ERO-025-0899 – Policy proposal to regulate additional sewage systems under the Building Code to support construction of on-farm worker housing

By Linda Heron on Sunday, December 7th, 2025

Posted in Agriculture, ORA Submissions, Environmental Registry, Regulatory, River Concerns, Rivers at Risk, Clean Water Act, Environmental Compliance Approval, Sewage, Water Quality

Manitou River

As ORA stated in our other on-farm sewage-related comments, this proposal represents a substantial loosening of Ontario’s long-standing safeguards against groundwater contamination, nutrient loading, failing septic systems, and cumulative impacts on rural watersheds. It shifts higher-risk sewage systems—up to a staggering 50,000 L/day per lot—from the rigorous Environmental Compliance Approval (ECA) regime into the far less protective Building Code framework. The province is attempting to replace environmental oversight with speed and convenience for development, at the direct expense of source water protection, freshwater ecosystem health, and the rights and safety of on-farm workers themselves.

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ERO-025-0872 – Streamlining environmental permissions for sewage works servicing on-farm worker housing

By Linda Heron on Sunday, December 7th, 2025

Posted in Sustainability, ORA Submissions, Septic Systems, Environmental Registry, Regulatory, River Concerns, Clean Water Act, Land Use, Environmental Compliance Approval, Urban Development, Sewage

The magnitude of these systems alone makes this proposal indefensible. Both documents confirm that sewage works with a total capacity of up to 50,000 litres per day and individual systems with a capacity up to 25,000 litres per day may be installed and operated without an Environmental Compliance Approval.^1,2 These volumes are not small or low-risk; they are equivalent to communal wastewater treatment systems serving dozens of households. Systems of this scale require careful plume modelling, nitrate-loading calculations, groundwater mounding analysis, assessment of down-gradient receptors, and long-term effluent criteria development—work that must be independently scrutinized to ensure protection of human health and drinking water sources. Allowing these systems to operate without MECP review creates an unacceptable risk of contaminant migration into shallow aquifers, private wells, and baseflow that sustains rivers and coldwater ecosystems.

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ERO-025-1104- Regulatory changes for accelerating and improving protections for Ontario’s drinking water source

By Linda Heron on Thursday, December 4th, 2025

Posted in ORA Submissions, Environmental Registry, River Concerns, Clean Water Act, Conservation Authorities Act, Land Use, Urban Development, Water Quality

Algae bloom.

The government’s proposal places disproportionate weight on “streamlining” and “efficiency,” as though Source Protection Plan (SPP) amendments are administrative bottlenecks rather than critical public safety safeguards. Altering or adding a municipal well or intake is not a technical footnote — it is a major hydrological intervention that alters the behaviour of the entire source watershed or aquifer system.

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Ontario Auditor General’s Report on Non-Municipal Drinking Water – CELA, Joint

By Linda Heron on Thursday, May 1st, 2025

Posted in Regulatory, River Concerns, Joint, Clean Water Act, Mercury, Municipal, PFAS, Toxics

As we near the 25th anniversary of the deadly drinking water tragedy in Walkerton, Ont., we are calling on the government to reaffirm Ontario’s commitment to safe drinking water for all by implementing the Auditor General’s 17 recommendations in a meaningful, timely and transparent way.

In addition to these findings, the Auditor General cited concerns about transparency, rigor and timeliness in how MECP and MoH approach regulatory modernization. Of note was MECPs incomplete feasibility assessment regarding protecting the source water of non-municipal systems – a critically important protection that is only afforded to Ontarians who rely on drinking water systems owned and operated by municipalities.

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

By Linda Heron on Monday, April 29th, 2024

Posted in ORA Submissions, Heavy Metal Contamination, Pollution, Joint, Clean Water Act, Water Quality, Ontario Water Resources Act, Safe Water Act

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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ERO-019-3268 – Strengthening our Environmental Compliance Approach

By Linda Heron on Monday, June 28th, 2021

West Credit River, Photo by Steve Noakes

The ORA offers strong support for polluters being held accountable; however, that isn’t what’s happening here. Rather than strengthening enforcement tools that hold polluters accountable, this government is systematically and persistently dismantling, weakening or bypassing all environmental policy and legislation that was designed to protect the environment and deter those industries, corporations or individuals who would pollute and/or destroy the environment.

These ERO postings consistently mislead the public, especially in the top several paragraphs and titles, which contain misleading introductions to the proposed policy the government is proposing. In fact, you can always count on these “modernization” policy changes to be a further attack on environmental policy and legislation. It is even more despicable that these attacks have largely been carried out during the government’s declared COVID Emergency, where no public consultation is required, and what consultation that does take place is meaningless when the main objective is to cut red tape and remove any roadblocks to development and pollution, in spite of the public’s strong recommendations to protect the environment.

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Speak out against Bill 66 – Schedules 5 and 10

By Linda Heron on Sunday, January 13th, 2019

Posted in Campaign, ORA Submissions, Environmental Registry, Regulatory, River Concerns, Government, Industry, Clean Water Act, Regulatory Submissions, Great Lakes Protection Act, Great Lakes Water Quality Agreement, Planning Act

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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EBR: 013-1817 – Watershed Planning Guidance

By Linda Heron on Saturday, April 7th, 2018

Posted in ORA Submissions, Environmental Registry, Regulatory, River Concerns, Clean Water Act, Conservation Authorities Act, Regulatory Submissions

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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Hydrocarbon Pipelines Added to Table of Drinking Water Threats – EBR-013-1839 and 1840

By Linda Heron on Tuesday, February 20th, 2018

Posted in ORA Submissions, Pollution, Environmental Registry, Regulatory, Pipelines, River Concerns, Rivers at Risk, Clean Water Act, Regulatory Submissions, Water Quality

ORA would like to point out that the proposed list does not address an in-water pipeline scenario, it only addresses pipelines above, below and under a water body. Therefore, it is extremely important that the following be added:

Recommendation 1:

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