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Category Archives: Dam Agreements

Exempting dams from requiring a Permit to Take Water – ERO-019-2517

By Linda Heron on Friday, November 20th, 2020
Posted in Dam Agreements, Dams, Environmental Registry, Fisheries, Impacts, Industry, Lakes & Rivers Improvement Act, Ontario Water Resources Act, ORA Submissions, Permit to Take Water, Regulatory, Regulatory Submissions, River Concerns, Rivers at Risk, Safety, Species at Risk, Water Quality

Melville Dam, Credit River, breached on 26 June 2017

ORA submits that the MECP’s priority must be the pursuit of its Statement of Environmental Values (SEV), and its vision and mandate of “an Ontario with clean and safe air, land and water that contributes to healthy communities, ecological protection, and environmentally sustainable development for present and future generations”[i].  There is nothing in the MECP’s SEV that promises to “remove the regulatory burden” from industry or “provide some cost savings for dam owners and operators”.  It is not the MECP’s duty to save dam owners and operators money or ease their regulatory burden. Its duty is to fulfill its Mandate to protect the environment and to follow its promise of environmentally sustainable development for our present and future generations.  Certainly, MECP’s priority should not be to cut regulatory burden at the expense of our air, land and water.  It is a tragedy that today’s cost savings for dam owners and operators will be borne on the backs of our children and grandchildren.

[i] Statement of Environmental Values: Ministry of the Environment and Climate Change

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Waterpower Agreements – Concerned Stakeholder/Citizen, by Rob MacGregor

By Linda Heron on Tuesday, August 9th, 2011
Posted in Agreement Renewals, American Eel, Dam Agreements, Dams, Energy, Hydroelectric, River Concerns, Rivers at Risk, Species at Risk

June 23, 2011:

Excerpt:

a) Sitting now as a concerned stakeholder/citizen outside of government, I now see very clearly the problem governments are faced with regarding public communication and consultation. Government has a job to do, has deadlines to meet and needs to tick off the public consultation box. In the case of waterpower agreements, apparently public consultation was not really required for some reason, but you’re branch did it anyway. While I am glad you chose to consult, I am annoyed that there is a rule, policy or guideline that even suggests that public consultation is not mandatory for agreements with such far reaching and ongoing potential impacts; where does that policy appear? Now that there is a brief interlude, I have to get some things tabled; hopefully they will be helpful in future attempts to consult with the public. While I am obviously interested in these agreements and appreciate the opportunity to comment, I resent being put in the position I have been in over the last month. I, like all other members of the public, am extremely busy living life. I am also very interested and concerned over some matters that are going on with “sustainable management” of the environment within government, and I wish to have an opportunity to comment effectively. I did not, in the case of waterpower agreements, but I have the following synthesis comments: Continue reading →

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

By Linda Heron on Saturday, July 23rd, 2011
Posted in Agreement Renewals, American Eel, Dam Agreements, Dams, Energy, Hydroelectric, Mississippi River, ORA Submissions, River Concerns, Rivers at Risk

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

By Linda Heron on Saturday, July 23rd, 2011
Posted in Agreement Renewals, American Eel, Chenaux Falls GS, Dam Agreements, Dams, Energy, Hydroelectric, ORA Submissions, Ottawa River, River Concerns, Rivers at Risk

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

By Linda Heron on Saturday, July 23rd, 2011
Posted in Agreement Renewals, American Eel, Chats Falls GS, Dam Agreements, Dams, Energy, Environmental Registry, Hydroelectric, ORA Submissions, Ottawa River, River Concerns, Rivers at Risk

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

By Linda Heron on Saturday, July 23rd, 2011
Posted in Agreement Renewals, American Eel, Dam Agreements, Dams, Energy, Gananoque GS, Gananoque River, Hydroelectric, ORA Submissions, River Concerns, Rivers at Risk

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

By Linda Heron on Saturday, July 23rd, 2011
Posted in Agreement Renewals, American Eel, Dam Agreements, Dams, ORA Submissions, River Concerns, Rivers at Risk, Species at Risk

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

By Linda Heron on Saturday, July 23rd, 2011
Posted in Agreement Renewals, American Eel, Dam Agreements, Environmental Registry, ORA Submissions

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.

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

By Linda Heron on Saturday, July 23rd, 2011
Posted in Agreement Renewals, American Eel, Dam Agreements, ORA Submissions

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.”

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