ORA is very concerned about the extreme deregulation that occurred with the recent waterpower exemption to the Permit to Take Water, and in this new Mercury Regulation where new and significantly redeveloped electricity producing dams have not been addressed. These important legislative requirements were designed to ensure hydroelectric facilities are held accountable for environmental and socio-economic impacts and risks to communities and riverine ecosystems.
We, the 112 undersigned organizations, call on the Government of Ontario to retain the current mandate of the province’s 36 Conservation Authorities in protecting, restoring and managing the watersheds where 95 percent of Ontarians reside. Their functions and responsibilities with respect to land use planning and permitting, monitoring, stewardship and education must be maintained, for the reasons outlined below.
In effect, this overbroad exemption means that for the duration of the regulation residents of Ontario, including Indigenous community members, will not have knowledge of, nor a means to participate in, provincial decisions which may have significant effects on the environment.
We strongly encourage the Ministries to hold fulsome and meaningful public consultations, aimed at ensuring that the proposed budgetary, legislative, and any future regulatory changes meet the desired vision of improving Ontario’s resilience to climate change. Until such time as a full assessment of the proposed changes is complete, we call on the government to delay enacting Bill 108, Schedule 2.
We, the undersigned organizations, strongly oppose proposed changes to the Endangered Species Act, 2007 (ESA) put forward in Schedule 5 of Bill 108. The changes contained in Schedule 5 will strip Ontario’s most vulnerable plants and animals of crucial legal protection.
We, the undersigned, are reaching out to all MPPs to urge you to uphold the spirit and intent of the ESA as well as its focus on demonstrable benefit to species, and to ensure that it is not weakened during the ongoing review.
We note, with deep concern, that environmental deregulation – making it easier for industry and development proponents to proceed with activities that harm species at risk and their habitats – appears to be the overall focus and intent of the options put forward for consideration. Reassuring statements that the review is intended to “improve protections,” “improve effectiveness” and provide “stringent protections” (p. 2) are misleading, in light of the actual proposed changes that MECP is inviting the public to consider. These include options that would undermine the very cornerstones of the law: science-based listing (including Indigenous Traditional Knowledge), mandatory habitat protection, and legislated timelines for planning and reporting.
Our organizations recommend choosing Alternative 3 – the Full Removal of Springbank Dam and the naturalization of this section of the Thames River. We submit that full dam removal and naturalization are the preferred solutions from an environmental perspective and would likely prove to be the most cost-effective over the long-term when Life-cycle costs and available provincial and federal funding are considered.
The full Capital and Life Cycle Costs of Rebuilding Riverside Dam were not realistically represented in the ESR and could well end up costing the taxpayers more than double what was presented to the public and City Council. A Rebuilt dam would be considered a new dam, not a repair or expansion of an existing weir, with an assessed High Hazard Potential, and is located within the City of Cambridge in a location that could place multiple residences and businesses at risk in the event of severe flooding or a dam breach. ORA and Partners submit that this Project goes far beyond the screening process provided by a Schedule B, Class EA. Consequently, we submit that this is a major project that should fall into a higher level of assessment.
The presence and impacts of PAHs in the Great Lakes has been noted in the Canada-ˇOntario Agreement for over three decades. The Ontario provincial government and the Canadian federal government conducted a report, The Status of Tier 1 and Tier 2 chemicals in the Great Lakes basin under the Canada -ˇOntario Agreement, which noted that, “in some cases, the levels of PAHS in open surface water are still above the Canadian Council of Ministers of the Environment (CCME) Canadian Water Quality Guidelines. These exceedances are associated with known industrial sources.”