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Modernization of Approvals – EBR Posting 011-6751 – ORA Comments


“ORA agrees that efficiencies of permitting and approvals, and streamlining of process, can be made in a way that benefits both the client, stakeholders and Ministry of Natural Resources (MNR), without compromising public health and safety, or the sustainability and health of the environment and natural resources.   ORA wishes to make the following recommendations with regard to modernization of approvals:

1.    Full Cost Recovery – Fee for Service

Fee for service is an essential component for cost recovery, and for maintaining the highly important scientific/research/fisheries aspect of MNR.  ORA agree that the full range of costs and benefits to natural resources and to Ontarians must be considered in determining feasibility and appropriate fees, and to ensure the wise use and protection of Ontario’s natural resources.

All costs related to a service should be charged back to the applicant/proponent, including the time consuming work of facilitating and advising on all aspects of applications, permitting, environmental assessments, compliance and enforcement.

To take it even one step further, ORA feels very strongly that all associated studies should not be undertaken or arranged by the proponent, but be performed or commissioned by MNR Science and Research staff, and all costs be charged back to the proponent.  This would ensure studies are conducted with the highest of integrity, results are reliable, and best practices are adhered to.”

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