The ORA is concerned that Bill 23 will have far-reaching negative effects on the environment and communities. This major streamlining of development is irresponsible and a recipe for disaster. Bill 23 works against sustainability and the watershed approach at a time when Government decision-making should be focused on protecting the environment and building climate resilience into Ontario’s communities and infrastructure.
First, it was enlightening to be provided with a clear definition of small and large hydro facilities in the Hydroelectric Program Development and Assessment webinar, as well as a total amount of power generated by these categories. You informed that the definition of small hydro would have a scope of installed capacity of 10 MW and under, with 30 companies representing 50 facilities generating a total of 120 to 150 MW, and large hydro having a scope of installed capacity of over 10 MW, with 3 companies representing 22 facilities producing a total of 1,000 MW.
The increased number of small hydro facilities making such a small contribution to our electricity grid impacts on multiple Ontario riverine ecosystems, whereas the 22 facilities producing 1,000 MW of power on presumably fewer rivers has a much lower trade-off value. Additionally, larger rivers have a greater capacity to buffer some of the worse effects of hydroelectric.
The Agency has deemed the Project to be within federal jurisdiction and required it to undergo a federal Impact Assessment, and yet Agnico Eagle (AE) is planning to move forward with their advanced exploration as soon as weather permits. ORA objects to the Project moving forward with any advanced exploration activities that would result in any damage to the environment.
AE boasts about setting the “gold standard”, “for over 60 years Agnico Eagle has been attracting investment to Canada, from those who seek a mining company committed to make mining work better for communities, shareholders and the planet”. ORA submits that Stakeholders expect AE to set the “gold standard” on this Project by undertaking the most environmentally and socially rigorous, advanced and responsible project “for communities, shareholders and the planet”.  Agnico Eagle Twitter Posting, 22 November 2021
ORA comments requesting a federal review under the Impact Assessment Act, 2 October 2021.
Upper Beaver Gold Project – IAAC Portal.
Canada has committed to ending plastic waste by 2030.i Reaching this goal will require ambitious actions that address the full life cycle of plastic.
Canada is a major—and growing—producer of plastics and the world’s second highest user of plastic on a per person basis.ii Production, use and disposal of plastics is an increasing contributor to climate change and habitat degradation. It also imposes disproportionate harm on those living next to production and disposal facilities, often low-income and Black, Indigenous and People of Colour communities.
We, the undersigned, therefore call on the Government of Canada to commit immediately to implement the following actions on an urgent basis:
Is it really renewable energy when it degrades the environment and impacts on communities in a negative way?
There are 241 hydroelectric dams in Ontario, and only 3 facilities have provided any form of fish passage.
The effects of dams and waterpower facilities on 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.
The ORA strongly urges the Impact Assessment Agency of Canada (IAAC) to determine that a federal Impact Assessment is required to ensure that the ecological, social, and cultural effects of this proposed Project are rigorously assessed and mitigated. A federal IA would ensure that the potential ongoing cumulative effects of this Project on the environment, Indigenous communities and the public are fully addressed to ensure a more environmentally and socially sustainable outcome.
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.
In consideration of the ecosystem benefits of a healthy West Credit River and its sensitive Brook Trout and Redside Dace population, we are recommending that inground infiltration of the final wastewater effluent be seriously considered, as a viable alternative to discharging warm sewage effluent directly into the West Credit River. Discharge of treated effluent by way of passive infiltration into the ground with slow percolation into this relatively small stream is the best way to ensure that the final effluent reaches the stream as natural and cold groundwater.
Judy Mabee, Chair of the Coalition and President of the Belfountain Community Organization stated that, “The Coalition is not deterred by the Minister’s Decision. We will continue on with our work to protect this highly valued coldwater Brook Trout population in the West Credit River. We are more than willing to work with the Department of Fisheries and Oceans and other federal and provincial regulators, including the Town of Erin and its consultants, to advocate for a wastewater plant that sets a new best in class industry standard for the protection of sensitive coldwater receiving streams.”
The purpose of Aaron Detlor’s communication was to “advise that the Haudenosaunee hold treaty rights over the area contemplated by this Project, and that the Project will interfere with those rights and interests… At the same time we are hereby asking Minister Wilkinson and the Crown generally to withhold any pending approvals subject to the commencement of a good faith process to uphold the honour of the Crown”.