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.
Learn more about how dams affect fish populations through this short video! 🐟
This closed-loop pumped storage Project does not seem likely to result in any serious negative impacts to other freshwater bodies, nor methylmercury contamination of fish tissue or greenhouse gas emissions, and it will provide clean backup power during the low-flow periods when small run-of-river hydroelectric facilities are shutting down because of reduced stream flow. Comparing the power output of this peak demand storage Project, and its minimal environmental impacts to the number of rivers it would have taken to generate 400 to 500 MW of power from dozens of small hydropower projects, makes it ORA’s preferred choice over conventional hydroelectric facilities.
Update: The Upper Thames Conservation Authority went with the most popular, Alternative #4, which is to construct a naturalized channel with offline ponds/wetlands – see photo above.
There are very few thriving Brook Trout populations left in southern Ontario, and it is especially surprising to find them present as far south as London, Ontario. Brook Trout are a sentinel species – the canary in the coal mine. In southern Ontario, Brook Trout populations have seen an 80% decline in their numbers over the last 50 years. Their populations have been under increasing pressure from a warming climate as well as agricultural, urban, rural and industrial development.
Removing the Dam and headpond to create a free-flowing and healthy coldwater Brook Trout fishery would be the perfect place for a family to go for walk, play or picnic in the Embro Conservation Area. It would provide a healthy riverine ecosystem and a beautiful natural environment for the entire community to enjoy!!
The province claims that “Ontario needs more housing, and we need it now. That’s why the Ontario government is taking bold and transformative action to get 1.5 million homes built over the next 10 years.” This Environmental Registry of Ontario (ERO) posting is only one component of a large series of other interconnected ERO postings relating to Bill 23. Due to the short comment period at this busiest time of year for such a complex, vague, poorly considered, and destructive policy and legislative “streamlining”, it is impossible to fully understand the full scope or depth of resulting effects to provide any kind of meaningful input. It is crucial that all ERO postings are well planned, concisely written and defined in clear policy language so the public fully understands what is being proposed and its potential positive and negative effects.
The Ontario government, through Bill 23 and its multitude of complex and interconnected legislation and policy amendments, has:
- Removed municipal jurisdiction from upper-tier municipalities to make policy decisions on land use planning matters that are based on local community interests.
- Removed a significant financial source (permits/building fees) in which to help pay for water and wastewater services, sewers, transportation infrastructure, and community parks needed to service 1.5 million additional homes.
- Prohibited Conservation Authorities all across Ontario from providing practical advice to municipalities, their ability to issue permits, or provide input into environmental concerns.
- Failed to provide adequate public and Indigenous consultation relating to Bill 23 matters.
- Is proposing to streamline the qualifications program for Building Practitioners (ERO-019-6433).
One prime example of ecosystem services is our fisheries which depend on strong and healthy ecosystems. In 2015 the Ontario Government launched a Provincial Fish Strategy – Fish for the Future, which indicated that Ontario’s recreational fisheries support robust sport fishing and tourism, which are a mainstay for many of the northern communities. It also reported that 1.5 million anglers spend $1.75 billion dollars in the province each year, supporting approximately 1,600 resource-based tourism businesses each and every year.[i] These are just a fraction of the ecosystem services that must be weighed against the full life cycle costs and benefits derived from any project that will impact our wetlands, wildlife, air, land or water.
We are a coalition of Indigenous Peoples and conservation and environmental non-governmental organizations concerned with the conservation of American Eel and write to ask that the Department of Fisheries and Oceans take all necessary steps to immediately list this important species under the Species at Risk Act (SARA).
First, the Coalition for the West Credit River (Coalition) would like to express our deepest appreciation that you and your staff worked with our Technical Team over the last several months to incorporate some of our recommendations into the Environmental Compliance Approval (ECA). However, we are concerned that our key recommendations for improvements to the draft ECA, received by you on 2 May, were not reflected in the ECA approved on 3 May 2022.
The Coalition is very appreciative of your strong support in recommending to the Honourable David Piccini, Minister of Environment, Conservation Parks (MECP) and Mayor Allan Alls, Town of Erin, that our draft Monitoring and Adaptive Management Plan be integrated into the Environmental Compliance Approval (ECA). As you are likely aware, the ECA for the Erin Water Resource Recovery Facility was approved on 3 May 2022 by Aziz Ahmed, P.Eng., MECP Manager of Municipal Water & Wastewater Permissions, appointed for the purposes of Part II.1 of the Environmental Protection Act.
The Agency has deemed the Project to be within federal jurisdiction and required it to undergo a federal Impact Assessment, and yet Agnico Eagle (AE) is planning to move forward with their advanced exploration as soon as weather permits. ORA objects to the Project moving forward with any advanced exploration activities that would result in any damage to the environment.
AE boasts about setting the “gold standard”, “for over 60 years Agnico Eagle has been attracting investment to Canada, from those who seek a mining company committed to make mining work better for communities, shareholders and the planet”. ORA submits that Stakeholders expect AE to set the “gold standard” on this Project by undertaking the most environmentally and socially rigorous, advanced and responsible project “for communities, shareholders and the planet”.  Agnico Eagle Twitter Posting, 22 November 2021
ORA comments requesting a federal review under the Impact Assessment Act, 2 October 2021.
Upper Beaver Gold Project – IAAC Portal.