As you know, the OWES is a science-based ranking system that provides a standardized approach to determining the relative value of wetlands. OWES assessments are necessary to designate Provincially Significant Wetlands (PSWs). This designation in turn results in a high level of protection under provincial law and policy such as the Provincial Policy Statement (sections 2.1.4, 2.1.5 and 2.1.8). Yet the complete overhaul of the OWES, as proposed, will ensure that very few wetlands would be deemed provincially significant in the future and that many if not most existing PSWs could lose that designation. As a result, very few of Ontario’s wetlands would benefit in the future from the protection that PSW designation currently provides. We urge you not to proceed with the proposed changes to the OWES, for the reasons outlined below.
The Ontario government’s own 2020 report, “Protecting People and Property: Ontario’s Flooding Strategy,” which resulted from the 2019 flooding disaster, states very clearly that “Flood risk management is achieved through multiple provincial acts, regulations, policies and technical guides and a wide range of provincial programs and services. Successful implementation relies on partnerships between provincial ministries, municipalities, Indigenous communities, conservation authorities, stakeholder organizations and the federal government.” 1
Instead, this proposal seeks to do the very opposite. It proposes to exempt the CAs from their authority under ten crucial Acts and their associated regulations; it blocks the CA partnership with municipalities and stakeholders and takes the authority of CAs away from permitting so they cannot properly fulfill the recommendations of this report that was commissioned by the Ontario government only a few short years ago. Now, where is the wisdom in that?
The ORA is concerned that Bill 23 will have far-reaching negative effects on the environment and communities. This major streamlining of development is irresponsible and a recipe for disaster. Bill 23 works against sustainability and the watershed approach at a time when Government decision-making should be focused on protecting the environment and building climate resilience into Ontario’s communities and infrastructure.
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.
First, it was enlightening to be provided with a clear definition of small and large hydro facilities in the Hydroelectric Program Development and Assessment webinar, as well as a total amount of power generated by these categories. You informed that the definition of small hydro would have a scope of installed capacity of 10 MW and under, with 30 companies representing 50 facilities generating a total of 120 to 150 MW, and large hydro having a scope of installed capacity of over 10 MW, with 3 companies representing 22 facilities producing a total of 1,000 MW.
The increased number of small hydro facilities making such a small contribution to our electricity grid impacts on multiple Ontario riverine ecosystems, whereas the 22 facilities producing 1,000 MW of power on presumably fewer rivers has a much lower trade-off value. Additionally, larger rivers have a greater capacity to buffer some of the worse effects of hydroelectric.
The ORA is in full agreement that Low Impact Development (LID) must be a priority in development planning guidance for stormwater management practices and should include innovative green infrastructure such as rain harvesting, rain gardens, green roofs, urban trees and forests, permeable surfaces, ditches, swales, stormwater catchments, and must emphasize the protection of wetlands.
When people refer to hydroelectric as clean, it’s usually in the context of GHG emissions; however, governments and utilities often use the term categorically and without caveat or qualification. Using the word “clean” in this context is misleading. Just because hydroelectric facilities are not spewing out smoke does not mean they are clean or renewable. In fact, waterpower has resulted in significant and ongoing impacts on water quality, water quantity, ecological processes, fish and wildlife populations and habitat, and to aboriginal communities. Hydroelectric also makes a significant daily contribution to the earth’s accumulation of greenhouse gases (GHG) in our atmosphere.
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.
The ORA is very supportive of policy and legislation that provides an ecosystem approach for planning at a watershed and subwatershed scale. It is essential that we ensure a healthy environment, with clean and abundant freshwater resources, that helps to provide resilience to the extremes of climate change. We are appreciative of the information webinar on the Subwatershed Planning Guide, and the 45-day comment period.
Overall, we are generally supportive of the draft guidelines as they seem broad ranging and comprehensive. We are especially pleased to see the partnership approach with Indigenous peoples included in the Guide and agree that this approach will lead to a much more comprehensive subwatershed plan.
Hydroelectric is not emission-free or clean. A Washington State University study on the effects of damming conducted in a central European impounded river revealed that the reservoir reaches are a major source of methane emissions and that areal emission rates far exceed previous estimates for temperate reservoirs or rivers. It showed that sediment accumulation correlates with methane production and subsequent ebullitive release rates. Results suggested that sedimentation-driven methane emissions from dammed river hot spot sites can potentially increase global freshwater emissions by up to 7%. Hydroelectric facilities need to acknowledge and account for the associated GHG emissions they produce.
 Maeck, A., DelSontro, T., McGinnis, D.F, Fischer, H., Flury, S., Schmidt, M., Fietzek, P. and Lorke, A., 2013. Sediment Trapping by Dams Creates Methane Emission Hot Spots, Environmental Science and Technology, 8130-8137, Online: http://www.dx.doi.org/10.1021/es4003907