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Mississippi, Chats, Chenaux Hydroelectric Generation Facilities – Agreement Renewals – Allen

June 20, 2011:

Excerpt:

Through my June 15, 2008 public input to MNR re EBR 010-3320 (To establish new regulatory provisions under the Endangered Species Act, 2007 to allow certain activities to continue), I alerted MNR to issues which it could have incorporated into the proposed agreements. For unknown reasons MNR has decided not to follow that advice. I ask that all of my three-year-old public comment to EBR 010-3320 be reviewed and incorporated into any agreement which goes forward. I also ask that my public comments re EBR 011-3334 be reviewed and incorporated into any agreement which goes forward. Continue reading


Mississippi River Hydroelectric Facilities – Agreement Renewals – Disposition of American Eel – ORA

June 20, 2011:

Excerpt:

The decline of the American Eel to near extirpation in Ontario is a matter of strong public interest and concern. Cumulatively, waterpower facilities have had major negative impacts on American Eel in Ontario by preventing adequate access to important historical habitat and by killing significant quantities of eel as they attempt to migrate back to sea to spawn. These impacts have persisted on an ongoing basis in Ontario for almost a century. Continue reading


Chenaux Hydroelectric Facility Agreement Renewal – Disposition of American Eel – ORA

June 20, 2011:

Excerpt:

This agreement must provide for permanent upstream and downstream passage to be installed at a specified time within the 30-year agreement, otherwise the ministry is committing the minister to an agreement that may not meet all tests of OReg. 242 for a 30-year period! This agreement does not even give a remote perception of assurance that the two fundamentals of recovery of eels will ever be installed, i.e. upstream and downstream passage. Continue reading


Chats Falls Generating Station Agreement Renewal – Disposition of American Eel – ORA

June 20, 2011:

Excerpt:

The ORA has noted previously that upstream and downstream passage should be pillars of all waterpower agreements involving eels. The agreement should be re-written with more careful and clear approaches that meet the tests of OReg. 242; otherwise the ministry may be unnecessarily subject to strong challenges. We have previously suggested ways of doing this in our response to the recent EBR posting on waterpower agreement. Continue reading


Gananoque Dam and Hydroelectric Facility – Agreement Renewal – Disposition of American Eel – ORA

May 23, 2011:

Excerpt:

The Waterpower Agreement process outlined in Regulation 242/08 of the ESA is one means of ensuring effective mitigation. However, the Gananoque Agreement falls far short of being an effective means of protection and recovery of the American Eel, and gives the appearance that waterpower developers have too much influence in negotiating effective agreements. A much stronger agreement should have been possible given that the ministry has had three years to negotiate it. Continue reading


Chaudiere Falls Hydro-electric Facilities, Waterpower Agreement Renewal – ORA

May 23, 2011:

Excerpt:

The agreements at Chaudier Falls are critical as these facilities are the most downstream of Ontario- owned facilities on the Ottawa River. Mitigation of the significant effects of Chats, Chenaux and Carillon dams and generating stations on eels are equally as strategic for eel recovery as they are all in the downstream middle reaches where eels still exist in the Ottawa River and continue to be impacted.   Continue reading


EBR-010-7775 – Proposed Major Amendment to the Crown Land Use Policy Atlas (Wolf Lake) – ORA

July 11, 2011:

Excerpt:

We are concerned about a proposed major amendment to the Crown Land Use Policy Atlas in the Chiniguchi River and Wolf Lake area of the Sudbury District. As the world’s largest old growth red pine forest1, the Wolf Lake area is ecologically unique and simply irreplaceable. As a popular tourist destination, the Wolf and Matagamasi Lake areas are an integral linkage for the Chiniguchi Waterway Park. Continue reading


EBR-011-3334: Agreements for existing hydro-electric generating stations – Allen

May 26, 2011:

Excerpt:

As a member of the American Eel Recovery Strategy Team and one of the six co-authors of the American Eel Recovery Strategy, I can assure you that my co-authors and I have paid assiduous attention to establishing a recovery strategy for American Eel which has feasible mitigation strategies that are within the responsibilities of the Minister and treat the required adaptive management process with respect. Under the circumstances I recommend that the deadline for completion of agreements under S.11 be extended to a date 12 months after the public release of Ontario Government policy outlining the long term recovery strategy for American Eel.

Continue reading


EBR-011-3334 – Agreements for existing hydro-electric generating stations – ORA

May 26, 2011:  “ORA would first like to emphasize the vital importance of providing safe upstream and downstream passage for American Eel, as well as all fish species, even those not listed officially as threatened or endangered species. Ensuring the conservation of Ontario’s biodiversity, and protecting the integrity of Ontario’s ecosystems, is absolutely essential when issuing any permit or approval for any waterpower facility, as each project can individually have serious potential impacts on the natural resources of Ontario.”

Continue reading


EBR-010-7895 – Site Release Policy – ORA

April 13, 2011:

Excerpt:

ORA is suggesting much more groundwork be undertaken, as well as consultation with the public and stakeholders, by the Applicant, before a Site Release is granted. There is no point in going through the Environmental Assessment process unless the Community, Stakeholders, and the Municipality have first given their consent. This Site Release Policy is important groundwork that must be completed and approved of before any Notice of Commencement is issued.  Continue reading