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 Environmental Bill of Rights, Environmental Compliance Approval, Joint, Land Use, Mining, Ontario Water Resources Act, Policy & Process, Provincial Policy Statement, Quarries, Regulatory, River Concerns, Rivers at Risk, Sewage, Species at Risk, Stormwater, Urban Development, Waste Water Treatment Facilities, Water Quality, Watershed Planning

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

By Linda Heron on Thursday, November 24th, 2022

Posted in Bill 23, Conservation Authorities Act, Endangered Species Act, Environmental Registry, Industry, Municipal, MZOs, Ontario Water Resources Act, ORA Submissions, Planning Act, Provincial Policy Statement, Regulatory Submissions, River Concerns, Rivers at Risk, Species at Risk, Urban Development, Water Quality, Watershed Planning

“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

By Linda Heron on Thursday, November 17th, 2022

Posted in Bill 23, Bills, Conservation Authorities Act, Environmental Registry, Municipal, MZOs, Ontario Water Resources Act, ORA Submissions, Planning Act, Pollution, Provincial Policy Statement, Regulatory, River Concerns, Rivers at Risk, Species at Risk, Water Quality, Watershed Planning

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

By Linda Heron on Wednesday, April 27th, 2022

Posted in Climate Change, Environmental Protection Act, Environmental Registry, Ontario Water Resources Act, ORA Submissions, Planning Act, River Concerns, Rivers at Risk, Sewage, Stormwater, Urban Development, Waste Water Treatment Facilities, Water Quality, Watershed Planning

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-019-4967 – Municipal Wastewater and Stormwater Management in Ontario – Discussion Paper

By Linda Heron on Monday, March 28th, 2022

Posted in Environmental Registry, ORA Submissions, River Concerns, Rivers at Risk, Sewage, Stormwater, Waste Water Treatment Facilities, Watershed Planning

The province should not be streamlining reporting requirements. Wastewater and stormwater management are vitally important to the health and resilience of our freshwater resources and to the people of Ontario. There are numerous complex and site specific considerations for each and every outfall of sewage effluent that is unique to the area and the water body. We cannot continue to release partially treated or untreated sewage into our lakes and rivers. We must stop thinking about how we can make it easier and start thinking about how we can make wastewater treatment more efficient and effective so we can build resilience into our lakes and rivers to help prepare for a warming climate.

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