory regime of hydroelectric facilities in particular, as it is commonly claimed by governments and industry to be ‘clean’, ‘green’ and ‘non-emitting. However, this is misleading the public at a pivotal time when we should be following the science.

Related Information:

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ERO-019-4219 Project List Amendments; ERO-019-6693 Municipal Class EA; ERO-019-6705 Improving Timelines for Comprehensive EAs

Scanning Wabagishik for mussels.

For the reasons set out below, CELA and other aligned organizations and First Nations conclude that the various environmental assessment (EA) proposals set out in these Registry notices are highly problematic, unsupported by persuasive evidence, and contrary to the public interest purpose of the Environmental Assessment Act (EAA), namely the betterment of Ontarians by providing for the protection, conservation, and wise management of the environment. 

Accordingly, we collectively recommend that these current proposals should be withdrawn and re-considered by the Ontario government. 

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Bill 71, ERO-019-6715 – Proposed Building More Mines Act, 2023

Re:  Bill 71
        ERO-019-6715 – Proposed Building More Mines Act, 2023
        ERO-019-6749 – Consequential administrative amendments under the Mining Act
        ERO-019-6750 – Proposed regulatory amendments to closure plan and rehabilitation

A very disturbing reality has been revealed, that this government is clearly moving away from evidence-based decision-making that is grounded in science and, instead, is moving fully into a total lack of regard for environmental and stakeholder protections, and Indigenous treaty rights. This government is going too far in its efforts to cut red tape and deregulate environmental protections in Ontario.

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Hydroelectric is not a Pathway to Decarbonization or Net Zero

Dear Ministers Guilbeault, Wilkinson and Champagne,

ORA understands the urgency in fulfilling the vitally important commitment the government has made to cut GHG emissions to 40-45% below 2005 levels by 2030; however, we will present evidence from independent third-party peer-reviewed studies indicating that an effective path to decarbonization is not through hydropower.

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ORA’s first Youth Engagement event!

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ORA collaborated with Engineers Without Borders (UW Chapter) to host a youth engagement workshop for 35 grade 11 students in St. Aloysius Gonzaga Secondary School on March 31st. The group included students from the STEM Club and from the Environment Specialist High Skills Major (SHSM) Red Seal Program. ORA offered the students a Sector-Partnered Experience (SPE) focusing on real-world environmental issues to be solved. Continue reading


Is hydroelectric a pathway to decarbonization?

Watch our video to understand how hydroelectricity is greenwashed by Ontario Power Generation as “clean” and “non-emitting” when there are hundreds of independent third-party studies to the contrary. Read our full submission here!

Please sign and share our petition to protect Ontario Rivers and send OPG a strong message! 


2023 Annual Acquisition Report – ORA Feedback

Big Falls, Trout Lake River

There are currently three pumped storage projects going through the planning and approvals process, that would add approximately 2,000 MW of electricity to the grid. Developing that same Installed Capacity from small hydroelectric projects would involve 200 – 10 MW proposals that would cause untold environmental damage to dozens of Ontario rivers.  It is imperative the province does not rush or over-reach its targets and develop new electricity projects unnecessarily.

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OPG: Proposed Coniston Generating Station Life Extension Project Environmental Report

Wherever water levels have been lifted from their former undeveloped elevation must be considered the full extent of the reservoir/s. This crucial detail is not set out in the ER; however, the full extent of the cascading facilities must be considered when detecting, measuring and reporting total GHG emissions (CH2, CH4 and N2O). This cascading system creates one very large artificial and ongoing multi-level series of reservoirs that are highly regulated through the WRWMP, and likely very high in GHG emissions.

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