Thank you for taking the first step toward protecting Ontario’s groundwater, and for putting the needs of communities before the profits of water bottlers. We support the proposed two year moratorium on the issuance of new or increasing permits to take water for water bottling, and are encouraged by the proposal’s stated purpose:
This would allow time for the Ministry [of Environment and Climate Change] to undertake a comprehensive look at our current understanding of Ontario’s groundwater resources and the rules that govern water bottling facilities that take groundwater.
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Lakes and Rivers Improvement Act – MNR Technical Bulletins – EBR 012-0562 – ORA Submission
Wabagishik Rapids, Vermilion River
Excerpt: “Our intention in commenting on these bulletins is to help ensure that waterpower projects developed under the LRIA are not approved until the effects on the environment and aquatic ecosystems are fully identified, understood, and effectively mitigated. It is also vital that the public has a mandated role and a voice in these processes.
It is also disturbing that the MNR is considering all responsibility for fish habitat and fish passage as out of scope, and is divesting its interests by way of these bulletins, with no clear MNR role mentioned, to the Department of Oceans and Fisheries (DFO). This is at a time when the federal government has just announced the signing of a memorandum of understanding between the DFO and the National Energy Board (NEB) to relinquish much of its oversight of fish habitat along pipeline corridors. This news was quietly released just before Christmas, and only highlights the need for the Ontario government to look after its own interests and not rely on federal protection for any of our crown resources. Unfortunately many elements of these bulletins do the very opposite. It is even more disturbing that this deferral was carried out despite the Fish Habitat Compliance and Referral Protocols for Ontario which was approved by government and identifies and enables roles for MNR in the matters of fish habitat and fish passage.
The exercise of reviewing these technical bulletins has been very disturbing to say the least. It is as though the bulletins were written by the waterpower industry instead of MNR. This series of bulletins reflect an abdication of the MNRs responsibilities under the Lakes and Rivers Improvement Act (LRIA).
It is ORA’s view that this government must continue to play a strong role in ensuring effective mitigation of the impacts of development to meet their strategic directions for sustainable development; and certainly that will be what Ontario taxpayers expect. It is vital that these bulletins reflect a commitment for inter-governmental cooperation, in a holistic and collaborative way, to ensure there are no gaps in fulfilling all responsibilities and commitments legislated under LRIA.”
American Eel Recovery Strategy – EBR Posting 012-0405 – ORA Submission
American Eel
Excerpt:
“American Eels were once abundant in the upper St. Lawrence River, Ottawa River, Lake Ontario, and their tributaries, and in fact were so plentiful that they were an invaluable source of sustenance to First Nation communities and early European settlers, and more recently supported thriving commercial and sports fisheries. This all changed with the advent of a multitude of hydroelectric dams constructed within the historic range of the species.
Key to the American Eel’s survival and recovery is its ability to migrate to its spawning area in the Sargasso Sea, near Bermuda. This is a perilous journey that only a very small percentage ever complete due to the cumulative effects of the numerous hydroelectric facilities that have killed, maimed, and cut off migration to their spawning area. Consequently their once thriving populations have been reduced to a mere one percent of their original numbers.” Continue reading
Review of Ontario’s Long Term Energy Plan – EBR# 011-9490 – ORA Submission
16 September 2013
Conservation First – A Renewed Vision for Conservation in Ontario – EBR# 011-9614 – ORA Submission
16 September 2013
Review of Long Term Energy Plan – EBR # 011-9490 – Rob MacGregor
16 September 2013
Dear Ms. Green
I tried to submit my brief comments online but only found a save button so I am uncertain if my comments were received. So I am providing comments again directly via email.
My major comment is that any public consultation regarding choices in long-term energy plans is incomplete without including the environmental risks associated with each choice. For instance, significant collateral ecological damage often comes with waterpower and asking the public to consider choices and comment on them with out a clear articulation of environmental risks associated with each sector is not only incomplete, it can be viewed as deceptive if later the government indicates it consulted with the public over the LTEP. I know the argument will be that there are other environmental processes that look after this aspect and that this consideration is out of scope. This siloed approach is rampant in government and extremely flawed. For instance, there have been many instances of serious collateral ecological damage in the past with waterpower projects, despite the existence of environmental regulations and processes, some could have been easily mitigated, mitigation of others would have been more difficult. Consulting with the public over energy plans for the province without a full discussion/disclosure of the environmental risks is a serious oversight, particularly in view of the fact that the environmental review process for energy projects is not working and needs to be reviewed and amended accordingly. Added to this is the simple fact that once a site is release for consideration for energy projects, a train starts rolling that is difficult if not impossible to stop. Indeed. finding ways to approve such projects can become the unwritten rule. A better approach would be for the province to first to develop a strategy that evaluates where such projects make ecological sense, and where they do not before sites are released for further consideration and investment by the various energy sectors. Continue reading
Proposed Great Lakes Protection Act – EBR Registry #011-6461 – ORA Submission
Excerpt: “ORA supports the clarity in Ontario’s Great Lakes Strategy that the goal that appeared in draft form as “protecting water” has been refined to “protecting water for human and ecological health” (p.30). Our concern is that the cumulative impact of various decisions that impact the waters in our rivers and streams (as evidenced by the example of Wabagishik Lake above) must be addressed urgently. The focus on improving wetlands, beaches and coastal areas, without also ensuring the rivers and streams feeding these features are being protected and improved as well, will not enable the vision of the proposed Act to be realized.
ORA recommends that, should Bill 6 be enacted, the Province immediately place a moratorium on all hydroelectric approvals within the Basin, until such time as their well-documented and substantial impacts on the health of the Great Lakes can be effectively assessed and addressed. The 40 year FIT contracts awarded to hydroelectric projects would ensure a long and lasting impact that could be very costly to stop or reverse once approved.” Continue reading
EBR 011-7696 – Proposed Approaches to the Implementation of the Endangered Species Act – ORA Comments
Excerpt:
“While there are some good recommendations in these proposed amendments to the Endangered Species Act (ESA), many are worded in language that is far too vague and open-ended, and others are simply unacceptable. ORA is very concerned that this will significantly weaken the hard-fought protection already afforded to our species at risk and their habitats, and is inconsistent with the ESA. Further, many of the proposed approaches appear to be in violation of the EBR in that there is no provision for public and First Nation consultation or transparency.
MNR’s Mission and Promise to Ontarians:
MNR’s Statement of Environmental Values (SEV) and strategic direction ensure sustainable development, protect and restore biodiversity, and must be the guiding principles in all decisions with regard to streamlining, modernization and economic development. The values set out in the SEV must be adhered to in the contemplation of any existing or planned activities where endangered species or habitat protection is in question. The SEV clearly states, “The Ministry’s mission is to manage Ontario’s natural resources in an ecologically sustainable way to ensure that they are available for the enjoyment and use of future generations. The Ministry is committed to the conservation of biodiversity and the use of natural resources in a sustainable manner.”
Streamlining and modernization of the Ministry of Natural Resources (MNR) is a good idea, but only if environmental, ecological, and species at risk protection is not threatened or diminished. All the streamlining, modernization and framework EBR postings preceding this one promised to uphold environmental and ecological values; however, this posting demonstrates that this promise is not being kept. This proposal clearly reflects a development at all costs approach taken by this administration.” Continue reading