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Category Archives: Pollution

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-019-7891-Proposing to Revoke the Municipal Class EA and make a New Regulation

Toronto Harbour Sewage Bypass – CBC

This proposal has the potential to pose major environmental and public safety risks to stakeholders, the public, and Indigenous communities. Consequently, the ORA is strongly opposed to all aspects of this proposed new MPAP regulation and highly recommends the complete withdrawal and permanent abandonment of the entire MPAP Regulation and revocation of the MCEA.

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ERO-019-7598 – Proposed Regulatory Amendments to the Build More Mines Act, 2023

“Open-pit Cppper Mine – Mission Complex” by docentjoyce is licensed under CC BY 2.0.

Actually, this government does not deserve the trust of its constituents because it has eroded all of our environmental protections and public engagement and consultation in related policy and legislation over the last 5 years. Therefore, when it claims that “the intention is not to fundamentally change the underlying rules but rather to clarify their source and application”, it is unbelievable – no longer credible – trust has been lost.  Especially since this proposal and the entire Build More Mines Act, 2023 was a total gutting of the Mining Act.

While streamlining mining legislation and policies can bring about certain benefits such as increased efficiency and reduced bureaucracy if done correctly; excessive streamlining without adequate safeguards can impact the environment, communities and even the long-term sustainability of the mining industry.  It will also lead to environmental degradation, community displacement and conflicts, social and economic imbalances, and undermine public trust with the lack of transparency and accountability.

To avoid these negative consequences, it is essential to strike a balance between streamlining mining regulations for efficiency and ensuring that there are robust environmental, social and legal safeguards in place. Proper consultation with local communities, adherence to international best practices and strict enforcement of responsible mining standards are crucial for achieving sustainable and responsible mining practices. This is not the case with any of these amendments.

Consequently, ORA rejects this proposal to streamline the Regulation.

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

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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Hydroelectric is not a Pathway to Decarbonization or Net Zero

Dear Ministers Guilbeault, Wilkinson and Champagne,

ORA understands the urgency in fulfilling the vitally important commitment the government has made to cut GHG emissions to 40-45% below 2005 levels by 2030; however, we will present evidence from independent third-party peer-reviewed studies indicating that an effective path to decarbonization is not through hydropower.

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Ministers Guilbeault and Duclos: Expand the single-use plastic ban – Joint

We, the undersigned organizations and individuals, are deeply concerned about the plastic waste and pollution crisis and its devastating impacts worldwide. As responsible ministers for the Canadian Environmental Protection Act – “an Act respecting pollution prevention and the protection of the environment and human health”, we urge you to take bolder and urgent action to tackle the crisis by expanding the single-use plastics ban to include a more comprehensive list of problematic plastics and substances.

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Hydropower is destroying our rivers, biodiversity and fueling Climate Change

Dams and hydropower facilities harm the environment and, when headponds or reservoirs are flooded, can produce carbon dioxide and methane for the life of the dam. Ontario is about to embark on a whole new era of dam building. Ontario has 224 operating hydropower plants and only 3 with fish passage.
By the way, Ontario Power Generation has been selling Clean Energy Credits for hydroelectric since 2013.   
NO MORE NEW HYDROELECTRIC DAMS IN ONTARIO!! 


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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Agnico Eagle Upper Beaver Gold Project – Tailored Impact Statement Guidelines & Public Participation Plan

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”.[1]  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”. [1] 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.

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