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I suggest a additional item be added to the enforcement toolbox.

Under EPA Section 191 and POA 96(2) the MECP has the authority to suspend ECAs, without consultation or input for Permissions Branch, until fines are paid. the defendant is provide with a notice and 30 days to pay the fines that are in default. Upon failure to pay an application is brought before a Justice of Peace under POA 69(2) for an Order to be issued.

MECP should be doing this and I can't understand why, as far as I know, it has only been done once. In that case the licences were suspended, the fines were then paid and licences were re-instated. The authority to do it exists -

Suspension of default in payment of fine
191 (1) Where a person is in default of payment of a fine imposed upon conviction for an offence against this Act, the Nutrient Management Act, 2002, the Ontario Water Resources Act, the Pesticides Act, the Safe Drinking Water Act, 2002, the Toxics Reduction Act, 2009 or the regulations made under any of them, on the application of the Director, an order may be made under subsection 69 (2) of the Provincial Offences Act directing that, until the fine is paid,
(a) one or more of the person’s licences be suspended;
(b) no licence be issued to the person, or
(c) the person’s registration under Part II.2 be suspended. 2010, c. 16, Sched. 7, s. 2 (86).
Duty of Director
(2) The Director shall,
(a) on being informed of an outstanding order referred to in subsection (1), suspend the person’s licence or registration, if it is not already suspended under another order referred to in subsection (1); and
(b) on being informed that the fine and any applicable administrative fee for the reinstatement of the licence or registration are paid, reinstate the licence or registration, unless the Director has been informed that,
(i) there is another outstanding order referred to in subsection (1) directing that the licence or registration be suspended, or
(ii) the licence or registration is suspended under any other order or under another statute. 2010, c. 16, Sched. 7, s. 2 (87).

Also MECP has SOP called Licence Suspension when Fines in Default.
I can make this SOP available upon request to the MECP person reviewing the comments.