Wherever water levels have been lifted from their former undeveloped elevation must be considered the full extent of the reservoir/s. This crucial detail is not set out in the ER; however, the full extent of the cascading facilities must be considered when detecting, measuring and reporting total GHG emissions (CH2, CH4 and N2O). This cascading system creates one very large artificial and ongoing multi-level series of reservoirs that are highly regulated through the WRWMP, and likely very high in GHG emissions.
Category Archives: Water Quality
Hydroelectric and its “Pathway to Decarbonization”
Please sign and share our Petition: Hydroelectric is NOT a Pathway to Decarbonization.
The increasing role of hydroelectric reservoirs as GHG emitters and negative environmental effects has resulted in thousands of independent peer-reviewed studies laying out the facts. However, the hydropower industry and governments have done a thorough job of promoting waterpower through a powerful disinformation campaign to mislead the world into believing it is clean and non-emitting while turning a blind eye to the growing body of evidence to the contrary.
ORA strongly recommends that OPG begin the use of drone technology to detect, map and measure GHG emissions within the entire zone of influence of its hydroelectric facilities – in the upstream reservoir, turbine intake, spillway and downstream of the dam. This will ensure that those who have purchased clean energy credits from OPG are getting what is claimed – a clean and non-emitting source of electricity. All data should be placed in real-time on the OPG website and made available to researchers and the public.
In closing, the ORA requests that the Minister finally remove the label of clean and non-emitting from hydroelectric generation. Certification will mean nothing if there is no authentic and verifiable science-based method of reducing Ontario’s GHG emissions. Furthermore, it would be unethical and fraudulent to mislead the public and corporations into believing they are paying for clean and non-emitting electricity when they are actually paying to fuel climate change.
Ministers Guilbeault and Duclos: Expand the single-use plastic ban – Joint
We, the undersigned organizations and individuals, are deeply concerned about the plastic waste and pollution crisis and its devastating impacts worldwide. As responsible ministers for the Canadian Environmental Protection Act – “an Act respecting pollution prevention and the protection of the environment and human health”, we urge you to take bolder and urgent action to tackle the crisis by expanding the single-use plastics ban to include a more comprehensive list of problematic plastics and substances.
Hydropower is destroying our rivers, biodiversity and fueling Climate Change
Dams and hydropower facilities harm the environment and, when headponds or reservoirs are flooded, can produce carbon dioxide and methane for the life of the dam. Ontario is about to embark on a whole new era of dam building. Ontario has 224 operating hydropower plants and only 3 with fish passage.
By the way, Ontario Power Generation has been selling Clean Energy Credits for hydroelectric since 2013.
NO MORE NEW HYDROELECTRIC DAMS IN ONTARIO!!
ERO-019-6177 – Review of A Place to Grow and Provincial Policy Statement
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).
ERO-019-6160 – Proposed Updates to the Ontario Wetland Evaluation System – Joint
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.
ERO-019-6141 – Legislative & Regulatory proposals affecting Conservation Authorities
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?
 Protecting People and Property: Ontario’s Flooding Strategy, 10 March 2020. P-7/42
Bill 23 – ORA Comments to the Standing Committee on Heritage Infrastructure and Cultural Policy
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.
Environmental Compliance Approval Number 7877-CALRZU – Erin Water Resource Recovery Facility – Joint
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.
Hydroelectric Program Development and Assessment – IESO Small Hydro Program
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.