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Category Archives: Environmental Compliance Approval

ERO 026-0419: Invitation to Municipalities to Register Potential Interest in Implementing a Water and Wastewater Public Corporation Model

By Linda Heron on Tuesday, August 11th, 2026
Posted in Sustainability, Drinking Water, Statement of Env. Values, Environmental Registry, River Concerns, Waste Water Treatment Facilities, Government, Environmental Compliance Approval, Sewage, Urban Development, Water Quality, Policy & Process, Safe Water Act, Sewage

The notice asks municipalities why they are interested in the model and how they anticipate it “will improve” their services; what their fiscal circumstances are; what steps they are taking on infrastructure; how independent governance “would benefit” their systems; how their proposal “improve[s] efficiency and generate[s] economies of scale”; and whether they are “willing to merge your water and wastewater systems into a public utility with surrounding systems.”1

Not one question asks about risk. Not one asks about drinking water sources, receiving waters, watersheds, climate resilience, affordability for low-income households, First Nations, or the Crown’s duty to consult. Not one asks what happens if the model does not work. The questions are written so that only a municipality already inclined toward the model can answer them, and only in its favour.

The sixth question is the one that reveals the destination. Merging systems “with surrounding systems” is regional consolidation of municipal water and wastewater utilities. That is a far larger proposal than the notice describes, and it has not been consulted on.

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ERO 019-2487, Supporting Guide to Calculate the Design Sewage Flow for Subsurface Sewage Works Subject to Section 53 of the Ontario Water Resources Act, and ERO 026-0643: Replacing Table 5-3 in the Design Guidelines for Sewage Works (2008)

By Linda Heron on Tuesday, August 11th, 2026
Posted in Environmental Registry, Regulatory, River Concerns, Rivers at Risk, Waste Water Treatment Facilities, Fisheries, Environmental Compliance Approval, Sewage, Environmental Protection Act, Urban Development, Water Quality, Ontario Water Resources Act, Policy & Process

ORA submits this letter in response to both postings together, because they are one instrument. ERO 019-2487 proposes the draft Design Sewage Flow Guide (the Guide), and ERO 026-0643 proposes to revoke Table 5-3 of the Design Guidelines for Sewage Works, 2008, and replace it with Table 1 of that same Guide.1,2 Neither can be assessed without the other.

ORA supports a clear, modern, well-evidenced guide for large subsurface sewage disposal systems. Applicants deserve certainty, and the Ministry of the Environment, Conservation and Parks (the Ministry) deserves complete applications. Much of the draft Guide does useful work, particularly the design options for modular systems, flow balancing, alternating drainfields and reserve areas.

ORA does not support the proposal as drafted, for one central reason. The numbers that come down are prescriptive. The protections that would make lower numbers safe are advisory. A subsurface sewage system that is undersized does not fail quietly. It surfaces, and it reaches ditches, streams and rivers. The recommendations below are offered to correct that imbalance, and none of them should be read as support for the reduced values in Table 1.

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ERO-025-1361: Exempting Low-risk Activities from Requiring Environmental Permissions

By Linda Heron on Monday, February 2nd, 2026
Posted in Sustainability, Drinking Water, Bottled Water, ORA Submissions, Permit to Take Water, Aquatic Life, Environmental Registry, Regulatory, Climate Change, River Concerns, Rivers at Risk, Fisheries, Mining, Environmental Compliance Approval, Sewage, Water Quality, Ontario Water Resources Act

Despite being characterized as “low risk,” many of the activities proposed for exemption pose known and foreseeable risks to private wells, municipal source water, groundwater-fed streams, wetlands, and downstream surface waters, particularly when considered cumulatively and under increasingly volatile hydrologic conditions. The Ministry’s assertion that these exemptions will not impact protection of human health or the environment is unsupported and contradicted by established hydrogeological science.

ORA’s concerns apply equally to the supporting Appendix, which relies on categorical assumptions of ‘low risk’ without evaluating groundwater connectivity, cumulative effects, or climate-driven hydrologic change.

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

By Linda Heron on Monday, February 2nd, 2026
Posted in Sustainability, Drinking Water, Bottled Water, ORA Submissions, Permit to Take Water, Environmental Registry, Regulatory, Climate Change, River Concerns, Energy, Rivers at Risk, Fisheries, Environmental Bill of Rights, Environmental Compliance Approval, Environmental Protection Act, Ontario Water Resources Act

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-025-0899 – 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-025-0600 – Streamlining Environmental Permissions for the Electricity Sector

By Linda Heron on Monday, August 25th, 2025
Posted in ORA Submissions, Hydroelectric, Environmental Registry, Regulatory, Energy, Rivers at Risk, Environmental Assessment Act, Environmental Compliance Approval, Environmental Protection Act, Water Quality

Wabagishik Rapids, Vermilion River

While the government claims this change would “streamline permissions” and “maintain environmental protections,” ORA submits that the proposed shift significantly undermines environmental safeguards, weakens public and Indigenous rights, and increases risks to Ontario’s watersheds, ecosystems, and communities.

The province’s own Ontario Provincial Climate Change Impact Assessment (2023) cautions that “changes in Ontario’s climate are expected to continue at unprecedented rates… and it will pose indirect threats to things like water availability and water quality.”[i] It further projects that northern Ontario, which experiences on average four extreme heat days annually, is projected to see upwards of 35 such days each year. while southern Ontario will see upwards of 55-60 extreme heat days annually by the 2080s—a fourfold increase from the current annual average of 16 days. These changes threaten stream temperature regimes, species survival, wetland retention, and seasonal flows.

[i] Ontario Provincial Climate Change Impact Assessment, Technical Report, January 2023.  Online: https://www.ontario.ca/files/2023-11/mecp-ontario-provincial-climate-change-impact-assessment-en-2023-11-21.pdf Continue reading →

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

By Linda Heron on Monday, October 30th, 2023
Posted in Regulatory, Stormwater, River Concerns, Rivers at Risk, Waste Water Treatment Facilities, Joint, Land Use, Mining, Quarries, Environmental Bill of Rights, Environmental Compliance Approval, Sewage, Species at Risk, Urban Development, Water Quality, Watershed Planning, Ontario Water Resources Act, Policy & Process, Provincial Policy Statement

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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Erin WWTP – Environmental Compliance Approval – Joint

By Linda Heron on Wednesday, August 24th, 2022
Posted in Erin WWTP, ORA Submissions, Regulatory, Rivers at Risk, Waste Water Treatment Facilities, Joint, Environmental Compliance Approval, Urban Development, West Credit River

Photo by Steven Noakes – West Credit River Brook Trout

The Coalition for the West Credit River (Coalition) remains very concerned with the potential environmental impact of the Erin Water Resource Recovery Facility (WRRF) and, in particular, the temperature of its treated effluent harming the sensitive coldwater Brook Trout habitat of the West Credit River. 

As your Ministry is aware, the approved sewage treatment plant proposes to discharge large flows of sewage effluent into the relatively small flow of the West Credit River. The lack of significant dilution will greatly magnify the thermal impact of warm effluent on this coldwater stream. 

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Delegation Request – Erin Water Resource Recovery Facility – Joint

By Linda Heron on Friday, June 3rd, 2022
Posted in Brook Trout, Erin WWTP, Aquatic Life, Regulatory, River Concerns, Rivers at Risk, Waste Water Treatment Facilities, Fisheries, Joint, Environmental Compliance Approval, Sewage, Urban Development, Sewage, West Credit River

Photo by Steven Noakes

The Coalition is very appreciative of your strong support in recommending to the Honourable David Piccini, Minister of Environment, Conservation Parks (MECP) and Mayor Allan Alls, Town of Erin, that our draft Monitoring and Adaptive Management Plan be integrated into the Environmental Compliance Approval (ECA). As you are likely aware, the ECA for the Erin Water Resource Recovery Facility was approved on 3 May 2022 by Aziz Ahmed, P.Eng., MECP Manager of Municipal Water & Wastewater Permissions, appointed for the purposes of Part II.1 of the Environmental Protection Act. 

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