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Category Archives: Ontario Water Resources Act

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

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-019-6951, 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-019-6141 – Legislative & Regulatory proposals affecting Conservation Authorities

“Consider This” by Storm Crypt is licensed under CC BY-NC-ND 2.0.

The Ontario government’s own 2020 report, “Protecting People and Property: Ontario’s Flooding Strategy,” which resulted from the 2019 flooding disaster, states very clearly that “Flood risk management is achieved through multiple provincial acts, regulations, policies and technical guides and a wide range of provincial programs and services. Successful implementation relies on partnerships between provincial ministries, municipalities, Indigenous communities, conservation authorities, stakeholder organizations and the federal government.” 1

Instead, this proposal seeks to do the very opposite. It proposes to exempt the CAs from their authority under ten crucial Acts and their associated regulations; it blocks the CA partnership with municipalities and stakeholders and takes the authority of CAs away from permitting so they cannot properly fulfill the recommendations of this report that was commissioned by the Ontario government only a few short years ago.  Now, where is the wisdom in that?

[1] Protecting People and Property: Ontario’s Flooding Strategy, 10 March 2020. P-7/42

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Bill 23 – ORA Comments to the Standing Committee on Heritage Infrastructure and Cultural Policy

Vermilion River – Our grandchildren’s future with water!

The ORA is concerned that Bill 23 will have far-reaching negative effects on the environment and communities. This major streamlining of development is irresponsible and a recipe for disaster. Bill 23 works against sustainability and the watershed approach at a time when Government decision-making should be focused on protecting the environment and building climate resilience into Ontario’s communities and infrastructure.

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Hydroelectric Program Development and Assessment – IESO Small Hydro Program

First, it was enlightening to be provided with a clear definition of small and large hydro facilities in the Hydroelectric Program Development and Assessment webinar, as well as a total amount of power generated by these categories. You informed that the definition of small hydro would have a scope of installed capacity of 10 MW and under, with 30 companies representing 50 facilities generating a total of 120 to 150 MW, and large hydro having a scope of installed capacity of over 10 MW, with 3 companies representing 22 facilities producing a total of 1,000 MW. 

The increased number of small hydro facilities making such a small contribution to our electricity grid impacts on multiple Ontario riverine ecosystems, whereas the 22 facilities producing 1,000 MW of power on presumably fewer rivers has a much lower trade-off value. Additionally, larger rivers have a greater capacity to buffer some of the worse effects of hydroelectric. 

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ERO 019-4971 – Draft Low Impact Development Stormwater Management Manual

Blue Heron in Waterloo, Ontario, by Leslie Bamford

The ORA is in full agreement that Low Impact Development (LID) must be a priority in development planning guidance for stormwater management practices and should include innovative green infrastructure such as rain harvesting, rain gardens, green roofs, urban trees and forests, permeable surfaces, ditches, swales, stormwater catchments, and must emphasize the protection of wetlands.

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ERO 019-4108 – Expanding Administrative Penalties for Environmental Contraventions

The ORA strongly supports the proposed penalty regulations under the Environmental Protection Act and the Ontario Water Resources Act that would revoke and replace existing penalty regulations under these acts.

That being said, this regulation would have been even more beneficial if this provincial government had not spent the last 4 years (more than 2 years of which have been under a COVID Emergency) totally gutting our hard-earned protective environmental legislation (all in the name of “cutting red tape”) and degrading (in some cases eliminating) the public’s ability to have input into a Project, to be consulted, and to appeal a Minister’s decision. Proponents have no worry of polluting or protecting the environment when there is no effective legislation left to comply with.

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ERO-019-3268 – Strengthening our Environmental Compliance Approach

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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Coalition concerns over Erin Wastewater Treatment Plant

Our concerns are well documented in the attached Briefing Notes report, which has been prepared by our Coalition in the process of requesting a federal review under the Impact Assessment Act.

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Exempting dams from requiring a Permit to Take Water – ERO-019-2517

Melville Dam, Credit River, breached on 26 June 2017

ORA submits that the MECP’s priority must be the pursuit of its Statement of Environmental Values (SEV), and its vision and mandate of “an Ontario with clean and safe air, land and water that contributes to healthy communities, ecological protection, and environmentally sustainable development for present and future generations[i].  There is nothing in the MECP’s SEV that promises to “remove the regulatory burden” from industry or “provide some cost savings for dam owners and operators”.  It is not the MECP’s duty to save dam owners and operators money or ease their regulatory burden. Its duty is to fulfill its Mandate to protect the environment and to follow its promise of environmentally sustainable development for our present and future generations.  Certainly, MECP’s priority should not be to cut regulatory burden at the expense of our air, land and water.  It is a tragedy that today’s cost savings for dam owners and operators will be borne on the backs of our children and grandchildren.

[i] Statement of Environmental Values: Ministry of the Environment and Climate Change

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