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Category Archives: Green Energy Act

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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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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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-019-3007 – Reviewing Ontario’s long-term energy planning framework

No new hydroelectric projects should be included in the short or long-term energy plan. Hydroelectric power generation is dirty energy resulting in significant ongoing negative impacts to riverine ecosystems, including, but not limited to GHG emissions (methane and Co2), degraded water quality, declining fish populations, methyl mercury contamination of fish, and ongoing harm to Indigenous communities.

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Parkhill Hydro Generating Station, Grand River

In September of 2016, the Grand River Conservation Authority (GRCA) received a Feed-in-Tariff Power Procurement Contract from the IESO to sell power to the grid.  In June 2017, the GRCA initiated a Class Environmental Assessment to evaluate the construction of a waterpower project, the Parkhill Hydro Generating Station located at the existing Parkhill Dam in the City of Cambridge. If approved and constructed, this waterpower project would have a nameplate capacity of 500 kW. The project is subject to the provisions of the Ontario Waterpower Association “Class Environmental Assessment for Waterpower Projects.” Pursuant to the Class EA, this project is considered to be associated with existing infrastructure. Continue reading


EBR 012-8840 – Ontario’s Long Term Energy Plan

 

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The Ministry of Energy is undertaking a formal review of Ontario’s Long-Term Energy Plan (LTEP), and comments were due on 16 December 2016.

The LTEP is a road map that will set the direction for Ontario’s energy future over the next 20 years.   More information on this EBR posting can be found here.

The Ministry of Energy must ensure that our electricity supply is environmentally, economically and socially sustainable and affordable.
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Objection to Feed-in-Tariff Program, FIT Rules Version 5.0.1

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Today I am writing to draw your attention to an issue that was quite concerning.  Rather than make an Application for Review under the Environmental Bill of Rights, I am reaching out to you in the hopes that you will withdraw a recent amendment to the FIT 5 Rules. Continue reading



ORA Meeting with Minister Glenn Thibeault

The Ministry of Energy has included hydroelectric in its renewable energy mix, and the generous rates and peaking bonuses have encouraged a rash of new hydro facilities to be proposed, as well as upgrades and changes to operating strategies that allow facilities to hold water back from downstream flow in order to produce power during peak demand hours. Many power producers arbitrarily adjust their operating strategy by using seasonal operating bands to peak on a daily basis – without first conducting an environmental assessment to determine the potential impacts, or the sustainability of the operation.

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