If the SEV is not being taken seriously now, why would we believe it will be taken seriously when this new SEV is adopted? The MECP should respect and fulfill its SEV in all areas of its purpose, which is its promise to Ontario taxpayers. Rather than focusing so heavily on the economy the MECP must apply its SEV in the protection and conservation of the environment.
We, the 70 undersigned organizations, are deeply concerned about both the “sharp increase” in the use of Minister’s Zoning Orders (MZOs) over the past year and the enhanced powers granted to the Minister of Municipal Affairs and Housing through amendments to the Planning Act, without public consultation, through Schedule 17 of Bill 197.
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.
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.
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.
This ERO proposal describes the GRSs as providing “stringent protections for species at risk and their habitats under the Endangered Species Act”, but how stringent are these protections when the legislation can be so easily set aside? This means that protection and recovery under the ESA is uncertain for all species at risk.
The wording in this Environmental Registry posting is very misleading when it claims that “Ontario is committed to providing strong protections for species at risk and improving outcomes by modernizing and improving the effectiveness of the Endangered Species Act, as committed to in our Made-in-Ontario Environment Plan”. This proposal is not improving the effectiveness of the Endangered Species Act (ESA), it is even doubtful it will increase the profits of private corporations. It will however be to the detriment of species at risk.
Please note that the Ontario government decision is to continue with the forestry industry exemption of the Endangered Species Act when logging in Crown forests: “A decision for this proposal has been published as a Bulletin under ERO 019-1995 on June 29, 2020.”
“Ontario has extended the temporary approach for forest operations conducted in Crown forests under the Endangered Species Act for an additional year. This will help avoid additional regulatory burden and economic strain on the forestry sector while a long-term approach is being considered.”
ORA is very concerned about the extreme deregulation that occurred with the recent waterpower exemption to the Permit to Take Water, and in this new Mercury Regulation where new and significantly redeveloped electricity producing dams have not been addressed. These important legislative requirements were designed to ensure hydroelectric facilities are held accountable for environmental and socio-economic impacts and risks to communities and riverine ecosystems.
In effect, this overbroad exemption means that for the duration of the regulation residents of Ontario, including Indigenous community members, will not have knowledge of, nor a means to participate in, provincial decisions which may have significant effects on the environment.
ORA also objects to Ontario ratepayers and/or taxpayers having to subsidize electricity pricing and capital expenditures for industry and private corporations. This Strategy focuses only on the economic benefits of doubling the harvest, without looking at the trade-offs or balancing that with equal measures to maintain a healthy environment. This is the only way to maintain the claim of sustainable forest management in Ontario.