The current government has gutted multiple key pieces of environmental legislation and policy that have taken decades to assemble. We are in a perilous state now where the requirement to consult with the public and Indigenous communities has been minimized, and the red tape cutting has gone to such extremes that public health and safety and the natural environment will be at increased risk as the climate continues to warm.
As you know, the OWES is a science-based ranking system that provides a standardized approach to determining the relative value of wetlands. OWES assessments are necessary to designate Provincially Significant Wetlands (PSWs). This designation in turn results in a high level of protection under provincial law and policy such as the Provincial Policy Statement (sections 2.1.4, 2.1.5 and 2.1.8). Yet the complete overhaul of the OWES, as proposed, will ensure that very few wetlands would be deemed provincially significant in the future and that many if not most existing PSWs could lose that designation. As a result, very few of Ontario’s wetlands would benefit in the future from the protection that PSW designation currently provides. We urge you not to proceed with the proposed changes to the OWES, for the reasons outlined below.
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?
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.
The Ontario Rivers Alliance is strongly supportive of the wires option solutions, rationales and conclusions made in the IESO’s 13 September 2022 presentation.
The total amount of GHGs emissions from a hydroelectric facility is dependent upon many factors, including the impounded reservoir, terrain, amount of organic matter, air-water temperature, reservoir depth and size, vegetation (algae and plant/tree litter), pH values, oxygen levels, flow velocity, water level fluctuations, wind speeds, precipitation, wetlands within the impoundment zone, and facility operating strategy (cycling and peaking to maximize power generation). Every hydroelectric facility is unique in its complexity and must be carefully studied and continually assessed and monitored to determine the total daily, seasonal and annual GHG emissions per MWh emanating from the system.
The Coalition for the West Credit River (Coalition) remains very concerned with the potential environmental impact of the Erin Water Resource Recovery Facility (WRRF) and, in particular, the temperature of its treated effluent harming the sensitive coldwater Brook Trout habitat of the West Credit River.
As your Ministry is aware, the approved sewage treatment plant proposes to discharge large flows of sewage effluent into the relatively small flow of the West Credit River. The lack of significant dilution will greatly magnify the thermal impact of warm effluent on this coldwater stream.
As representatives of more than 90 organizations from across Canada, we are writing to urge you to put nature at the centre of Canada’s forthcoming National Adaptation Strategy.
The impacts of climate change are already being felt across the country, and we must all work together to both reduce greenhouse gas emissions and build resilient communities and ecosystems.
First, the Coalition for the West Credit River (Coalition) would like to express our deepest appreciation that you and your staff worked with our Technical Team over the last several months to incorporate some of our recommendations into the Environmental Compliance Approval (ECA). However, we are concerned that our key recommendations for improvements to the draft ECA, received by you on 2 May, were not reflected in the ECA approved on 3 May 2022.
The Coalition is very appreciative of your strong support in recommending to the Honourable David Piccini, Minister of Environment, Conservation Parks (MECP) and Mayor Allan Alls, Town of Erin, that our draft Monitoring and Adaptive Management Plan be integrated into the Environmental Compliance Approval (ECA). As you are likely aware, the ECA for the Erin Water Resource Recovery Facility was approved on 3 May 2022 by Aziz Ahmed, P.Eng., MECP Manager of Municipal Water & Wastewater Permissions, appointed for the purposes of Part II.1 of the Environmental Protection Act.