Overall, the material presented makes clear that the Fund mechanism will make it easier for habitat destruction to occur at the hands of industry and developers. Indeed, according to the proposal the main purpose of the Fund is to give operators a quicker and less cumbersome alternative to completing actions to provide an overall benefit for the species negatively impacted by their activities. The Fund is a part of a package of damaging amendments to the Endangered Species Act, 2007 (ESA), passed in June 2019 that, taken together, represent a gross weakening of the ability of the Act to fulfill its purpose to recover Ontario’s at-risk species. Our primary concerns with the Fund are outlined below.
Bill 229 is just the most recent in a long list of omnibus bills containing devastating amendments, exemptions and streamlining of key environmental policy and legislation designed to protect our environment and communities and provide the public and stakeholders with meaningful input. These government actions have created a deep erosion of public trust and confidence. It is unacceptable that it would mislead its citizens and bypass the norms by taking advantage of a world-wide health emergency to aggressively push their destructive agenda through.
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.
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 effects of dams and hydroelectric facilities on fish populations and fisheries have been well documented over the past century and include the loss or serious decline of many iconic fish species, which are resources of importance to Ontario’s economy, biodiversity, and natural and cultural heritage.
Since 1963 the Little Long Generating Complex on the Lower Mattagami River in Northern Ontario has been the source of an environmental crisis of immeasurable proportions. Thousands of Lake Sturgeon have been entrained through spillway gates and left stranded waiting to be captured and relocated back to their adopted man-made habitat, leaving waters not fit for survival. Adam Creek Spillway is well known province-wide as a thorn in hydro electric energy and should not be defined or qualified as GREEN energy.
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.
Peaking operations, with the variable flow discharge and ramping patterns, the rate and frequency of water level changes, and the amount of time the station is at its maximum discharge level, can all have a significant impact on the degree of channel and bank erosion.
The full Capital and Life Cycle Costs of Rebuilding Riverside Dam were not realistically represented in the ESR and could well end up costing the taxpayers more than double what was presented to the public and City Council. A Rebuilt dam would be considered a new dam, not a repair or expansion of an existing weir, with an assessed High Hazard Potential, and is located within the City of Cambridge in a location that could place multiple residences and businesses at risk in the event of severe flooding or a dam breach. ORA and Partners submit that this Project goes far beyond the screening process provided by a Schedule B, Class EA. Consequently, we submit that this is a major project that should fall into a higher level of assessment.