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Category Archives: Rivers at Risk

ERO-019-6647 – IESO Pathways to Decarbonization Study

Greenhouse Gas Emissions from Reservoirs

The ORA will never be in favour of streamlining the regulatory, approvals and permitting processes as they were put in place to protect our natural environment and communities, and have already been significantly undermined.

Instead, we need strong and rigorous environmental assessment and robust public, Indigenous and stakeholder consultation if we are to build climate resilience into our air, land and freshwater resources.

I will briefly address my rationale and the dangers of streamlining the regulatory regime of hydroelectric facilities in particular, as it is commonly claimed by governments and industry to be ‘clean’, ‘green’ and ‘non-emitting. However, this is misleading the public at a pivotal time when we should be following the science.

Related Information:

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Bill 71, ERO-019-6715 – Proposed Building More Mines Act, 2023

Re:  Bill 71
        ERO-019-6715 – Proposed Building More Mines Act, 2023
        ERO-019-6749 – Consequential administrative amendments under the Mining Act
        ERO-019-6750 – Proposed regulatory amendments to closure plan and rehabilitation

A very disturbing reality has been revealed, that this government is clearly moving away from evidence-based decision-making that is grounded in science and, instead, is moving fully into a total lack of regard for environmental and stakeholder protections, and Indigenous treaty rights. This government is going too far in its efforts to cut red tape and deregulate environmental protections in Ontario.

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Hydroelectric is not a Pathway to Decarbonization or Net Zero

Dear Ministers Guilbeault, Wilkinson and Champagne,

ORA understands the urgency in fulfilling the vitally important commitment the government has made to cut GHG emissions to 40-45% below 2005 levels by 2030; however, we will present evidence from independent third-party peer-reviewed studies indicating that an effective path to decarbonization is not through hydropower.

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2023 Annual Acquisition Report – ORA Feedback

Big Falls, Trout Lake River

There are currently three pumped storage projects going through the planning and approvals process, that would add approximately 2,000 MW of electricity to the grid. Developing that same Installed Capacity from small hydroelectric projects would involve 200 – 10 MW proposals that would cause untold environmental damage to dozens of Ontario rivers.  It is imperative the province does not rush or over-reach its targets and develop new electricity projects unnecessarily.

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OPG: Proposed Coniston Generating Station Life Extension Project Environmental Report

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.

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Hydroelectric and its “Pathway to Decarbonization”

Abitibi River – Twin Falls GS

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.

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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

Photo by Al Oman

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).

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Environmental Accountability in Ontario – Consultation Paper

Big Falls – Victory – stopped a proposed hydroelectric project on a sacred site!

The current government has gutted multiple key pieces of environmental legislation and policy that have taken decades to assemble. We are in a perilous state now where the requirement to consult with the public and Indigenous communities has been minimized, and the red tape cutting has gone to such extremes that public health and safety and the natural environment will be at increased risk as the climate continues to warm. 

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ERO-019-6141 – Legislative & Regulatory proposals affecting Conservation Authorities

“Consider This” by Storm Crypt is licensed under CC BY-NC-ND 2.0.

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?

[1] Protecting People and Property: Ontario’s Flooding Strategy, 10 March 2020. P-7/42

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