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.
No new hydroelectric projects should be included in the short or long-term energy plan. Hydroelectric power generation is dirty energy resulting in significant ongoing negative impacts to riverine ecosystems, including, but not limited to GHG emissions (methane and Co2), degraded water quality, declining fish populations, methyl mercury contamination of fish, and ongoing harm to Indigenous communities.
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.
The Trout Lake River has since time before memory been out travel route to and from Lac Seul and other places south. That river system is still a travel route. The river is full of wild rice fields, medicines, and other relations who thrive in the interdependence of this water system. The Trout Lake River meets with the Chukuni River and both then flow into the English River. Downstream of the English River are two communities, Grassy Narrows First Nation and Wabaseemoong First Nation. These two communities have already been devastated by the presence of methyl-mercury in the water and in their local food sources. I am sure that you are aware of their ongoing efforts to have the river cleaned up and for their people to be given proper medical care for having been poisoned by this polluted river.
You will find all the submissions made by ORA and our members here.
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.
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.
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.
Ontario has hundreds, if not thousands of dams that are unsafe and no longer serving any useful purpose. These dams are blocking fish passage, degrading water quality, fragmenting habitat, threatening species at risk and sensitive cold water species. ORA is working to take them out. Check out this excellent overview of the problems with hydropower:
The effects of dams and hydroelectric facilities on fish populations and fisheries have been well documented over the past century and include the loss or serious decline of many iconic fish species, which are resources of importance to Ontario’s economy, biodiversity, and natural and cultural heritage.
Since 1963 the Little Long Generating Complex on the Lower Mattagami River in Northern Ontario has been the source of an environmental crisis of immeasurable proportions. Thousands of Lake Sturgeon have been entrained through spillway gates and left stranded waiting to be captured and relocated back to their adopted man-made habitat, leaving waters not fit for survival. Adam Creek Spillway is well known province-wide as a thorn in hydro electric energy and should not be defined or qualified as GREEN energy.