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Category Archives: Environmental Bill of Rights

ERO-025-1363: Streamlining Environmental Permissions for Mineral Exploration

OLYMPUS DIGITAL CAMERA

ORA submits that ERO-025-1363 must be assessed in conjunction with ERO-025-1361, as both postings form part of a coordinated regulatory restructuring intended to accelerate mineral exploration by weakening Ontario’s environmental oversight framework. Together, these proposals shift authority away from the Environmental Protection Act (EPA) and the Ontario Water Resources Act (OWRA) and toward Mining Act instruments that are designed to promote extraction rather than protect water, ecosystems, and public health.

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ERO-025-1212 – Enhancing Transmission Capacity North of Dryden – The Red Lake Transmission Project

Lake Sturgeon trapped in hydroelectric overflow channel.

The Energy for Generations report also mischaracterizes hydropower as “clean” and “non-emitting,” despite decades of global research confirming that reservoirs are significant methane sources, often on par with gas plants. Emissions intensify as reservoirs warm, water levels fluctuate, and organic sediments accumulate behind the dam—conditions prevalent across northern Ontario.

No cumulative-effects assessment has been conducted. The Province has not evaluated the combined impacts of hydropower expansion, mining, new transmission corridors, wastewater and agricultural inputs, industrial discharges, or climate-driven hydrologic shifts—contrary to federal science guidance from DFO and Environment and Climate Change Canada.

Ratepayers also face growing financial increases and risks. The government is proposing to shift early-stage hydropower planning, incentives, and consultation costs—including Indigenous consultation costs—onto electricity bills, an unprecedented transfer of speculative project risk from proponents to the public. Transmission capital costs are likewise recovered from consumers, meaning premature expansion will financially burden households and businesses for decades.

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One Project, One Review: Co-operation Agreements for the Assessment of Major Projects

Vermilion River – Our grandchildren’s future with water!

ORA’s recommendations call for enforceable public-participation standards, clear cumulative-effects gatekeeping, transparent reasons for any federal withdrawal, Indigenous-led consultation processes, and a national commitment to freshwater conservation and resilience. While ORA’s work spans mining (including Ring of Fire), hydropower, wastewater-treatment facilities, and dam-safety issues, these examples illustrate, rather than shift, the focus to the urgent need for fair, transparent, science-based federal oversight.

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Omnibus Bill 5 & Associated ERO Notices: 025-0409, 025-0416, 025-0418, 025-0389, 025-0396

The ORA is writing in response to Omnibus Bill 5, Protecting Ontario by Unleashing the Economy Act, 2025, introduced to the Ontario Legislature on April 15, 2025, and its associated schedules and Environmental Registry of Ontario (ERO) postings. ORA strongly opposes this sweeping omnibus bill, which undermines Ontario’s environmental protections, public and Indigenous rights, and constitutional and legal obligations. Bill 5 and its related schedules represent a regressive and dangerous rollback of vital environmental safeguards and democratic oversight mechanisms.

Bill 5 and its associated schedules and ERO postings represent a sweeping and unprecedented attack on Ontario’s environmental rule of law, public participation rights, and Indigenous sovereignty and rights. The Protecting Ontario by Unleashing the Economy Act, 2025, is misinformation—it does not protect Ontario but rather dismantles the province’s core environmental, legal, and democratic foundations.

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Omnibus Bill 5 – ERO-025-0391 – Special Economic Zones Act, 2025

ORA strongly opposes the proposed Special Economic Zones Act, 2025, as outlined in ERO 025-0391 and introduced through the omnibus Protect Ontario by Unleashing Our Economy Act, 2025 (Bill 5). The legislation enables vast regulatory rollbacks and consolidates decision-making power in the provincial Cabinet, bypassing vital environmental, democratic, and Indigenous consultation mechanisms.

The SEZ framework constitutes a radical departure from Ontario’s long-standing legal tradition of environmental stewardship, public participation, and transparent land-use planning. The proposed Act undermines the public interest in favour of unchecked industrial expansion.

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ERO-019-6951, 6963, 6928 & 6853 – Proposed Streamlining to Permit-by-Rule, Waste Management, Stormwater Management and Site Dewatering Activities – ORA Support

Canadian Environmental Law Association (CELA) has prepared the following analysis and recommendations in response to the four above-noted Environmental Registry of Ontario (ERO) notices, which propose dramatic changes to Ontario’s permit-by-rule framework. The undersigned environmental, conservation, and civil society organizations have endorsed CELA’s submission. Collectively, it is strongly recommended that the Ministry of Environment, Conservation and Parks not move ahead with the four proposals…

We are willing to meet and discuss CELA’s submission at your convenience.

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ERO-019-6216 Proposed Amendments to Greenbelt Plan & ERO-019-6217 – Proposed Amendments to the Greenbelt Area boundary regulation – Joint

West Credit River. Photo by Steve Noakes.

We, the 78 undersigned organizations, are strongly opposed to the Ontario Government’s proposal to remove 7,400 acres of land from the Greenbelt. Opening these lands to development would destroy vital wildlife corridors, negatively impact woodlands, wetlands and watercourses, and result in the loss of over 5,000 acres of farmland. The government’s rationale – that these lands are needed for housing – is unfounded and untrue. We urge you not to proceed with this proposal for the reasons outlined below…

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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-019-4867 – EA Requirements for Advanced Recycling Facilities – Joint

“Advanced recycling” is an umbrella term, sometimes also called “chemical” or “molecular recycling” that encompasses an ever-growing list of technologies that are speculative when it comes to recycling plastic. The reality is that there is no known commercial example of an “advanced recycling” facility anywhere in the world that turns plastic waste back into plastic products or packaging.

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DRAFT PROJECT LIST REGULATION UNDER THE ENVIRONMENTAL ASSESSMENT ACT (ERO 019-4219) – Joint

West Credit River. Photo by Steve Noakes.

 Accordingly, we request that the Ministry revise and re-post the draft regulation for further public review/comment to ensure that it fully implements the stated purpose of the EAA, namely, the betterment of the people of Ontario by providing for the protection, conservation, and wise management of the environment. 

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