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Category Archives: Industry

Feedback on the IESO Resource Adequacy and Long-Term 2 RFP Engagement

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.

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Marmora Pumped Storage – Clean Energy Hub Project

This closed-loop pumped storage Project does not seem likely to result in any serious negative impacts to other freshwater bodies, nor methylmercury contamination of fish tissue or greenhouse gas emissions, and it will provide clean backup power during the low-flow periods when small run-of-river hydroelectric facilities are shutting down because of reduced stream flow. Comparing the power output of this peak demand storage Project, and its minimal environmental impacts to the number of rivers it would have taken to generate 400 to 500 MW of power from dozens of small hydropower projects, makes it ORA’s preferred choice over conventional hydroelectric facilities.

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ERO-019-6647 – IESO Pathways to Decarbonization Study

Greenhouse Gas Emissions from Reservoirs

The ORA will never be in favour of streamlining the regulatory, approvals and permitting processes as they were put in place to protect our natural environment and communities, and have already been significantly undermined.

Instead, we need strong and rigorous environmental assessment and robust public, Indigenous and stakeholder consultation if we are to build climate resilience into our air, land and freshwater resources.

I will briefly address my rationale and the dangers of streamlining the regulatory regime of hydroelectric facilities in particular, as it is commonly claimed by governments and industry to be ‘clean’, ‘green’ and ‘non-emitting. However, this is misleading the public at a pivotal time when we should be following the science.

Related Information:

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Hydroelectric is not a Pathway to Decarbonization or Net Zero

Dear Ministers Guilbeault, Wilkinson and Champagne,

ORA understands the urgency in fulfilling the vitally important commitment the government has made to cut GHG emissions to 40-45% below 2005 levels by 2030; however, we will present evidence from independent third-party peer-reviewed studies indicating that an effective path to decarbonization is not through hydropower.

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Is hydroelectric a pathway to decarbonization?

Watch our video to understand how hydroelectricity is greenwashed by Ontario Power Generation as “clean” and “non-emitting” when there are hundreds of independent third-party studies to the contrary. Read our full submission here!

Please sign and share our petition to protect Ontario Rivers and send OPG a strong message! 


IESO – 2023 Annual Acquisition Report Feedback

There are numerous independent third-party studies reporting that hydroelectric facilities emit significant amounts of carbon dioxide, methane and nitrous oxide and we will be stuck with these dams for 100 years or more as proponents are quick to point out. There are also no up-front decommissioning fees to take these dams out when the rivers start to dry up, and the truth is finally acknowledged that they are methane factories.

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2023 Annual Acquisition Report – ORA Feedback

Big Falls, Trout Lake River

There are currently three pumped storage projects going through the planning and approvals process, that would add approximately 2,000 MW of electricity to the grid. Developing that same Installed Capacity from small hydroelectric projects would involve 200 – 10 MW proposals that would cause untold environmental damage to dozens of Ontario rivers.  It is imperative the province does not rush or over-reach its targets and develop new electricity projects unnecessarily.

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OPG: Proposed Coniston Generating Station Life Extension Project Environmental Report

Wherever water levels have been lifted from their former undeveloped elevation must be considered the full extent of the reservoir/s. This crucial detail is not set out in the ER; however, the full extent of the cascading facilities must be considered when detecting, measuring and reporting total GHG emissions (CH2, CH4 and N2O). This cascading system creates one very large artificial and ongoing multi-level series of reservoirs that are highly regulated through the WRWMP, and likely very high in GHG emissions.

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Hydroelectric and its “Pathway to Decarbonization”

Abitibi River – Twin Falls GS

Please sign and share our Petition:  Hydroelectric is NOT a Pathway to Decarbonization.

The increasing role of hydroelectric reservoirs as GHG emitters and negative environmental effects has resulted in thousands of independent peer-reviewed studies laying out the facts. However, the hydropower industry and governments have done a thorough job of promoting waterpower through a powerful disinformation campaign to mislead the world into believing it is clean and non-emitting while turning a blind eye to the growing body of evidence to the contrary.

ORA strongly recommends that OPG begin the use of drone technology to detect, map and measure GHG emissions within the entire zone of influence of its hydroelectric facilities – in the upstream reservoir, turbine intake, spillway and downstream of the dam. This will ensure that those who have purchased clean energy credits from OPG are getting what is claimed – a clean and non-emitting source of electricity. All data should be placed in real-time on the OPG website and made available to researchers and the public.

In closing, the ORA requests that the Minister finally remove the label of clean and non-emitting from hydroelectric generation. Certification will mean nothing if there is no authentic and verifiable science-based method of reducing Ontario’s GHG emissions. Furthermore, it would be unethical and fraudulent to mislead the public and corporations into believing they are paying for clean and non-emitting electricity when they are actually paying to fuel climate change.

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ERO-019-6141 – Legislative & Regulatory proposals affecting Conservation Authorities

“Consider This” by Storm Crypt is licensed under CC BY-NC-ND 2.0.

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?

[1] Protecting People and Property: Ontario’s Flooding Strategy, 10 March 2020. P-7/42

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