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.
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
Ontarians may have invented the Blue Box, but our current linear, make-use-dispose economy makes it impossible for recycling alone to solve our growing waste problem. Currently, less than seven per cent of Ontario’s waste is recycled through the Blue Box, and 1 the province sends over 8 million tonnes (70 per cent)2 of trash to landfills and incinerators every year.
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.
Finally, the West Credit River is a headwaters tributary of the Credit River and is considered the crown jewel of coldwater brook trout fisheries in Ontario. This fishery significantly adds to the economic and social fabric of the province, with Ontario fisheries contributing a total of approximately $2.5 billion annually to the provincial economy. MNRF’s own documents predict that climate change will reduce the number of watersheds in Ontario with brook trout by 50% by 2050.
Removing the regulatory baseline for 113 of Ontario’s most heavily polluting facilities in nine environmentally damaging sectors is the wrong approach if the Government of Ontario’s goal is to hold polluters accountable, as it has stated on several occasions. In order to achieve that goal, the MISA regulations should be updated and expanded to new facilities operating in Ontario across the nine industrial sectors.
While abandoning the historically thoughtful context of a normal PPS review is ill-advised at any time, it is irresponsible to tilt the PPS toward an excessive empowerment of development-as-usual at a time of a changing climate, threats to biodiversity, regional ecological integrity, and the gathering momentum of the sixth mass extinction.
ORA submits that Schedule 5 of Bill 66 is a regressive, unwarranted and potentially risky proposal that is inconsistent with the public interest and does not adequately safeguard the health and safety of Ontarians. Does the MECP really want to set the stage for another Grassy Narrows mercury disaster? Instead, the MECP should be focusing on improving the TRA and its regulations to better protect communities.