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Category Archives: Regulatory

ERO 019-5816 – Development of a Clean Energy Credit Registry

The total amount of GHGs emissions from a hydroelectric facility is dependent upon many factors, including the impounded reservoir, terrain, amount of organic matter, air-water temperature, reservoir depth and size, vegetation (algae and plant/tree litter), pH values, oxygen levels, flow velocity, water level fluctuations, wind speeds, precipitation, wetlands within the impoundment zone, and facility operating strategy (cycling and peaking to maximize power generation).  Every hydroelectric facility is unique in its complexity and must be carefully studied and continually assessed and monitored to determine the total daily, seasonal and annual GHG emissions per MWh emanating from the system.

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Erin WWTP – Environmental Compliance Approval – Joint

Photo by Steven Noakes – West Credit River Brook Trout

The Coalition for the West Credit River (Coalition) remains very concerned with the potential environmental impact of the Erin Water Resource Recovery Facility (WRRF) and, in particular, the temperature of its treated effluent harming the sensitive coldwater Brook Trout habitat of the West Credit River. 

As your Ministry is aware, the approved sewage treatment plant proposes to discharge large flows of sewage effluent into the relatively small flow of the West Credit River. The lack of significant dilution will greatly magnify the thermal impact of warm effluent on this coldwater stream. 

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Environmental Compliance Approval Number 7877-CALRZU – Erin Water Resource Recovery Facility – Joint

Photo by Steven Noakes

First, the Coalition for the West Credit River (Coalition) would like to express our deepest appreciation that you and your staff worked with our Technical Team over the last several months to incorporate some of our recommendations into the Environmental Compliance Approval (ECA). However, we are concerned that our key recommendations for improvements to the draft ECA, received by you on 2 May, were not reflected in the ECA approved on 3 May 2022. 

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Delegation Request – Erin Water Resource Recovery Facility – Joint

Photo by Steven Noakes

The Coalition is very appreciative of your strong support in recommending to the Honourable David Piccini, Minister of Environment, Conservation Parks (MECP) and Mayor Allan Alls, Town of Erin, that our draft Monitoring and Adaptive Management Plan be integrated into the Environmental Compliance Approval (ECA). As you are likely aware, the ECA for the Erin Water Resource Recovery Facility was approved on 3 May 2022 by Aziz Ahmed, P.Eng., MECP Manager of Municipal Water & Wastewater Permissions, appointed for the purposes of Part II.1 of the Environmental Protection Act. 

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Renomination of Radionuclides as Chemicals of Mutual Concern Under the Great Lakes Water Quality Agreement

Five years ago, in March 2016, 110 groups submitted an application under the Great Lakes Water Quality Agreement (GLWQA) to designate radionuclides as Chemicals of Mutual Concern (CMCs) under Annex 3 of that Agreement. We submitted our nomination in reply to Environment and Climate Change Canada’s (ECCC) and the U.S. Environmental Protection Agency’s (EPA) call for nominations from the public. 

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Hydroelectric Program Development and Assessment – IESO Small Hydro Program

First, it was enlightening to be provided with a clear definition of small and large hydro facilities in the Hydroelectric Program Development and Assessment webinar, as well as a total amount of power generated by these categories. You informed that the definition of small hydro would have a scope of installed capacity of 10 MW and under, with 30 companies representing 50 facilities generating a total of 120 to 150 MW, and large hydro having a scope of installed capacity of over 10 MW, with 3 companies representing 22 facilities producing a total of 1,000 MW. 

The increased number of small hydro facilities making such a small contribution to our electricity grid impacts on multiple Ontario riverine ecosystems, whereas the 22 facilities producing 1,000 MW of power on presumably fewer rivers has a much lower trade-off value. Additionally, larger rivers have a greater capacity to buffer some of the worse effects of hydroelectric. 

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ERO 019-4971 – Draft Low Impact Development Stormwater Management Manual

Blue Heron in Waterloo, Ontario, by Leslie Bamford

The ORA is in full agreement that Low Impact Development (LID) must be a priority in development planning guidance for stormwater management practices and should include innovative green infrastructure such as rain harvesting, rain gardens, green roofs, urban trees and forests, permeable surfaces, ditches, swales, stormwater catchments, and must emphasize the protection of wetlands.

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Bill C-28, An Act to amend the Canadian Environmental Protection Act, 1999 – Joint Support

“Banksy Toxic Waste” by Noodlefish is marked with CC BY-NC-SA 2.0.

The undersigned organizations and experts support the following Submission to the Ministers of Environment and Climate Change and Health on Bill C-28, An Act to Amend the Canadian Environmental Protection Act, 1999, etc. submitted by the Canadian Environmental Law Association in February 2022. This submission is relevant for Bill S-5 (An Act to amend the Canadian Environmental Protection Act, 1999, to make related amendments to the Food and Drugs Act and to repeal the Perfluorooctane Sulfonate Virtual Elimination Act) released on February 9, 2022. 

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A Clean Electricity Standard in support of a net-zero electricity sector – Discussion Paper

When people refer to hydroelectric as clean, it’s usually in the context of GHG emissions; however, governments and utilities often use the term categorically and without caveat or qualification. Using the word “clean” in this context is misleading. Just because hydroelectric facilities are not spewing out smoke does not mean they are clean or renewable.  In fact, waterpower has resulted in significant and ongoing impacts on water quality, water quantity, ecological processes, fish and wildlife populations and habitat, and to aboriginal communities. Hydroelectric also makes a significant daily contribution to the earth’s accumulation of greenhouse gases (GHG) in our atmosphere.

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ERO 019-4108 – Expanding Administrative Penalties for Environmental Contraventions

The ORA strongly supports the proposed penalty regulations under the Environmental Protection Act and the Ontario Water Resources Act that would revoke and replace existing penalty regulations under these acts.

That being said, this regulation would have been even more beneficial if this provincial government had not spent the last 4 years (more than 2 years of which have been under a COVID Emergency) totally gutting our hard-earned protective environmental legislation (all in the name of “cutting red tape”) and degrading (in some cases eliminating) the public’s ability to have input into a Project, to be consulted, and to appeal a Minister’s decision. Proponents have no worry of polluting or protecting the environment when there is no effective legislation left to comply with.

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