Excerpt:
ORA shares many values with the Ontario Ministry of Natural Resources (MNR) as expressed in your Biodiversity Strategy, strategic direction, and Statement of Environmental Values. We support exercises that take a strategic landscape approach with an aim to reduce overlap and eliminate duplication, provided it is done with a precautionary approach, and that the baby is not thrown out with the bathwater.
The provincial government already has an appropriate toolkit of legislation and policy to protect and enhance ecosystems, while at the same time ensuring that development proceeds sustainably. However, there appears to be conflicting priorities between the push for development projects under the Green Energy Act, and the mandate of protecting the environment and natural resources, and nowhere is this more evident than in waterpower development with its numerous and well documented negative effects. For this reason we have tested and reviewed the framework largely by using the development of additional waterpower as our chosen example.
In the course of our review we found that the current framework is flawed by not expressly embedding the overall requirement for projects to be environmentally and ecologically sustainable at both the local and regional scales.