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Category Archives: Environmental Registry

ERO-019-8369 – Proposed Bill 185, Cutting Red Tape to Build More Homes Act, 2024

Vermilion River – Our grandchildren’s future with water!

The ORA is strongly opposed to the proposal to remove the public’s appeal rights for the adoption or amendment of Official Plans and Zoning By-Laws to the Ontario Land Tribunal (OLT). These amendments are unfair as they undermine the public’s right to appeal local land-use decisions and deny access to justice. The public’s right to appeal has been a long-standing feature of the Planning Act, and there is no persuasive evidence-based reason by this government to revoke this important right. It is consequential when a municipality approves a project that would be environmentally damaging to a property owner or may cause public health issues to the local community, the public would no longer be able to challenge the municipality’s decision at the OLT.

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ERO-019-4300 – Exempting 5 LRIA Orders from EBR Stakeholder Consultation Requirements

The ORA is in strong support of ensuring that MNRF is more efficient in issuing permits to remove old and unsafe dams; however, we are strongly opposed to exempting these five LRIA orders from the requirements to consult the public under Part II of the EBR. This would mean that stakeholders, the public and Indigenous communities would have no opportunity to be consulted and provide input on projects that could heavily impact their property values, quality of life, and other important landowner interests!

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ERO-019-7891-Proposing to Revoke the Municipal Class EA and make a New Regulation

Toronto Harbour Sewage Bypass – CBC

This proposal has the potential to pose major environmental and public safety risks to stakeholders, the public, and Indigenous communities. Consequently, the ORA is strongly opposed to all aspects of this proposed new MPAP regulation and highly recommends the complete withdrawal and permanent abandonment of the entire MPAP Regulation and revocation of the MCEA.

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ERO-019-7739 – Proposal to return lands to the Greenbelt

Greenbelt

ORA strongly supports the following:

  1. The new section to the Act, 14.1, to restore the Greenbelt Plan to the 15 areas of land that were removed or redesignated in 2022, while maintaining the 2022 lands that were added.
  2. The re-enactment and enhancement of section 2 of the Oak Ridges Moraine Conservation Act, 2001, to repeal the authority of the Lieutenant Governor in Council to add/remove lands from the Greenbelt.
  3. Lastly, ORA supports the new section of the Act, 26, to restore the designation of land that was redesignated in 2022.

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ERO-019-7561 & ERO-019-7562 – Proposal to Return Lands to the Greenbelt

In response to the proposal to return lands to the Greenbelt, the ORA offers our strong support for all lands that were removed from the Greenbelt on 14 December 2022 being immediately returned to the Greenbelt, as per the proposed Amendments to the Greenbelt Plan and the Greenbelt Area Boundary Regulation O.Reg 59/05.

ORA also recommends that all lands this government added to the Greenbelt land to compensate for the December 2022 removal of Greenbelt lands remain within the Greenbelt under the protection of the Greenbelt Act, 2005, and Greenbelt Plan.

Once the land is returned to the Greenbelt, it must remain designated as Greenbelt with all the relevant land use restrictions, and any future removal must be made extremely onerous through protective amendments to the appropriate legislation.

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ERO-019-7598 – Proposed Regulatory Amendments to the Build More Mines Act, 2023

“Open-pit Cppper Mine – Mission Complex” by docentjoyce is licensed under CC BY 2.0.

Actually, this government does not deserve the trust of its constituents because it has eroded all of our environmental protections and public engagement and consultation in related policy and legislation over the last 5 years. Therefore, when it claims that “the intention is not to fundamentally change the underlying rules but rather to clarify their source and application”, it is unbelievable – no longer credible – trust has been lost.  Especially since this proposal and the entire Build More Mines Act, 2023 was a total gutting of the Mining Act.

While streamlining mining legislation and policies can bring about certain benefits such as increased efficiency and reduced bureaucracy if done correctly; excessive streamlining without adequate safeguards can impact the environment, communities and even the long-term sustainability of the mining industry.  It will also lead to environmental degradation, community displacement and conflicts, social and economic imbalances, and undermine public trust with the lack of transparency and accountability.

To avoid these negative consequences, it is essential to strike a balance between streamlining mining regulations for efficiency and ensuring that there are robust environmental, social and legal safeguards in place. Proper consultation with local communities, adherence to international best practices and strict enforcement of responsible mining standards are crucial for achieving sustainable and responsible mining practices. This is not the case with any of these amendments.

Consequently, ORA rejects this proposal to streamline the Regulation.

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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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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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