16 September 2013

Dear Ms. Green

I tried to submit my brief comments online but only found a save button so I am uncertain if my comments were received. So I am providing comments again directly via email.

My major comment is that any public consultation regarding choices in long-term energy plans is incomplete without including the environmental risks associated with each choice.  For instance, significant collateral ecological damage often comes with waterpower and asking the public to consider choices and comment on them with out a clear articulation of environmental risks associated with each sector is not only incomplete, it can be viewed as deceptive if later the government indicates it consulted with the public over the LTEP. I know the argument will be that there are other environmental processes that look after this aspect and that this consideration is out of scope. This siloed approach is rampant in government and extremely flawed.  For instance, there have been many instances of serious collateral ecological damage in the past with waterpower projects, despite the existence of  environmental regulations and processes, some could have been easily mitigated, mitigation of others would have been more difficult.  Consulting with the public over energy plans for the province without a full discussion/disclosure of the environmental risks is a serious oversight, particularly in view of the fact that the environmental review process for energy projects is not working and needs to be reviewed and amended accordingly. Added to this is the simple fact that once a site is release for consideration for energy projects, a train starts rolling that is difficult if not impossible to stop. Indeed. finding ways to approve such projects can become the unwritten rule. A better approach would be for the province to first to develop a strategy that evaluates where such projects make ecological sense, and where they do not before sites are released for further consideration and investment by the various energy sectors. Continue reading →