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Category Archives: ORA Submissions


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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ERO-013-4208, A Made-in-Ontario Environment Plan

It is difficult to place any trust in the promises of this Plan when this government’s recent actions are reflecting something very different. Key policy and legislation were recently proposed in Bills 57 and 66 that would remove the position of the Environmental Commissioner of Ontario, bypass the Clean Water Actand several other important Acts, repeal the Toxic Reduction Act,and streamline the Endangered Species Act to support its “Open for Business” mandate.  How is the government doing its part to “help our urban and rural communities and landscapes become more sustainable and resilient” when at the same time key legislation is being repealed, streamlined or bypassed?  

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VICTORY!! Schedule 10 removed from Bill 66

We all had a HUGE VICTORY yesterday!!  “Thank you” for taking part in ORA’s campaign to Speak Out Against Schedule 10 of Bill 66.  The Ontario government reported that they will be removing Schedule 10 from Bill 66.   A BIG THANKS to you and many other people, organizations and municipalities that rallied together to speak out against this regressive Bill.

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Bill 66 – ERO 013-4234 – Repeal of the Toxics Reduction Act & ERO 013-4235 – Planning & reporting changes under Regs.

Pollution – website banner of toxic water as running from sewers to the environment

ORA submits that Schedule 5 of Bill 66 is a regressive, unwarranted and potentially risky proposal that is inconsistent with the public interest and does not adequately safeguard the health and safety of Ontarians. Does the MECP really want to set the stage for another Grassy Narrows mercury disaster? Instead, the MECP should be focusing on improving the TRA and its regulations to better protect communities.

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Bill 66 – Restoring Ontario’s Competitiveness Act – 2018, Schedule 10

In closing, risky development decisions made in one or more jurisdictions could have significant negative cumulative impacts on our air, land and/or water, as well as the Great Lakes and many other highly valued ecosystems.  Being “Open-for-Business” is a good thing, unless it is at the expense of public health and safety or the environment.  Do we really want to risk another Walkerton or Grassy Narrows disaster? That is precisely what the province is fostering with Bill 66. 

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Speak out against Bill 66 – Schedules 5 and 10

The Government of Ontario is proposing Bill 66, Restoring Ontario’s Competitiveness Act, 2018. It is unacceptable that key environmental protection and legislation that protects the public is under attack.

Schedule 5 of Bill 66 would repeal the Toxics Reduction Act and two regulations. The purpose of the TRA is to prevent pollution and protect human health and the environment by reducing the use and creation of toxic substances and informing Ontarians about toxic substances. 

Schedule 10 of this Bill would enable municipalities to simply pass an “open-for-business planning by-law” under the Planning Act, to exempt local development from the application of key components of several important provincial laws, plans and policies, including the:
• Clean Water Act, 2006, Section 39
• Great Lakes Protection Act, 2015, Section 20
• Greenbelt Act, 2005, Section 7
• Lake Simcoe Protection Act, 2008, Section 6, and 
• Oak Ridges Moraine Conservation Act, 2003, Section 7  

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Proposal to establish a hunting season for double-crested cormorants in Ontario – ERO 013-4124

Nesting Double-Crested Cormorants – a wild native species in Ontario

This disturbing proposal would allow the killing of 50 cormorants per day from March 15 until December 31 each year, which would potentially mean the killing of more than 14,000 birds per hunter, per killing season.  Additionally, both members of a nesting pair are required for nesting success; therefore, the killing of either the male or female during the nesting season would result in their chicks starving to death. The government also proposes to amend the Fish and Wildlife Conservation Act to allow killed cormorants to be left to spoil, but suggests that if this proposal proceeds it may be accompanied by regulations to require retrieval and disposal of the carcasses.  This entire proposal is unacceptable, irresponsible and unjustified, and presents an increased risk to cottagers and recreational boaters and fishermen.

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