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Category Archives: Regulatory Submissions

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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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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Hydroelectric is not a Pathway to Decarbonization or Net Zero

Dear Ministers Guilbeault, Wilkinson and Champagne,

ORA understands the urgency in fulfilling the vitally important commitment the government has made to cut GHG emissions to 40-45% below 2005 levels by 2030; however, we will present evidence from independent third-party peer-reviewed studies indicating that an effective path to decarbonization is not through hydropower.

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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. Continue reading


Is hydroelectric a pathway to decarbonization?

Watch our video to understand how hydroelectricity is greenwashed by Ontario Power Generation as “clean” and “non-emitting” when there are hundreds of independent third-party studies to the contrary. Read our full submission here!

Please sign and share our petition to protect Ontario Rivers and send OPG a strong message! 


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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