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Category Archives: Environmental Registry

ERO 019-4971 – Draft Low Impact Development Stormwater Management Manual

Blue Heron in Waterloo, Ontario, by Leslie Bamford

The ORA is in full agreement that Low Impact Development (LID) must be a priority in development planning guidance for stormwater management practices and should include innovative green infrastructure such as rain harvesting, rain gardens, green roofs, urban trees and forests, permeable surfaces, ditches, swales, stormwater catchments, and must emphasize the protection of wetlands.

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ERO-019-4967 – Municipal Wastewater and Stormwater Management in Ontario – Discussion Paper

The province should not be streamlining reporting requirements. Wastewater and stormwater management are vitally important to the health and resilience of our freshwater resources and to the people of Ontario. There are numerous complex and site specific considerations for each and every outfall of sewage effluent that is unique to the area and the water body. We cannot continue to release partially treated or untreated sewage into our lakes and rivers. We must stop thinking about how we can make it easier and start thinking about how we can make wastewater treatment more efficient and effective so we can build resilience into our lakes and rivers to help prepare for a warming climate. 

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ERO 019-4108 – Expanding Administrative Penalties for Environmental Contraventions

The ORA strongly supports the proposed penalty regulations under the Environmental Protection Act and the Ontario Water Resources Act that would revoke and replace existing penalty regulations under these acts.

That being said, this regulation would have been even more beneficial if this provincial government had not spent the last 4 years (more than 2 years of which have been under a COVID Emergency) totally gutting our hard-earned protective environmental legislation (all in the name of “cutting red tape”) and degrading (in some cases eliminating) the public’s ability to have input into a Project, to be consulted, and to appeal a Minister’s decision. Proponents have no worry of polluting or protecting the environment when there is no effective legislation left to comply with.

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ERO-019-4978 – Subwatershed Planning Guide

The ORA is very supportive of policy and legislation that provides an ecosystem approach for planning at a watershed and subwatershed scale. It is essential that we ensure a healthy environment, with clean and abundant freshwater resources, that helps to provide resilience to the extremes of climate change.  We are appreciative of the information webinar on the Subwatershed Planning Guide, and the 45-day comment period.

Overall, we are generally supportive of the draft guidelines as they seem broad ranging and comprehensive.  We are especially pleased to see the partnership approach with Indigenous peoples included in the Guide and agree that this approach will lead to a much more comprehensive subwatershed plan.

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ERO 019-4219 – Moving to a project list approach under the EAA

West Credit River Brook Trout – Photo by Steve Nokams

When these unregulated projects come home to roost, and the environmental impacts begin to damage or destroy highly valued public interests, such as our lakes and rivers, endangered species, our drinking water, and the economy, the government will pay a very high price.  Unfortunately, the damage that will result from these irresponsible and negligent actions will not easily be undone, and in many cases will not be resolved in our lifetimes.

If the government wants to incorporate “one-project, one review”, then it must be a robust EA process with fulsome public and Indigenous consultation, or it may find the process much longer than it might have intended.

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Response to MECP Decision on Application for Investigation

Photo by Steve Noakes.

We were very disappointed in Ms. Paul’s decision to deny our Application for Investigation; however, we were also not surprised. This provincial government has systematically dismantled much of Ontario’s environmental policy and legislation with an ambitious goal of “cutting red tape”, and “modernizing”. They have successfully carried out their mission through specious explanations that mislead the public and deflect concern over important Environmental Registry postings and massive omnibus Bills. This method has allowed them to proceed with sweeping cuts to numerous pieces of important legislation without much public fuss – all during their declared COVID Emergency. The decision on our Application for Investigation is simply another example of bypassing key legislation to facilitate a Project that has strong community opposition.

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EBR Application for Investigation of Town of Erin – Proposed Erin Wastewater Treatment Plant – Joint

West Credit River Brook Trout. Photo by Steve Noakes.

The Belfountain Community and Planning Organization and Linda Heron are filing an Application for Investigation of the Corporation of the Town of Erin, under Part V, of the Environmental Bill of Rights, 1993. We are very concerned that the Town is moving forward to the construction phase of the Project when it has not yet fulfilled key commitments it made in its Town of Erin Urban Centre Wastewater Servicing Class Environmental Study Report.  The Ministry will investigate whether the Town contravened or violated Section 38 of the Environmental Assessment Act. 

Please click on this Google Drive link to view or download the Application for Investigation and Appendix A.  Continue reading


ERO-019-3268 – Strengthening our Environmental Compliance Approach

West Credit River, Photo by Steve Noakes

The ORA offers strong support for polluters being held accountable; however, that isn’t what’s happening here.  Rather than strengthening enforcement tools that hold polluters accountable, this government is systematically and persistently dismantling, weakening or bypassing all environmental policy and legislation that was designed to protect the environment and deter those industries, corporations or individuals who would pollute and/or destroy the environment.

These ERO postings consistently mislead the public, especially in the top several paragraphs and titles, which contain misleading introductions to the proposed policy the government is proposing.  In fact, you can always count on these “modernization” policy changes to be a further attack on environmental policy and legislation. It is even more despicable that these attacks have largely been carried out during the government’s declared COVID Emergency, where no public consultation is required, and what consultation that does take place is meaningless when the main objective is to cut red tape and remove any roadblocks to development and pollution, in spite of the public’s strong recommendations to protect the environment.

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ERO-019-3007 – Reviewing Ontario’s long-term energy planning framework

No new hydroelectric projects should be included in the short or long-term energy plan. Hydroelectric power generation is dirty energy resulting in significant ongoing negative impacts to riverine ecosystems, including, but not limited to GHG emissions (methane and Co2), degraded water quality, declining fish populations, methyl mercury contamination of fish, and ongoing harm to Indigenous communities.

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ERO-019-2826, Statement of Environmental Values for the Ministry of Environment, Conservation and Parks

If the SEV is not being taken seriously now, why would we believe it will be taken seriously when this new SEV is adopted? The MECP should respect and fulfill its SEV in all areas of its purpose, which is its promise to Ontario taxpayers. Rather than focusing so heavily on the economy the MECP must apply its SEV in the protection and conservation of the environment. 

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