Bill 71, ERO-019-6715 – Proposed Building More Mines Act, 2023

By Linda Heron on Sunday, April 16th, 2023

Posted in Bill 71, Environmental Registry, Heavy Metal Contamination, Land Use, Mining, ORA Submissions, Pollution, Regulatory Submissions, River Concerns, Rivers at Risk, Water Quality

Re: Bill 71
ERO-019-6715 – Proposed Building More Mines Act, 2023
ERO-019-6749 – Consequential administrative amendments under the Mining Act
ERO-019-6750 – Proposed regulatory amendments to closure plan and rehabilitation

A very disturbing reality has been revealed, that this government is clearly moving away from evidence-based decision-making that is grounded in science and, instead, is moving fully into a total lack of regard for environmental and stakeholder protections, and Indigenous treaty rights. This government is going too far in its efforts to cut red tape and deregulate environmental protections in Ontario.

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ERO-019-6177 – Review of A Place to Grow and Provincial Policy Statement

By Linda Heron on Thursday, December 29th, 2022

Photo by Al Oman

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).

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ERO-019-6161 – Conserving Ontario’s Natural Heritage

By Linda Heron on Monday, December 26th, 2022

Posted in Bill 23, Environmental Registry, Fisheries, Land Use, ORA Submissions, Species at Risk, Urban Development

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.

^[i] Fisheries in Ontario – Information about recreational and commercial fisheries in Ontario. Online: https://www.ontario.ca/page/fisheries-ontario

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

By Linda Heron on Monday, February 28th, 2022

Posted in Environmental Assessment Act, Environmental Bill of Rights, Joint, Land Use, ORA Submissions, Plastic, Plastics, Recycling, River Concerns, Rivers at Risk, Toxics, Urban Development

“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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EBR Application for Investigation of Town of Erin – Proposed Erin Wastewater Treatment Plant – Joint

By Linda Heron on Friday, August 27th, 2021

Posted in Environmental Assessment Act, Environmental Registry, Environmental Reports, Erin WWTP, Fisheries, Joint, Land Use, ORA Submissions, Regulatory, Regulatory Submissions, River Concerns, Rivers at Risk, Sewage, Urban Development, Waste Water Treatment Facilities, West Credit River

West Credit River Brook Trout. Photo by Steve Noakes.

The Belfountain Community and Planning Organization and Linda Heron are filing an Application for Investigation of the Corporation of the Town of Erin, under Part V, of the Environmental Bill of Rights, 1993. We are very concerned that the Town is moving forward to the construction phase of the Project when it has not yet fulfilled key commitments it made in its Town of Erin Urban Centre Wastewater Servicing Class Environmental Study Report. The Ministry will investigate whether the Town contravened or violated Section 38 of the Environmental Assessment Act.

Please click on this Google Drive link to view or download the Application for Investigation and Appendix A. Continue reading →

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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Minister Wilkinson Decision on Designation Request – Letter to Coalition

By Linda Heron on Wednesday, May 26th, 2021

Posted in Aquatic Life, Brook Trout, Erin WWTP, Fisheries, Government, Impact Assessment Act, Joint, Land Use, ORA Submissions, Redside Dace, Regulatory, River Concerns, Rivers at Risk, Sewage, Sewage, Urban Development, Waste Water Treatment Facilities, West Credit River

After careful consideration of the information provided by the Town of Erin, federal authorities, provincial ministries, the local conservation authority, the concerns expressed in your letter, other known public concerns, and advice from the Impact Assessment Agency of Canada (the Agency), I decided that the Project does not warrant designation pursuant to Subsection 9(1) of the IAA.

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Concerns over Brook Trout and Fish Habitat on the West Credit River

By Linda Heron on Thursday, March 25th, 2021

Posted in Aquatic Life, Brook Trout, Climate Change, Environmental Assessment Act, Erin WWTP, Fisheries, Government, Impact Assessment Act, Land Use, ORA Submissions, Redside Dace, Regulatory, River Concerns, Rivers at Risk, Species at Risk, Urban Development, Waste Water Treatment Facilities, West Credit River

West Credit River. Photo by Steve Noakes.

The Ontario Rivers Alliance (ORA) strongly disagrees with your response to our numerous concerns and recommendations when you assert that you “have concluded that temperature effects have been adequately assessed using field data, a nearby wastewater treatment plant’s effluent temperature data, and CORMIX – a state-of-the-art mixing model”. Your response totally ignored a key issue we raised that will impact on every aspect of stream health and Brook Trout survival, both over the short term and into the future.

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Town of Erin Urban Center Wastewater Servicing Class Environmental Study Report, Joint

By Linda Heron on Thursday, February 18th, 2021

Posted in Government, Joint, Land Use, Municipal, ORA Submissions, River Concerns, Rivers at Risk, Sewage, Urban Development, Waste Water Treatment Facilities, West Credit River

Thank you again for your invitation to meet. We very much welcome the opportunity to discuss our concerns with you and your representatives. Prior to scheduling our meeting, it would be more productive if you could address the questions below in writing. Our expectation is that your answers to the questions below will provide a framework for our meeting. Details of our concerns are outlined in the updated “Briefing Notes”- attached.

The questions that follow do not represent all our questions and concerns; however, we would appreciate detailed answers to the following:

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Bradford Bypass – Request for designation under s.9 of the Impact Assessment Act – Support

By Linda Heron on Wednesday, February 3rd, 2021

Posted in Climate Change, Impact Assessment Act, Land Use, Regulatory, Regulatory Submissions, Species at Risk, Support, Urban Development

A highly controversial environmental assessment study under the Ontario Environmental Assessment Act was completed 23 years ago. It concluded that the project would cause adverse effects to fish habitat including severe stormwater and groundwater impacts. The environmental assessment did not evaluate the impacts on species at risk, migratory birds or climate change. This study has not been updated.

The provincial regulatory process is grossly inadequate.

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