Our concerns are well documented in the attached Briefing Notes report, which has been prepared by our Coalition in the process of requesting a federal review under the Impact Assessment Act.
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.
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
With climate change impacts bearing down on us, decision makers have a responsibility to ensure the resiliency of our freshwater resources. If this proposal moves forward it will be a precipitous turning point for our future with freshwater in Ontario and beyond.
Since this project was first proposed, a large percentage of the community of Bala Falls have been opposed to it. Citizens have lobbied, marched, picketed, petitioned and railed against this abomination being built in the heart of their town. Immediately downstream of the dam is a favourite public swimming and picnic area that draws local residents and tourists from far and wide. This project will pose a public safety risk; however, there is no Public Safety Plan – it wasn’t included in the initial Environmental Report, nor was it adequately addressed. It was unacceptable in 2012, and it’s still unacceptable – it should never have been approved in the first place.
CELA stresses that, regardless of whatever water charge is required to recover actual management costs, the amount of water that is available based on long term sustainability and other goals such as meeting population growth targets, ensuring climate change resiliency, and realizing benefits to future generations is finite. As such, simply recovering the province’s water management costs must not be used as the determinant as to whether a water permit ought to be issued or a specific water use ought to be prioritized. Second, while not directly related to the new proposed charge, we believe our general comments and recommendations discussed above are important considerations to ensuring the aims of the water charges program are met.
Thank you for taking the first step toward protecting Ontario’s groundwater, and for putting the needs of communities before the profits of water bottlers. We support the proposed two year moratorium on the issuance of new or increasing permits to take water for water bottling, and are encouraged by the proposal’s stated purpose:
This would allow time for the Ministry [of Environment and Climate Change] to undertake a comprehensive look at our current understanding of Ontario’s groundwater resources and the rules that govern water bottling facilities that take groundwater.
ORA strenuously objects to a PTTW being issued to Nestle, on either a temporary or a permanent basis, for the extraction of water in Elora, or anywhere else in Ontario. Water from aquifers, rivers or lakes is an essential public commons that must not be privatized, or allowed to be extracted for the purpose of private profit or shareholder earnings.
Extracting up to 1.6 million litres of water each day could place water supply to communities and individuals living within the surrounding area at risk. The Mayor of Elora and many of its residents have already expressed their concerns and objections to this ill-conceived proposal to allow a global conglomerate to profit from a resource that must be protected as a public trust. It is incumbent upon the Ministry of Environment and Climate Change to protect the interests of its citizens and this essential water supply.
Namewaminikan Hydro (NH) is proposing to develop the Namewaminikan Waterpower Project (NWP), which consists of two “run-of-river” hydroelectric generating stations on the Namewaminikan River. This river is essentially located in the municipality of Greenstone and runs north of the community of Beardmore, Ontario. The sites to be developed are called Long Rapids and Twin Falls. The Long Rapids station will generate 5.6 megawatts (MW) of hydroelectric power whereas the Twin Falls station will produce 4.4 MW, for a project total of 10 MW.
The project will require the construction of a new 34.5 kV powerline. This line will bebuilt along existing roads and along the High Falls powerline over a distance of approximately 22 km.
A Feed-In-Tariff (FIT) contract for 40 years of electricity purchase was signed with the OPA in April 2010. The construction schedule was produced taking into consideration restrictions related to clearing, instream works and moose calving activities.
Construction is planned for summer 2012, whereas commercial operation is scheduled for fall 2014. More information here.
A Permit to Take Water has been applied for and is open for comment under an EBR 012-1976 until 19 July 2014.