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.
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.
As we all work to emerge from this unprecedented disruption, our 235 organizations and millions of supporters want to emphasize that investments in nature and biodiversity on our lands and in our ocean can create jobs and be an essential part of an economic recovery and a sustainable future. Canada is in a particularly strong position to lead global efforts in this regard. We support your commitments to increase protection of lands, freshwater, and ocean, embrace nature-based climate solutions, and urge you to invest in achieving these outcomes.
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.
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.
With the warming temperatures and extreme rain and drought events that climate change is predicted to bring with increasing frequency and intensity as time passes, decision makers and legislators bear a responsibility to strengthen freshwater protection and resiliency – not weaken it. If this proposal moves forward it will be a precipitous turning point for our future with freshwater in Ontario and beyond.
You will find ORA’s submissions regarding Bill 132 here.
Check out ORA’s speech to the Standing Committee on General Government: Continue reading
With climate change impacts bearing down on us, decision makers have a responsibility to ensure the resiliency of our freshwater resources. If this proposal moves forward it will be a precipitous turning point for our future with freshwater in Ontario and beyond.
These ARA amendments are likely to intensify rather than reduce divisive land use conflicts involving new or expanded aggregate operations.
As a basic, the province must have a comprehensive approach to watershed management through flood mapping, mitigation and hazard planning and protection, including services such as wetland protection, climate change adaptation and resilience, biodiversity health and land use planning. In other words, we must be beefing up our public safety and environmental protection efforts, rather than gutting and streamlining key policy and legislation, as well as funding for our regulators.