The ORA is offering feedback on the 13 December 2023 Independent Electricity System Operator (IESO) webinar. ORA strongly objects to new hydroelectric being included as a “non-emitting” resource, eligible for the Long Term 2 (LT2) Request For Proposals (RFP). Participants were informed of an overall need for 5 TWH of energy emerging at the end of the decade and growing through the 2030s. The LT2 RFP has an anticipated installed capacity target of around 2,000 MW of non-emitting energy resources to be procured and operational by 2030. ORA questions the IESO’s rationale for applying the non-emitting label to hydroelectric when there are numerous independent third-party peer-reviewed studies, as well as the Intergovernmental Panel on Climate Change (IPCC) reporting guidelines. This immense volume of studies indicate that hydropower reservoirs generate significant and ongoing greenhouse gas (GHG) emissions, especially methane, for the full life cycle of the dam. It is misleading the public to claim that hydroelectric is “non-emitting” in the LT2 RFP or in any other public arenas and could be considered fraudulent.
Canadian Environmental Law Association (CELA) has prepared the following analysis and recommendations in response to the four above-noted Environmental Registry of Ontario (ERO) notices, which propose dramatic changes to Ontario’s permit-by-rule framework. The undersigned environmental, conservation, and civil society organizations have endorsed CELA’s submission. Collectively, it is strongly recommended that the Ministry of Environment, Conservation and Parks not move ahead with the four proposals…
We are willing to meet and discuss CELA’s submission at your convenience.
The Ontario government’s own 2020 report, “Protecting People and Property: Ontario’s Flooding Strategy,” which resulted from the 2019 flooding disaster, states very clearly that “Flood risk management is achieved through multiple provincial acts, regulations, policies and technical guides and a wide range of provincial programs and services. Successful implementation relies on partnerships between provincial ministries, municipalities, Indigenous communities, conservation authorities, stakeholder organizations and the federal government.” 1
Instead, this proposal seeks to do the very opposite. It proposes to exempt the CAs from their authority under ten crucial Acts and their associated regulations; it blocks the CA partnership with municipalities and stakeholders and takes the authority of CAs away from permitting so they cannot properly fulfill the recommendations of this report that was commissioned by the Ontario government only a few short years ago. Now, where is the wisdom in that?
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.
The ORA is in full agreement that Low Impact Development (LID) must be a priority in development planning guidance for stormwater management practices and should include innovative green infrastructure such as rain harvesting, rain gardens, green roofs, urban trees and forests, permeable surfaces, ditches, swales, stormwater catchments, and must emphasize the protection of wetlands.
The province should not be streamlining reporting requirements. Wastewater and stormwater management are vitally important to the health and resilience of our freshwater resources and to the people of Ontario. There are numerous complex and site specific considerations for each and every outfall of sewage effluent that is unique to the area and the water body. We cannot continue to release partially treated or untreated sewage into our lakes and rivers. We must stop thinking about how we can make it easier and start thinking about how we can make wastewater treatment more efficient and effective so we can build resilience into our lakes and rivers to help prepare for a warming climate.