The ORA offers strong support for polluters being held accountable; however, that isn’t what’s happening here. Rather than strengthening enforcement tools that hold polluters accountable, this government is systematically and persistently dismantling, weakening or bypassing all environmental policy and legislation that was designed to protect the environment and deter those industries, corporations or individuals who would pollute and/or destroy the environment.
These ERO postings consistently mislead the public, especially in the top several paragraphs and titles, which contain misleading introductions to the proposed policy the government is proposing. In fact, you can always count on these “modernization” policy changes to be a further attack on environmental policy and legislation. It is even more despicable that these attacks have largely been carried out during the government’s declared COVID Emergency, where no public consultation is required, and what consultation that does take place is meaningless when the main objective is to cut red tape and remove any roadblocks to development and pollution, in spite of the public’s strong recommendations to protect the environment.
ORA supports objectives that involve clean, healthy, safe and sustainable freshwater management. Our lakes and rivers flow across many borders, including municipal, regional, provincial and country-wide borders. Therefore, it is necessary to consider a Canada Water Agency that uses an integrated watershed and basin approach in its core mission and mandate, acting as an oversight agency.
Our concerns are well documented in the attached Briefing Notes report, which has been prepared by our Coalition in the process of requesting a federal review under the Impact Assessment Act.
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.
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
In May of 2013 the Ontario Rivers Alliance made a Part II Order request on the proposed Trout Lake River Hydroelectric Generating Station, at Big Falls, in the Red Lake area. This proposal seemed to die a natural death with no decision on our Part II request, or activity/movement forward on the project. Here we are now more than 7 years later, and last week we received the correspondence below from the MECP stating that
“As part of our government’s efforts to boost Ontario’s economic recovery after COVID- 19, we have passed the COVID-19 Economic Recovery Act, 2020, including amendments to the Environmental Assessment Act.
The changes to the Environmental Assessment Act will allow us to build a strong environmental assessment program that effectively considers the input of local communities and focuses on projects that have the highest impact to the environment. The Act will continue to consider “the protection, conservation and wise management in Ontario of the environment”. A key change made to the Environmental Assessment Act was to limit Part II Order requests to potential adverse impacts of projects to constitutionally protected Aboriginal or treaty rights. All Part II Order requests that were under review which do not pertain to potential adverse impacts on constitutionally protected Aboriginal or treaty rights have been terminated by the amendments.”
The COVID-19 Economic Recovery Act was passed earlier this year, and this legislative amendment is retroactive in its backwards reach to 2013. In spite of the government’s misleading claim that the changes to the EAA “will allow us to build a strong environmental assessment program”, it couldn’t be further from the truth. In fact, there is now no mechanism to request a more rigorous environmental assessment, and public consultation and consideration on these risky projects, as well as the ability to make a Part II Order request, is no longer a possibility. There was also no public or Indigenous consultation before the passing of the Economic Recovery Act.
Since early in 2016, the Ontario Rivers Alliance, Thames River Anglers Association and several other partners have advocated for the removal of the Springbank Dam on the Thames River. We are happy to report that the City of London is moving forward with its decommissioning.
A Consulting Engineer will be chosen to complete the detailed design for its decommissioning as per the recommendations outlined in the completed One River Environmental Assessment, with an aim for construction in 2021. We are looking forward to the project moving forward in 2021!
We will keep you informed as the project progresses.
The City of Cambridge is moving forward on a detailed design plan of the new rebuild of Riverside Dam on the Speed River. Construction is planned for 2022 and work set for completion in 2023. Meanwhile, the full price tag won’t be known until the dam’s design plan has been finalized. This dam has been determined to be at “high risk” of failing within the next 2 to 10 years.
ORA worked extensively towards the decommissioning of this dam. Removing the dam would have been much cheaper, safer and healthier for the riverine ecosystem.
Riverside Dam construction delayed to 2022 with higher price tag, CBC News, 8 Sept 2020
Cambridge Council gives go-ahead to plan for Riverside repairs, CTV News, 8 Sept 2020
The motion, presented on Monday night, suggested by the committee calls for North Huron Council to approve an engineering study to determine the future of the dam and set out a schedule for fundraising for the rehabilitation of the structure. If that schedule cannot be met, however, the recommendation calls for the removal of the structure.
Howson Dam spillway to be tested, 23 Nov 2020
North Huron Council approves engineering study on Howson Dam, 9 July 2020
‘It’s going to be black or white’: North Huron council approves funding Howson Dam committee to speak to engineers, experts, 9 July 2020