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Category Archives: Rivers at Risk

American Eel: Consultation check-in on listing under the Species at Risk Act (SARA) – Joint

American Eel

Like Pacific Salmon in the west, American Eel are critically important to Indigenous Peoples in eastern Canada – culturally, spiritually, and for food security. Unlike Pacific Salmon, however, little has been done to address their decline. Despite being assessed as Threatened by COSEWIC in 2012 — more than a decade ago — the species is not yet listed and consequently there is no recovery strategy in place directed at stemming further population decline or contributing to the recovery of this species. The need to implement recovery is urgent given the recent and rapid decline of American Eel in Canada and globally, including a 99% decline in the Upper St. Lawrence population. The decision on whether to add the American Eel to Schedule 1 of the Species at Risk Act has been delayed for far too long. This delay has hindered conservation efforts and the creation of meaningful partnerships to advance the recovery of American Eel.

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IESO Long-Term 2 RFP Engagement – April 4, 2024

The Chute, First Falls, Ivanhoe River – Photo by Mark Clement

Unfortunately, the hydropower industry, as well as all levels of government, have ignored the extensive body of evidence compiled over the last few decades, indicating that hydroelectric reservoirs contribute approximately 5 to 7% of global GHG emissions that, individually, can rise to the level of a gas-fired facility. Instead, the industry and this government greenwash it with disinformation by labelling it as non-emitting, low-emitting, clean or renewable to mislead the public into believing it will cut GHG emissions when, in fact, it will be adding significantly to global emissions until the dam is removed.

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Provincial Action on Road Salt Pollution of Aquatic Bodies – Sign our Petition

Road salts represent the largest source of chloride inputs into Ontario waters. Ontario makes up less than 11% of Canada’s landmass, but it is the biggest user of road salts in the nation. Your Ministry’s scientific data shows conclusively that salt has been and continues to be a threat to aquatic ecosystems which is increasing in magnitude over time.  SIGN OUR PETITION HERE!

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Feedback on the IESO Resource Adequacy and Long-Term 2 RFP Engagement

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.

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ERO-019-6951, 6963, 6928 & 6853 – Proposed Streamlining to Permit-by-Rule, Waste Management, Stormwater Management and Site Dewatering Activities – ORA Support

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.

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ERO-019-7598 – Proposed Regulatory Amendments to the Build More Mines Act, 2023

“Open-pit Cppper Mine – Mission Complex” by docentjoyce is licensed under CC BY 2.0.

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.

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Marmora Pumped Storage – Clean Energy Hub Project

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.

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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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