Tag Archives: environment

EBR 012-1120 Invasive Species Act – ORA Submission

Eurasian Milfoil

Excerpt:

ORA offers our support on the proposal to enact an Invasive Species Act (Bill 167), and to emphasize the importance of a proactive approach to minimize the possibility of intentional and unintentional introductions of alien and invasive species, and of mitigating the effects of species that have already been introduced.

For the Invasive Species Act to be effective, it is important that this legislation is accompanied by invasive species policies and implementation plans, along with collaboration between the Ontario government, ministries, agencies, municipalities and federal authorities, along with adequate funding, staff and required resources that are dedicated to the successful application of the policies and action plans. It is crucial that invasive species policy be incorporated into all decision-making processes throughout all pertinent government agencies in order to protect the economic, social and ecological integrity within all of Canada. Continue reading


Marter Township Generating Station Environmental Report – Blanche River – Part II Order Request

Krugerdorf Chutes, Blanche River

This proposal has a Feed-in-Tariff (FIT) contract which pays a 50% peaking bonus for all power generated.  FIT Contracts have a 40 year term.   Projects with FIT contracts cannot be told to stop generating if Ontario has a surplus of power – they get paid for all power generated whether it is required or not.  Proposed to produce 2.1 MW Installed Capacity, which with seasonal flows will more realistically produce 50% of that – approximately 1 MW of power.

ORA has made a Part II Order request to the Minister of Environment to elevate this proposal to an Individual Environmental Assessment – a much more rigorous environmental assessment.  Awaiting MOE response.

Published: 14 March 2014

Excerpt:

“It is ORA’s submission that Xeneca’s approach falls far short of their claims in many key aspects of this ER, and does its best to sell the reader on the project, with an approach of convincing the reader to just trust them, let them build it, and then through monitoring and adaptive management during pre and post construction the riverine ecosystem will be just fine. This approach is not acceptable.”  Read more below:

Download (PDF, 593KB)


Proposed Hydroelectric Generating Station at the Bala Falls

Bala Falls Portage

Posted 8 March 2014

There is a lot at stake in a battle that has gone on for close to a decade.  Through a “Competitive Site Release” in 2004 the Ministry of Natural Resources (MNR) made some Crown land available south of the Bala north falls for the development of a hydro-electric generating station (Bala is north-west of Gravenhurst). The MNR is very motivated to see this happen, as not only would it help fulfill the province’s mandate for additional power generation from renewable energy sources, but MNR staff would also no longer need to adjust stop-logs to regulate water flows and levels, or be responsible for the maintenance and repair of the Bala north and south dams – instead, the proponent would have these responsibilities. Unfortunately, the MNR appears to be so motivated that they have shown little concern for the many negative impacts on fish spawning and other habitat problems that would be created.

In 2005 a proponent was awarded “Applicant of Record” status, and since then has proposed at least three different configurations, all of which would also create major public safety and economic problems.

SaveTheBalaFalls.com, the local cottager association, and the public have therefore been actively engaged both in the process and also in ensuring the appropriate government Ministries, agencies, and politicians are presented with the many outstanding concerns and issues.

One major issue is that the Bala Falls landscape is central to Bala and the surrounding area’s recreation and tourism economy as the falls are very visible and accessible, and are the main focus of visits – including literally bus-loads of tourists in the summer. They come to view the falls, to climb on the rocks, and to play in the usually serene water at the base of the falls. There are also residences within 200 feet, as well as long-time and very popular public in-water recreation that occurs within 50 feet, both upstream and downstream of the proposed generating station and the treacherously turbulent water it would create.

Another major issue is that the proposed project would obstruct a traditional and historic Portage, which is still in use. As a result of a request by the MNR, written historical proof was provided to confirm that this Portage was in use prior to the initial Crown land patent, and Section 65(4) of the Public Lands Act prohibits such obstruction. In May 2013 the MNR unilaterally declared that this land was suddenly too dangerous for the public to access – even though their own 2011 Public Safety Measures Plan for this exact area had no such concerns. We have responded with reasons why this proposed project would still be illegal under the Public Lands Act, and await a response on this complicated topic.

Two years ago, the Ministry of the Environment (MOE) told us that in the ten years the current legislation has been in place, there have been more than 50 requests to elevate different proposed hydro-electric generation proposals to an Individual Environmental Assessment. Such further study is the required first step to having any chance of an Environmental Assessment (EA) approval being denied. But the MOE has denied EVERY ONE of these 50 requests. That is, there has never been a “Part II Order” request for elevation approved. This places the fairness and efficacy of the entire EA process in question.

The current situation for the proposed Bala project is that not only are major approvals still required from all four levels of government, but there are legal challenges as well.

And SaveTheBalaFalls.com and the community will continue to ask; would it be safe, would it be beautiful, and would there be enough water over the falls to continue to draw people to Bala. We still don’t have answers, so we continue to ensure decision-makers know the problems.

Click here for more information, including the sign-up for our e-Newsletters.


Energy East Pipeline – Get Informed

Posted 8 March 2014

The Energy East Pipeline Pre-Application was just filed by TransCanada, and public consultation is beginning.

You can register for the OEB Province-Wide Stakeholder Community Discussion Meetings here, and find details of when and where discussion meetings will take place here.

Volume 2 of their Project Description, section 1.11, lists the Ontario rivers that would be impacted, which are listed below for your convenience.

1.11.4 Ontario Water (Volume 2)

In ON, the ON West, Northern Ontario, and the North Bay Shortcut segments cross two primary watersheds (the Nelson River and Great Lakes–St. Lawrence watershed) and 41 named river crossings including:

  • Winnipeg River
  • Wabigoon River
  • Dog River
  • Black Sturgeon River
  • Kenogami River
  • Pagwachuan River
  • Nagagami River
  • Kabinakagami River
  • Opasatika River
  • Kapuskasing River
  • Mattagami River
  • Frederick House River
  • Blanche River
  • Montreal River
  • Madawaska River
  • Mississippi River
  • Rideau River
  • South Nation River

Preliminary List of Watercourse Crossings Requiring a Site Specific Design by Province of Ontario:

  • Hoasic Creek
  • Hoople Creek
  • Raisin River
  • McIntyre Creek
  • Riviere Beaudette
  • Riviere Delisle
  • East Rigaud River
  • Rigaud River

1.11.5 Ontario Wetlands (Volume 2, P1-48)

In Ontario, three wetland areas crossed by the Project have been designated as provincially significant. These include:

  • Delisle River (0.3 ha)
  • Froatburn Swamp (8.3 ha)
  • Glen Becker Swamp (5.6 ha)
  • Hosaic Creek (1.2 ha)
  • Ingleside (4.2 ha)

There will be up to 72 pumping stations which may carry an increased risk of spills.  Locations are yet to be determined through public and First Nation consultations.

 


ORA Actions Have Significant Impact on Protection of Rivers

The-Chute-Second-Falls

Posted 8 March 2014

A number of environmentally harmful hydroelectric projects would likely be under construction by now if not for actions taken by ORA and our members.

In the fall of 2011, ORA was instrumental in a coordinated effort that resulted in three separate Environmental Reports (ERs) submitted by Xeneca Power Development Inc. (Xeneca)  being rejected by Ontario’s Ministry of Environment.  This was due to several deficiencies, as well as a “lack of traceability and transparency in Xeneca’s decision-making process and associated documentation”.  The developer was sent back to complete key studies and do more planning.  This rejection has led to another two years of studies, which has provided precious time for circumstances to influence some of their other proposals.  These ERs were three of a total of 19 proposals by Xeneca.

This was due to ORA and several of its members submitting Part II Order requests on hydro-electric proposals for the Ivanhoe, Frederick House and Serpent Rivers.  These were requests for the Minister of Environment to require an Individual Environmental Assessment (EA) for the projects.

Under current provincial legislation, Part II Order requests are the only option for the public and stakeholders to advocate for a more rigorous scrutiny of the proposal, and hopefully a more environmentally and socially sustainable hydroelectric project.

The proponent led process puts the fox in charge of the henhouse.  The proponent decides when to notify and consult with stakeholders, relay information, and share important documentation. Proponents don’t hesitate to let you know it’s a done deal, and that there is nothing you can do to stop the project.

Although requests to elevate the first three projects to individual EAs were not granted, these efforts did result in the proponent being required to conduct further studies. Not only did this delay the original three proposals, but it also caused Xeneca to shelve several other proposals that it had intended to issue Draft ERs on by the spring of 2012.  It has also provided time for the Department of National Defence to remove two waterpower sites on the Petawawa River.

This action by ORA and its members in 2011 bought valuable time for other events to transpire, and without this action, many of these proposals would most likely have been through the EA process by now, into the permitting phase, and under construction.

As of yet, none of Xeneca’s 19 intended projects have been approved by the Minister of Environment, and not one of the original three proposals has come back through to ER.

The first of Xeneca’s projects to make it through to the ER stage since then is the proposed Wabagishik Rapids Generating Station on the Vermilion River. In response to Xeneca’s ER and Notice of Completion in the fall of 2013, nineteen Part II Order requests were submitted to the MOE by ORA, Vermilion River Stewardship, and other concerned citizens. The large number of requests is in large part due to public awareness activities by ORA over the past few years. Currently, we are awaiting a response from the Minister regarding Wabagishik.

You can help ORA continue our work by becoming a member or making a contribution.  For more information click here.

 


American Eel Recovery Strategy – EBR Posting 012-0405 – ORA Submission

American Eel

Excerpt:

“American Eels were once abundant in the upper St. Lawrence River, Ottawa River, Lake Ontario, and their tributaries, and in fact were so plentiful that they were an invaluable source of sustenance to First Nation communities and early European settlers, and more recently supported thriving commercial and sports fisheries.  This all changed with the advent of a multitude of hydroelectric dams constructed within the historic range of the species.

Key to the American Eel’s survival and recovery is its ability to migrate to its spawning area in the Sargasso Sea, near Bermuda.  This is a perilous journey that only a very small percentage ever complete due to the cumulative effects of the numerous hydroelectric facilities that have killed, maimed, and cut off migration to their spawning area.  Consequently their once thriving populations have been reduced to a mere one percent of their original numbers.” Continue reading



Wabagishik Rapids Generating Station – Environmental Report – ORA Part II Order request

Wabagishik Rapids, Vermilion River – Proposed Dam Site

Excerpt:  “This project has not been planned in an environmentally responsible manner, and has not fully taken into account the interests of local stakeholders and the public. Therefore, it is our position that for all the reasons noted herein, Xeneca has not fulfilled its requirements under the Class EA for Waterpower.”

Continue reading



Enerdu GS, Mississippi River, Almonte – Part II Order Request, by ORA

Almonte, Mississippi River

Almonte, Mississippi River

Summary of Recommendations:

It is ORA’s position that referring to this proposal as a “run-of-river” operation throughout the entire Environmental Report (ER), and not revealing or addressing the fact that this facility is actually a peaking operation that holds water back to produce power during peak demand hours, is a fatal flaw that places the integrity of the entire ER in question. We must then ask, what other important details have been left out.

Recommendation 1:
After having carefully reviewed the ER and the Response from Enerdu, and for all the reasons set out in this letter, ORA is making a formal request to the Minister of the Environment to elevate this proposal to an Individual Environmental Assessment.

Recommendation 2:
Failing the implementation of Recommendation 1, ORA requests that the Minister reject Enerdu’s ER, and the proponent be ordered to provide an ER that addresses all the recommendations and concerns set out in this letter.

Recommendation 3:
The categorization of “Existing Infrastructure” does not define or differentiate the rigor or level of the environmental evaluation required, and therefore the full impacts of the existing and planned operations must all be fully considered and assessed – both upstream and downstream.

Recommendation 4:
If Enerdu’s intent is to continue peaking this facility, then the proponent should be ordered to correct their ER by removing all reference to this project as a run-of-river and to instead make reference to it as a “modified peaking hydroelectric facility”. Continue reading