The province claims that “Ontario needs more housing, and we need it now. That’s why the Ontario government is taking bold and transformative action to get 1.5 million homes built over the next 10 years.” This Environmental Registry of Ontario (ERO) posting is only one component of a large series of other interconnected ERO postings relating to Bill 23. Due to the short comment period at this busiest time of year for such a complex, vague, poorly considered, and destructive policy and legislative “streamlining”, it is impossible to fully understand the full scope or depth of resulting effects to provide any kind of meaningful input. It is crucial that all ERO postings are well planned, concisely written and defined in clear policy language so the public fully understands what is being proposed and its potential positive and negative effects.
The Ontario government, through Bill 23 and its multitude of complex and interconnected legislation and policy amendments, has:
- Removed municipal jurisdiction from upper-tier municipalities to make policy decisions on land use planning matters that are based on local community interests.
- Removed a significant financial source (permits/building fees) in which to help pay for water and wastewater services, sewers, transportation infrastructure, and community parks needed to service 1.5 million additional homes.
- Prohibited Conservation Authorities all across Ontario from providing practical advice to municipalities, their ability to issue permits, or provide input into environmental concerns.
- Failed to provide adequate public and Indigenous consultation relating to Bill 23 matters.
- Is proposing to streamline the qualifications program for Building Practitioners (ERO-019-6433).
One prime example of ecosystem services is our fisheries which depend on strong and healthy ecosystems. In 2015 the Ontario Government launched a Provincial Fish Strategy – Fish for the Future, which indicated that Ontario’s recreational fisheries support robust sport fishing and tourism, which are a mainstay for many of the northern communities. It also reported that 1.5 million anglers spend $1.75 billion dollars in the province each year, supporting approximately 1,600 resource-based tourism businesses each and every year.[i] These are just a fraction of the ecosystem services that must be weighed against the full life cycle costs and benefits derived from any project that will impact our wetlands, wildlife, air, land or water.
We are a coalition of Indigenous Peoples and conservation and environmental non-governmental organizations concerned with the conservation of American Eel and write to ask that the Department of Fisheries and Oceans take all necessary steps to immediately list this important species under the Species at Risk Act (SARA).
First, the Coalition for the West Credit River (Coalition) would like to express our deepest appreciation that you and your staff worked with our Technical Team over the last several months to incorporate some of our recommendations into the Environmental Compliance Approval (ECA). However, we are concerned that our key recommendations for improvements to the draft ECA, received by you on 2 May, were not reflected in the ECA approved on 3 May 2022.
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.
The Agency has deemed the Project to be within federal jurisdiction and required it to undergo a federal Impact Assessment, and yet Agnico Eagle (AE) is planning to move forward with their advanced exploration as soon as weather permits. ORA objects to the Project moving forward with any advanced exploration activities that would result in any damage to the environment.
AE boasts about setting the “gold standard”, “for over 60 years Agnico Eagle has been attracting investment to Canada, from those who seek a mining company committed to make mining work better for communities, shareholders and the planet”. ORA submits that Stakeholders expect AE to set the “gold standard” on this Project by undertaking the most environmentally and socially rigorous, advanced and responsible project “for communities, shareholders and the planet”.  Agnico Eagle Twitter Posting, 22 November 2021
ORA comments requesting a federal review under the Impact Assessment Act, 2 October 2021.
Upper Beaver Gold Project – IAAC Portal.
Canada has committed to ending plastic waste by 2030.i Reaching this goal will require ambitious actions that address the full life cycle of plastic.
Canada is a major—and growing—producer of plastics and the world’s second highest user of plastic on a per person basis.ii Production, use and disposal of plastics is an increasing contributor to climate change and habitat degradation. It also imposes disproportionate harm on those living next to production and disposal facilities, often low-income and Black, Indigenous and People of Colour communities.
We, the undersigned, therefore call on the Government of Canada to commit immediately to implement the following actions on an urgent basis:
It is challenging to understand the logic of a November 2021 CBC article that reports, “The Nature Conservancy and the World Wildlife Fund are two environmental groups that oppose new hydro dams because they can block fish migration, harm water quality, damage surrounding ecosystems and release methane and CO2. But they say adding turbines to non-powered dams can be part of a shift toward low-impact hydro projects that can support expansion of solar and wind power.” Whether it’s a new dam or an older retrofitted dam, they will result in the same negative impacts and produce the same amount of methane for 70 to 100 years or more.
When these unregulated projects come home to roost, and the environmental impacts begin to damage or destroy highly valued public interests, such as our lakes and rivers, endangered species, our drinking water, and the economy, the government will pay a very high price. Unfortunately, the damage that will result from these irresponsible and negligent actions will not easily be undone, and in many cases will not be resolved in our lifetimes.
If the government wants to incorporate “one-project, one review”, then it must be a robust EA process with fulsome public and Indigenous consultation, or it may find the process much longer than it might have intended.
Is it really renewable energy when it degrades the environment and impacts on communities in a negative way?
There are 241 hydroelectric dams in Ontario, and only 3 facilities have provided any form of fish passage.
The effects of dams and waterpower facilities on fisheries have been well documented over the past century, and include the loss or serious decline of many iconic fish species, which are resources of importance to Ontario’s economy, biodiversity, and natural and cultural heritage.