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Category Archives: Regulatory Submissions

Environmental Accountability in Ontario – Consultation Paper

Big Falls – Victory – stopped a proposed hydroelectric project on a sacred site!

The current government has gutted multiple key pieces of environmental legislation and policy that have taken decades to assemble. We are in a perilous state now where the requirement to consult with the public and Indigenous communities has been minimized, and the red tape cutting has gone to such extremes that public health and safety and the natural environment will be at increased risk as the climate continues to warm. 

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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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ERO 019-5816 – Development of a Clean Energy Credit Registry

The total amount of GHGs emissions from a hydroelectric facility is dependent upon many factors, including the impounded reservoir, terrain, amount of organic matter, air-water temperature, reservoir depth and size, vegetation (algae and plant/tree litter), pH values, oxygen levels, flow velocity, water level fluctuations, wind speeds, precipitation, wetlands within the impoundment zone, and facility operating strategy (cycling and peaking to maximize power generation).  Every hydroelectric facility is unique in its complexity and must be carefully studied and continually assessed and monitored to determine the total daily, seasonal and annual GHG emissions per MWh emanating from the system.

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Renomination of Radionuclides as Chemicals of Mutual Concern Under the Great Lakes Water Quality Agreement

Five years ago, in March 2016, 110 groups submitted an application under the Great Lakes Water Quality Agreement (GLWQA) to designate radionuclides as Chemicals of Mutual Concern (CMCs) under Annex 3 of that Agreement. We submitted our nomination in reply to Environment and Climate Change Canada’s (ECCC) and the U.S. Environmental Protection Agency’s (EPA) call for nominations from the public. 

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Hydroelectric Program Development and Assessment – IESO Small Hydro Program

First, it was enlightening to be provided with a clear definition of small and large hydro facilities in the Hydroelectric Program Development and Assessment webinar, as well as a total amount of power generated by these categories. You informed that the definition of small hydro would have a scope of installed capacity of 10 MW and under, with 30 companies representing 50 facilities generating a total of 120 to 150 MW, and large hydro having a scope of installed capacity of over 10 MW, with 3 companies representing 22 facilities producing a total of 1,000 MW. 

The increased number of small hydro facilities making such a small contribution to our electricity grid impacts on multiple Ontario riverine ecosystems, whereas the 22 facilities producing 1,000 MW of power on presumably fewer rivers has a much lower trade-off value. Additionally, larger rivers have a greater capacity to buffer some of the worse effects of hydroelectric. 

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Bill C-28, An Act to amend the Canadian Environmental Protection Act, 1999 – Joint Support

“Banksy Toxic Waste” by Noodlefish is marked with CC BY-NC-SA 2.0.

The undersigned organizations and experts support the following Submission to the Ministers of Environment and Climate Change and Health on Bill C-28, An Act to Amend the Canadian Environmental Protection Act, 1999, etc. submitted by the Canadian Environmental Law Association in February 2022. This submission is relevant for Bill S-5 (An Act to amend the Canadian Environmental Protection Act, 1999, to make related amendments to the Food and Drugs Act and to repeal the Perfluorooctane Sulfonate Virtual Elimination Act) released on February 9, 2022. 

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A Clean Electricity Standard in support of a net-zero electricity sector – Discussion Paper

When people refer to hydroelectric as clean, it’s usually in the context of GHG emissions; however, governments and utilities often use the term categorically and without caveat or qualification. Using the word “clean” in this context is misleading. Just because hydroelectric facilities are not spewing out smoke does not mean they are clean or renewable.  In fact, waterpower has resulted in significant and ongoing impacts on water quality, water quantity, ecological processes, fish and wildlife populations and habitat, and to aboriginal communities. Hydroelectric also makes a significant daily contribution to the earth’s accumulation of greenhouse gases (GHG) in our atmosphere.

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Agnico Eagle Upper Beaver Gold Project – Tailored Impact Statement Guidelines & Public Participation Plan

The Agency has deemed the Project to be within federal jurisdiction and required it to undergo a federal Impact Assessment, and yet Agnico Eagle (AE) is planning to move forward with their advanced exploration as soon as weather permits. ORA objects to the Project moving forward with any advanced exploration activities that would result in any damage to the environment.

AE boasts about setting the “gold standard”, “for over 60 years Agnico Eagle has been attracting investment to Canada, from those who seek a mining company committed to make mining work better for communities, shareholders and the planet”.[1]  ORA submits that Stakeholders expect AE to set the “gold standard” on this Project by undertaking the most environmentally and socially rigorous, advanced and responsible project “for communities, shareholders and the planet”. [1] Agnico Eagle Twitter Posting, 22 November 2021
ORA comments requesting a federal review under the Impact Assessment Act, 2 October 2021.
Upper Beaver Gold Project – IAAC Portal.

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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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