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.
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.
The City of Cambridge is moving forward on a detailed design plan of the new rebuild of Riverside Dam on the Speed River. Construction is planned for 2022 and work set for completion in 2023. Meanwhile, the full price tag won’t be known until the dam’s design plan has been finalized. This dam has been determined to be at “high risk” of failing within the next 2 to 10 years.
ORA worked extensively towards the decommissioning of this dam. Removing the dam would have been much cheaper, safer and healthier for the riverine ecosystem.
Riverside Dam construction delayed to 2022 with higher price tag, CBC News, 8 Sept 2020
Cambridge Council gives go-ahead to plan for Riverside repairs, CTV News, 8 Sept 2020
Ontario has hundreds, if not thousands of dams that are unsafe and no longer serving any useful purpose. These dams are blocking fish passage, degrading water quality, fragmenting habitat, threatening species at risk and sensitive cold water species. ORA is working to take them out. Check out this excellent overview of the problems with hydropower:
On September 28, 2018, you requested, on behalf of the Ontario Rivers Alliance and other partners, that the City be required to prepare an individual environmental assessment for the replacement of Riverside Dam. I am taking this opportunity to inform you that I have decided that elevating the project to an individual environmental assessment is not required.
Join ORA and partners in a project to improve a coldwater Brook Trout fishery and habitat in Hanlon Creek. These Brookies will be jumping for joy when this project is done!!
On 23 – 24 June of 2017, the upstream Gorrie Dam failed and the Howson Dam was at capacity during an extreme rain event and flood when 175 mm of rain fell in just 7 hours, placing more than 150 property owners at risk and resulting in an estimated $11-million in damages in the Town of Harriston. This severe rain event broke previous records by approximately 40% and was the second highest flow on the North Maitland in the 48 years of record. Fortunately, no one was killed; however, it could have been much worse, as in October of 2015, when a South Carolina flood breached 18 dams, and resulted in 16 deaths.
Since last December, it is difficult to recall a week that has gone by where some sort of new major twist hasn’t happened with this story. Late in 2015, the Thames River Anglers Association (TRAA) and the Ontario Rivers Alliance (ORA) brought together a coalition of 20 different organizations, representing over 250,000 members, to jointly sign on to two letters sent to the City of London’s Mayor and Council requesting decommissioning. Continue reading