ORA is very concerned about the extreme deregulation that occurred with the recent waterpower exemption to the Permit to Take Water, and in this new Mercury Regulation where new and significantly redeveloped electricity producing dams have not been addressed. These important legislative requirements were designed to ensure hydroelectric facilities are held accountable for environmental and socio-economic impacts and risks to communities and riverine ecosystems.
The government recommendation asks whether the current concentrations of the chemical “exceed” the benchmarks or guidelines. This implies that we are okay until the benchmarks or guidelines are exceeded. This is not true. Health impacts don’t suddenly start to occur when you cross that narrow threshold of meeting the threshold and move into exceeding. We are already in trouble once we are near or have met the benchmarks or guidelines.
Removing the regulatory baseline for 113 of Ontario’s most heavily polluting facilities in nine environmentally damaging sectors is the wrong approach if the Government of Ontario’s goal is to hold polluters accountable, as it has stated on several occasions. In order to achieve that goal, the MISA regulations should be updated and expanded to new facilities operating in Ontario across the nine industrial sectors.
With climate change impacts bearing down on us, decision makers have a responsibility to ensure the resiliency of our freshwater resources. If this proposal moves forward it will be a precipitous turning point for our future with freshwater in Ontario and beyond.
While abandoning the historically thoughtful context of a normal PPS review is ill-advised at any time, it is irresponsible to tilt the PPS toward an excessive empowerment of development-as-usual at a time of a changing climate, threats to biodiversity, regional ecological integrity, and the gathering momentum of the sixth mass extinction.
In closing, we urge the Ministry of Natural Resources and Forestry to recognize the necessity of managing flood mitigation at a watershed scale and the importance of natural infrastructure. There is no need to reinvent the wheel when it comes to protecting our communities from flooding. This goal can be achieved by investing in our existing agencies (eg, conservation authorities) and by protecting and restoring our natural infrastructure (eg, wetlands and forests).
While we strongly support maximizing consultation opportunities, we also support timely action to address long understood but neglected problems with CEPA, a law that has not been significantly amended in two decades.
On behalf of the 58 undersigned groups, we are providing these comments on the draft Great Lakes Binational Strategy for Mercury Risk Management (April 2018, hereafter “Mercury Strategy”). Note that these comments expand on comments submitted by Canadian Environmental Law Association, National Wildlife Federation and Toxics Free Great Lakes Network on this matter on May 25, 2018.
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.
On behalf of the 47 undersigned organizations, we are providing these comments on the two draft binational strategies under Annex 3 – Binational Strategy for PCB Risk Management (February 2017, hereafter “PCB Strategy”), and Binational Strategy for HBCD Risk Management (March 2017, hereafter “HBCD Strategy”). We are offering several general observations and recommendations to the Parties for both chemical of mutual concern (CMC) strategies together. Then for each strategy document, we offer specific observations and/or recommendations for individual sections.