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Category Archives: Regulatory Submissions

Bill 66 – ERO 013-4234 – Repeal of the Toxics Reduction Act & ERO 013-4235 – Planning & reporting changes under Regs.

Pollution – website banner of toxic water as running from sewers to the environment

ORA submits that Schedule 5 of Bill 66 is a regressive, unwarranted and potentially risky proposal that is inconsistent with the public interest and does not adequately safeguard the health and safety of Ontarians. Does the MECP really want to set the stage for another Grassy Narrows mercury disaster? Instead, the MECP should be focusing on improving the TRA and its regulations to better protect communities.

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Bill 66 – Restoring Ontario’s Competitiveness Act – 2018, Schedule 10

In closing, risky development decisions made in one or more jurisdictions could have significant negative cumulative impacts on our air, land and/or water, as well as the Great Lakes and many other highly valued ecosystems.  Being “Open-for-Business” is a good thing, unless it is at the expense of public health and safety or the environment.  Do we really want to risk another Walkerton or Grassy Narrows disaster? That is precisely what the province is fostering with Bill 66. 

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Speak out against Bill 66 – Schedules 5 and 10

The Government of Ontario is proposing Bill 66, Restoring Ontario’s Competitiveness Act, 2018. It is unacceptable that key environmental protection and legislation that protects the public is under attack.

Schedule 5 of Bill 66 would repeal the Toxics Reduction Act and two regulations. The purpose of the TRA is to prevent pollution and protect human health and the environment by reducing the use and creation of toxic substances and informing Ontarians about toxic substances. 

Schedule 10 of this Bill would enable municipalities to simply pass an “open-for-business planning by-law” under the Planning Act, to exempt local development from the application of key components of several important provincial laws, plans and policies, including the:
• Clean Water Act, 2006, Section 39
• Great Lakes Protection Act, 2015, Section 20
• Greenbelt Act, 2005, Section 7
• Lake Simcoe Protection Act, 2008, Section 6, and 
• Oak Ridges Moraine Conservation Act, 2003, Section 7  

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Approach to a key regulation under the proposed Fish and Fish Habitat Divisions of the Fisheries Act

ORA is very supportive of Fisheries and Oceans Canada’s efforts to strengthen the Fisheries Act Regulations and are pleased to provide our comments on the proposed amendments to the existing Applications for Authorization under Paragraph 35(2)(b) of the Fisheries Act Regulations.

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Impact Assessment Act – Project List, Information Requirements, Timelines

ORA has fully participated in the Canadian Environmental Assessment Process review and was very hopeful with this government’s promise to “rebuild public trust, protect the environment, advance reconciliation with Indigenous peoples, and ensure good projects get built…” While there are some encouraging components, such as requiring the Minister and Cabinet to provide reasons for environmental approvals and creating a single agency to conduct assessments, it is extremely disappointing that the proposed Impact Assessment Act (IAA) further undermines credibility and trust as well as its ability to protect the environment. It is a very flawed process when after going through years of application review and examination of science-based evidence, that the Minister could make a purely political decision and prioritize economic considerations over meeting climate commitments – as it is doing now with the Trans Mountain Pipeline. 

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CELA et al. Comments on PBDE Draft Strategy – ORA Support

The proposed binational strategy on PBDEs outlines limited actions to address PBDEs levels in the Great Lakes beyond the measures that have already been committed on PBDEs by each country. It is also important that U.S. and Canada outline expected reduction targets for PBDEs in contrast to the current approach to outline intended measures. Without targets the ability to indicate successful and effective actions on PBDEs would be difficult to achieve.

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Canadian Environmental Protection Act – Review

We at the ORA fully support strengthening the Canadian Environmental Protection Act (CEPA) through the list of 87 recommendations made by The Standing Committee on Environment and Sustainable Development in its Eighth Report, tabled on 15 June 2017.  The ORA supports the right to a healthy environment.  Healthy communities, a healthy economy and a healthy environment are essential to Canada’s sustainability.   A review of the Act presents the federal government with a golden opportunity to improve the health and well-being of all people in Canada.

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Updating the Part II Order request process under the Environmental Assessment Act – EBR: 013-2099

Many individuals and groups embarking on the Part II Order process are new to it, have no legal assistance or background, and are unfamiliar with the terminology and rules; therefore, if we are truly aiming to provide help to the public it is extremely important that clear, succinct and concise instructions be provided in this policy/guidance document.

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EBR: 013-1817 – Watershed Planning Guidance

This document does not go far enough to place CAs in a central role of watershed planning and management, or in working collaboratively with other municipalities and planning authorities. The CAs have a mandate to ensure the conservation, restoration and responsible management of Ontario’s water, as well as the land and natural habitats; however, municipalities have no such mandate and are more development oriented. It is essential that municipalities are not just using this Watershed Planning Guidance purely for municipal land use planning or a stormwater management tool, but that CAs play a central role, and it is used as an integrated watershed planning and management framework.

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