While the effects of large hydro projects (200 MW) have been well known and documented for over a century, small (up to 10 MW) and medium sized (10 MW to 200 MW) hydroelectric projects involve many of the same impacts per unit of power generated and, cumulatively, the environmental degradation can exceed that of large hydro projects. Small and medium sized hydro projects are situated on smaller and often more sensitive riverine ecosystems; however, like large hydro projects, will also alter the river’s flow regime and can have significant impacts on the aquatic environment, as flow is a major determinant of a river’s ecological characteristics and its aquatic biodiversity.
A recent study examined scaled hydropower impacts in the Nu River basin of southwestern China, where the researchers calculated impact per MW of capacity across 14 metrics between small and large hydropower projects (with small being below 50 MW as defined in Chinese policy). They found that small hydropower dams had greater impact per MW for 9 of the 14 metrics, including length of river channel affected and impact on habitat designated as conservation priorities.
In May of 2013 the Ontario Rivers Alliance made a Part II Order request on the proposed Trout Lake River Hydroelectric Generating Station, at Big Falls, in the Red Lake area. This proposal seemed to die a natural death with no decision on our Part II request, or activity/movement forward on the project. Here we are now more than 7 years later, and last week we received the correspondence below from the MECP stating that
“As part of our government’s efforts to boost Ontario’s economic recovery after COVID- 19, we have passed the COVID-19 Economic Recovery Act, 2020, including amendments to the Environmental Assessment Act.
The changes to the Environmental Assessment Act will allow us to build a strong environmental assessment program that effectively considers the input of local communities and focuses on projects that have the highest impact to the environment. The Act will continue to consider “the protection, conservation and wise management in Ontario of the environment”. A key change made to the Environmental Assessment Act was to limit Part II Order requests to potential adverse impacts of projects to constitutionally protected Aboriginal or treaty rights. All Part II Order requests that were under review which do not pertain to potential adverse impacts on constitutionally protected Aboriginal or treaty rights have been terminated by the amendments.”
The COVID-19 Economic Recovery Act was passed earlier this year, and this legislative amendment is retroactive in its backwards reach to 2013. In spite of the government’s misleading claim that the changes to the EAA “will allow us to build a strong environmental assessment program”, it couldn’t be further from the truth. In fact, there is now no mechanism to request a more rigorous environmental assessment, and public consultation and consideration on these risky projects, as well as the ability to make a Part II Order request, is no longer a possibility. There was also no public or Indigenous consultation before the passing of the Economic Recovery Act.
Instead of exemptions or a more streamlined Class EAW, the OWA should be proposing amendments to provide for a much more rigorous and accountable process that ensures fish friendly turbines, effective and safe fish passage, a more rigorous cumulative effects assessment, and a more comprehensive and meaningful consultation process. We should be making our rivers more resilient in the face of climate change – not exempting waterpower projects from the Class EAW. Instead, the OWA and the Ontario government are placing our environment and communities at risk.
The fact that Lake Sturgeon and American Eel no longer exists in this section of the Madawaska River, is all the more reason that OPG should make every effort to rehabilitate these populations and include effective fish passage for these and other fish species at this facility. OPG is a provincial entity and as such should set the example as a beacon for responsible and sustainable hydroelectric facilities and operations in Ontario.
The ORA is opposed to this proposal that would gut the Environmental Assessment Act (EAA) and the Environmental Assessment (EA) program. Since the EAA was amended in 1996 there have been many official calls for an improved EAA and EA program, amongst those calls were the Environmental Commissioner for Ontario and the Auditor General of Ontario. Over this time, the EA program and EAA have become more and more streamlined, and this has led to increasing uncertainty for stakeholders and proponents.
Many individuals and groups embarking on the Part II Order process are new to it, have no legal assistance or background, and are unfamiliar with the terminology and rules; therefore, if we are truly aiming to provide help to the public it is extremely important that clear, succinct and concise instructions be provided in this policy/guidance document.
It is imperative that the Town of Erin examines every means possible to make its community more resilient to climate change, and most importantly, to protect its finite freshwater resources and its fishery. In fact, consideration of climate change was not even mentioned within the EA documentation, and ORA sees this as a major flaw, when it should have been included as a key consideration in the Scoring Matrix.
MEDIA RELEASE: For Immediate Release: 13 July 2016
10 Ontario Rivers Protected from 19 Hydroelectric Projects
SUDBURY: The Ontario Rivers Alliance (ORA) is celebrating a major victory in the protection of 10 Ontario rivers that have been under threat from 19 proposed hydroelectric projects. Actions taken by the ORA and its members have led to what was considered to be impossible – the termination of 19 Feed-in-Tariff (FIT) Contracts.
In 2011, ORA came into being to address a rash of 87 proposed hydroelectric proposals initiated under the Green Energy Act. The offer of generous incentives to produce power during peak demand hours had proponents rushing to claim access to falls and rapids on rivers all across the province. The number of proposals to actually receive FIT Contracts was soon reduced to 41, and of those, Xeneca Power Development Inc. had secured 19 contracts for projects involving 23 Crown sites on 10 Ontario rivers. Continue reading
It was very surprising and disappointing to read your decision letter; however, it was somewhat understandable when the Minister’s decision was based upon inaccurate and unsupported responses contained within the Ministry Review (Review) document, Xeneca Power Development Inc.’s (Xeneca) correspondence, and the Environmental Report (ER). Continue reading
ORA urges the MOECC to reject all aspects of the proposed major amendment to the Class EA for Waterpower (except the minor housekeeping changes), on the grounds that waterpower is far too complex and site-specific to assume that projects under 500 kW at existing infrastructure, or that increases in efficiency of an existing waterpower facility, would be less likely to involve new environmental effects or impact on communities. This is absolutely wrong thinking for the protection, conservation and wise management of Ontario rivers.