ORA submits that the MECP’s priority must be the pursuit of its Statement of Environmental Values (SEV), and its vision and mandate of “an Ontario with clean and safe air, land and water that contributes to healthy communities, ecological protection, and environmentally sustainable development for present and future generations”[i]. There is nothing in the MECP’s SEV that promises to “remove the regulatory burden” from industry or “provide some cost savings for dam owners and operators”. It is not the MECP’s duty to save dam owners and operators money or ease their regulatory burden. Its duty is to fulfill its Mandate to protect the environment and to follow its promise of environmentally sustainable development for our present and future generations. Certainly, MECP’s priority should not be to cut regulatory burden at the expense of our air, land and water. It is a tragedy that today’s cost savings for dam owners and operators will be borne on the backs of our children and grandchildren.
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.
The Rudd Dam’s headpond had essentially turned into a large wetland created by over 100 years of sediment accumulating behind the dam, and the shallow pond’s water temperature was no longer viable brook trout habitat. After the removal of the Rudd Dam the water temperature was reduced and brook trout habitat was made more resilient to a warming climate. It was also an earthen dam that had already failed once, and the dam owner’s objective was to reduce his risk and liability.
With the warming temperatures and extreme rain and drought events that climate change is predicted to bring with increasing frequency and intensity as time passes, decision makers and legislators bear a responsibility to strengthen freshwater protection and resiliency – not weaken it. If this proposal moves forward it will be a precipitous turning point for our future with freshwater in Ontario and beyond.
You will find ORA’s submissions regarding Bill 132 here.
Check out ORA’s speech to the Standing Committee on General Government: Continue reading
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.
In November of 2015, Ontario Rivers Alliance (ORA) commented on EBR 012-5093, regarding a Technical Bulletin for the Alterations, Improvements and Repairs of Existing Dams. You can find our submission on our Blog here. On March 24, 2016, ORA received a Decision Notice, as well as the approved Technical Bulletin. Continue reading
ORA is very pleased to offer our comments on this EBR posting regarding the administration of Section 16 of the Lakes and Rivers Improvement Act (LRIA). However, to our knowledge, no decision has yet been made on the comments ORA submitted in January of 2014, regarding EBR 012-0562, the Technical Bulletins designed to provide guidance for dam location, operation, maintenance, amendments, reporting and approval under the Lakes and Rivers Improvement Act (LRIA). Effective LRIA guidelines and policies are essential to regulating dams and maintaining healthy rivers.
For Immediate Release: 5 November 2015
Hydro Impacts 101 – The Trade-offs
Significant environmental damage from hydroelectric power generation has been ongoing for many decades in Ontario and in other locations throughout the world, yet the public has been led to believe that it provides a clean and green source of energy because there is no smoke, no ash, and no radiation. Indeed, some mistakenly think that all hydro contributes positively to the climate change issue. “This report will help to set the record straight on just how clean and green waterpower really is”, said Linda Heron, Chair of the Ontario Rivers Alliance (ORA). Continue reading
Toxic and nuisance algal bloom occurrences in Lake Erie have increased over the past decade. The blooms threaten drinking water quality, increase costs associated with treatment needs, and occasionally force closures of treatment plants. They clog industrial water intake systems, adversely impact commercial and recreational fishing activities and other recreational pursuits, and degrade fish and wildlife habitat and populations.
Environment Canada solicited input on the draft target recommendations of the Great Lakes Water Quality Agreement (GLWQA) Nutrients Annex Subcommittee from June 30 to August 31, 2015. Following consideration of input received, Environment Canada and the U.S. Environmental Protection Agency will finalize targets by February 2016. Development of binational phosphorus reduction strategies and domestic action plans to meet the objectives for phosphorus concentrations and loading targets in Lake Erie will be developed by 2018.
For more information about the GLWQA please visit Binational.Net(External link).
Excerpt: “Our intention in commenting on these bulletins is to help ensure that waterpower projects developed under the LRIA are not approved until the effects on the environment and aquatic ecosystems are fully identified, understood, and effectively mitigated. It is also vital that the public has a mandated role and a voice in these processes.
It is also disturbing that the MNR is considering all responsibility for fish habitat and fish passage as out of scope, and is divesting its interests by way of these bulletins, with no clear MNR role mentioned, to the Department of Oceans and Fisheries (DFO). This is at a time when the federal government has just announced the signing of a memorandum of understanding between the DFO and the National Energy Board (NEB) to relinquish much of its oversight of fish habitat along pipeline corridors. This news was quietly released just before Christmas, and only highlights the need for the Ontario government to look after its own interests and not rely on federal protection for any of our crown resources. Unfortunately many elements of these bulletins do the very opposite. It is even more disturbing that this deferral was carried out despite the Fish Habitat Compliance and Referral Protocols for Ontario which was approved by government and identifies and enables roles for MNR in the matters of fish habitat and fish passage.
The exercise of reviewing these technical bulletins has been very disturbing to say the least. It is as though the bulletins were written by the waterpower industry instead of MNR. This series of bulletins reflect an abdication of the MNRs responsibilities under the Lakes and Rivers Improvement Act (LRIA).
It is ORA’s view that this government must continue to play a strong role in ensuring effective mitigation of the impacts of development to meet their strategic directions for sustainable development; and certainly that will be what Ontario taxpayers expect. It is vital that these bulletins reflect a commitment for inter-governmental cooperation, in a holistic and collaborative way, to ensure there are no gaps in fulfilling all responsibilities and commitments legislated under LRIA.”