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Category Archives: Environmental Registry

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Accordingly, we collectively recommend that these current proposals should be withdrawn and re-considered by the Ontario government.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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ORA’s first Youth Engagement event!

ORA Hydroelectric Youth Engagement-1ORA Hydroelectric Youth Engagement-2ORA Hydroelectric Youth Engagement-3ORA Hydroelectric Youth Engagement-4ORA Hydroelectric Youth Engagement-5ORA Hydroelectric Youth Engagement-6ORA Hydroelectric Youth Engagement-7

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.

ORA’s team consisted of a Fisheries Biologist, Civil Engineer and Environmental Sciences experts interacting with the students to present and discuss the significant and ongoing environmental effects of hydroelectric facilities, as well as the engineering principles behind them.

The students were then assigned to groups and encouraged to think of alternative eco-friendly solutions to meet the growing electricity demands of the country. We helped them consider several aspects of power generation including how electricity can be used more efficiently, its impacts on wildlife and communities, and the criteria we need to consider when constructing electricity generation facilities. The groups presented their innovative ideas and gift cards were awarded to the group with the most sustainable and feasible solution.

We were thrilled and amazed at the enthusiasm and ingenuity of the students!


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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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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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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