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Category Archives: Joint

ERO No. 019-8320: New Minister’s Permit and Review powers under the Conservation Authorities Act – Joint

We, the 61 undersigned organizations, strongly oppose the proposed regulation regarding the Minister’s new permit and review powers under the Conservation Authorities Act. The proposed regulation, if passed, would enable the Minister of Natural Resources and Forestry to override a very broad suite of permitting decisions issued by conservation authorities for activities prohibited without a permit. In such cases, rather than having permitting decisions informed by the deep local knowledge, technical expertise and watershed-health mandate of conservation authorities, they will be politically driven at the request of development proponents seeking to reduce their cost burden and proceed with otherwise prohibited activities regardless of risks.

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American Eel: Consultation check-in on listing under the Species at Risk Act (SARA) – Joint

American Eel

Like Pacific Salmon in the west, American Eel are critically important to Indigenous Peoples in eastern Canada – culturally, spiritually, and for food security. Unlike Pacific Salmon, however, little has been done to address their decline. Despite being assessed as Threatened by COSEWIC in 2012 — more than a decade ago — the species is not yet listed and consequently there is no recovery strategy in place directed at stemming further population decline or contributing to the recovery of this species. The need to implement recovery is urgent given the recent and rapid decline of American Eel in Canada and globally, including a 99% decline in the Upper St. Lawrence population. The decision on whether to add the American Eel to Schedule 1 of the Species at Risk Act has been delayed for far too long. This delay has hindered conservation efforts and the creation of meaningful partnerships to advance the recovery of American Eel.

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Request for Commitment of Continued Public Funding of Bacteriological Private Well Testing – Joint

There have been recent reports from various sources stating that Public Health Ontario has plans to phase out public access to free bacteriological testing for private water wells. The proposed “gradual discontinuation” of this important testing service was described in the Auditor General’s 2023 audit report as part of a “streamlining” plan that Public Health Ontario has been developing since 2017. Subsequently, Minister Jones has stated in the legislature that the private well water testing will continue.

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Provincial Action on Road Salt Pollution of Aquatic Bodies – Sign our Petition

Road salts represent the largest source of chloride inputs into Ontario waters. Ontario makes up less than 11% of Canada’s landmass, but it is the biggest user of road salts in the nation. Your Ministry’s scientific data shows conclusively that salt has been and continues to be a threat to aquatic ecosystems which is increasing in magnitude over time.  SIGN OUR PETITION HERE!

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ERO-019-7378 – Black Ash regulation – Joint

Black Ash

On behalf of the 42 undersigned organizations, we are writing to express our strong opposition to the proposed conditional exemption for the endangered Black Ash, under Ontario’s Endangered Species Act, 2007 (ESA). The proposed minimizes protections for the Black Ash at every turn and reveals a disturbing lack of intent on the part of the Ministry of Environment, Conservation and Parks (MECP to prioritize the survival and recovery of the species.

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ERO-019-6951, 6963, 6928 & 6853 – Proposed Streamlining to Permit-by-Rule, Waste Management, Stormwater Management and Site Dewatering Activities – ORA Support

Canadian Environmental Law Association (CELA) has prepared the following analysis and recommendations in response to the four above-noted Environmental Registry of Ontario (ERO) notices, which propose dramatic changes to Ontario’s permit-by-rule framework. The undersigned environmental, conservation, and civil society organizations have endorsed CELA’s submission. Collectively, it is strongly recommended that the Ministry of Environment, Conservation and Parks not move ahead with the four proposals…

We are willing to meet and discuss CELA’s submission at your convenience.

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Advancing Protected and Conservation Areas – Joint

On April 1, 2021 the Ontario government announced the appointment of a working group of conservation experts to “identify opportunities to protect and conserve more natural areas” in the province, a key commitment in the government’s Made-in-Ontario Environment Plan. The working group provided a report with recommendations to the Minister of Environment, Conservation and Parks entitled, “A New Approach: Advancing Protected and Conserved Areas in Ontario.” The report was only recently made available to the public through a Freedom of Information request.

On behalf of the 124 undersigned organizations, we urge you to implement key recommendations of the report, specifically: 1) to partner with Indigenous Nations and engage the public, municipalities and interested groups to immediately implement a strategy to protect 30 percent of our lands and waters by 2030 and 2) to establish an innovation fund to support implementation. We urge you to make funding and resources available commensurate with the globally significant opportunity that is available in Ontario right now.

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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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Ministers Guilbeault and Duclos: Expand the single-use plastic ban – Joint

We, the undersigned organizations and individuals, are deeply concerned about the plastic waste and pollution crisis and its devastating impacts worldwide. As responsible ministers for the Canadian Environmental Protection Act – “an Act respecting pollution prevention and the protection of the environment and human health”, we urge you to take bolder and urgent action to tackle the crisis by expanding the single-use plastics ban to include a more comprehensive list of problematic plastics and substances.

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