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.
Canadian Environmental Law Association (CELA) has prepared the following analysis and recommendations in response to the four above-noted Environmental Registry of Ontario (ERO) notices, which propose dramatic changes to Ontario’s permit-by-rule framework. The undersigned environmental, conservation, and civil society organizations have endorsed CELA’s submission. Collectively, it is strongly recommended that the Ministry of Environment, Conservation and Parks not move ahead with the four proposals…
We are willing to meet and discuss CELA’s submission at your convenience.
Presented at ORA’s Annual General Meeting by Dr. Frederick Schueler and Aleta Karstad:
Actually, this government does not deserve the trust of its constituents because it has eroded all of our environmental protections and public engagement and consultation in related policy and legislation over the last 5 years. Therefore, when it claims that “the intention is not to fundamentally change the underlying rules but rather to clarify their source and application”, it is unbelievable – no longer credible – trust has been lost. Especially since this proposal and the entire Build More Mines Act, 2023 was a total gutting of the Mining Act.
While streamlining mining legislation and policies can bring about certain benefits such as increased efficiency and reduced bureaucracy if done correctly; excessive streamlining without adequate safeguards can impact the environment, communities and even the long-term sustainability of the mining industry. It will also lead to environmental degradation, community displacement and conflicts, social and economic imbalances, and undermine public trust with the lack of transparency and accountability.
To avoid these negative consequences, it is essential to strike a balance between streamlining mining regulations for efficiency and ensuring that there are robust environmental, social and legal safeguards in place. Proper consultation with local communities, adherence to international best practices and strict enforcement of responsible mining standards are crucial for achieving sustainable and responsible mining practices. This is not the case with any of these amendments.
Consequently, ORA rejects this proposal to streamline the Regulation.
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.
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.
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.
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.
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.
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.