Our organizations recommend choosing Alternative 3 – the Full Removal of Springbank Dam and the naturalization of this section of the Thames River. We submit that full dam removal and naturalization are the preferred solutions from an environmental perspective and would likely prove to be the most cost-effective over the long-term when Life-cycle costs and available provincial and federal funding are considered.
The full Capital and Life Cycle Costs of Rebuilding Riverside Dam were not realistically represented in the ESR and could well end up costing the taxpayers more than double what was presented to the public and City Council. A Rebuilt dam would be considered a new dam, not a repair or expansion of an existing weir, with an assessed High Hazard Potential, and is located within the City of Cambridge in a location that could place multiple residences and businesses at risk in the event of severe flooding or a dam breach. ORA and Partners submit that this Project goes far beyond the screening process provided by a Schedule B, Class EA. Consequently, we submit that this is a major project that should fall into a higher level of assessment.
The presence and impacts of PAHs in the Great Lakes has been noted in the Canada-ˇOntario Agreement for over three decades. The Ontario provincial government and the Canadian federal government conducted a report, The Status of Tier 1 and Tier 2 chemicals in the Great Lakes basin under the Canada -ˇOntario Agreement, which noted that, “in some cases, the levels of PAHS in open surface water are still above the Canadian Council of Ministers of the Environment (CCME) Canadian Water Quality Guidelines. These exceedances are associated with known industrial sources.”
ORA understands the pressure municipalities are under when communities rally to maintain or rebuild their beloved mill ponds. However, it is up to all authorities and municipalities to take a leadership role that places public safety and landscape scale ecological integrity above local individual or group interests.
OTTAWA, Mar. 19, 2018 – Increased federal action to protect and recover American Eel is urgently needed, say the Canadian Wildlife Federation (CWF) and nine other partners in conservation including the Algonquin to Adirondacks Collaborative, the Lanark County Stewardship Council, Nature Québec, Ontario Nature, and the Ontario Rivers Alliance.
Unfortunately, water protection is not equal across the province; therefore, ORA submits that this proposal, and other provincial initiatives, must go much further to protect freshwater resources throughout all of Ontario. This is especially important in areas of intense mining or industrial development.
In the interests of public transparency and community right-to-know, we urge ECCC to continue to pursue this matter with its stakeholders by sending out for public comment the ENGO proposal to add radionuclides (2013), the ECCC and CNSC Joint Response (2017), and the ENGO response (2018), rather than recommending an outright rejection to add radionuclides to the NPRI without having consulted with the broad community.