The ORA favours conservation of Ontario’s natural resources, and most especially as it relates to fish and their habitat. ORA agrees that the Ministry should apply existing federal government guidance for fines and increase the use of contravention tickets for more types of offences. It makes sense to issue tickets rather than using the federal court process.
Overall, the material presented makes clear that the Fund mechanism will make it easier for habitat destruction to occur at the hands of industry and developers. Indeed, according to the proposal the main purpose of the Fund is to give operators a quicker and less cumbersome alternative to completing actions to provide an overall benefit for the species negatively impacted by their activities. The Fund is a part of a package of damaging amendments to the Endangered Species Act, 2007 (ESA), passed in June 2019 that, taken together, represent a gross weakening of the ability of the Act to fulfill its purpose to recover Ontario’s at-risk species. Our primary concerns with the Fund are outlined below.
Bill 229 is just the most recent in a long list of omnibus bills containing devastating amendments, exemptions and streamlining of key environmental policy and legislation designed to protect our environment and communities and provide the public and stakeholders with meaningful input. These government actions have created a deep erosion of public trust and confidence. It is unacceptable that it would mislead its citizens and bypass the norms by taking advantage of a world-wide health emergency to aggressively push their destructive agenda through.
ORA submits that the MECP’s priority must be the pursuit of its Statement of Environmental Values (SEV), and its vision and mandate of “an Ontario with clean and safe air, land and water that contributes to healthy communities, ecological protection, and environmentally sustainable development for present and future generations”[i]. There is nothing in the MECP’s SEV that promises to “remove the regulatory burden” from industry or “provide some cost savings for dam owners and operators”. It is not the MECP’s duty to save dam owners and operators money or ease their regulatory burden. Its duty is to fulfill its Mandate to protect the environment and to follow its promise of environmentally sustainable development for our present and future generations. Certainly, MECP’s priority should not be to cut regulatory burden at the expense of our air, land and water. It is a tragedy that today’s cost savings for dam owners and operators will be borne on the backs of our children and grandchildren.
Wetlands are among the most productive and diverse habitats on Earth. They provide incalculable benefits for communities, including flood mitigation, water filtration, carbon sequestration, wildlife habitat, wild foods and medicines, recreational opportunities and more. They are also of immense economic value. For example, wetlands can reduce the financial costs of floods by up to 38 percent; in the Great Lakes region the benefits provided by wetlands are worth 13 to 35 times more than the cost of protecting or restoring them; and in southern Ontario alone wetlands provide over $14 billion dollars in benefits every year.
While the effects of large hydro projects (200 MW) have been well known and documented for over a century, small (up to 10 MW) and medium sized (10 MW to 200 MW) hydroelectric projects involve many of the same impacts per unit of power generated and, cumulatively, the environmental degradation can exceed that of large hydro projects. Small and medium sized hydro projects are situated on smaller and often more sensitive riverine ecosystems; however, like large hydro projects, will also alter the river’s flow regime and can have significant impacts on the aquatic environment, as flow is a major determinant of a river’s ecological characteristics and its aquatic biodiversity.
A recent study examined scaled hydropower impacts in the Nu River basin of southwestern China, where the researchers calculated impact per MW of capacity across 14 metrics between small and large hydropower projects (with small being below 50 MW as defined in Chinese policy). They found that small hydropower dams had greater impact per MW for 9 of the 14 metrics, including length of river channel affected and impact on habitat designated as conservation priorities.
Brook trout spawning in a coldwater stream. Film by Steve Noakes
Groups concerned about Erin’s proposed plant effect on coldwater fish, by Keegan Kozolanka
Ontario Rivers Alliance says town has ‘dismissed’ plans to protect Credit River brook trout from Erin wastewater plant, by Alexandra Heck
The Town of Erin (Erin) is in the design phase of a new sewage treatment plant, and the Ontario Rivers Alliance (ORA) is concerned that the sewage plant effluent will endanger some of the most productive and highly valued brook trout populations in the West Credit River. Continue reading
Ontarians may have invented the Blue Box, but our current linear, make-use-dispose economy makes it impossible for recycling alone to solve our growing waste problem. Currently, less than seven per cent of Ontario’s waste is recycled through the Blue Box, and 1 the province sends over 8 million tonnes (70 per cent)2 of trash to landfills and incinerators every year.
Instead of exemptions or a more streamlined Class EAW, the OWA should be proposing amendments to provide for a much more rigorous and accountable process that ensures fish friendly turbines, effective and safe fish passage, a more rigorous cumulative effects assessment, and a more comprehensive and meaningful consultation process. We should be making our rivers more resilient in the face of climate change – not exempting waterpower projects from the Class EAW. Instead, the OWA and the Ontario government are placing our environment and communities at risk.
The ORA strongly objects to any approach that eliminates the opportunity for public and Indigenous consultation and input regarding any sewage and stormwater infrastructure projects, especially any expansions or upgrades when they could have a negative environmental impact on the riverine environment and communities.