2011, September 22:
The CEAA, 4.(2) states, “In the administration of this Act, the Government of Canada, the Minister, the Agency and all bodies to the provisions of this Act, including federal authorities and responsible authorities, shall exercise their powers in a manner that protects the environment and human health and applies the precautionary principle.”
Four Slide GS Environmental Assessment Report is incomplete as there are still field studies to be completed, and public consultations that must take place, before approval should be granted. For the many reasons listed above, this type of “modified peaking run-of-river” hydro-electric dam is very harmful to a riverine ecosystem, both upstream and downstream; and when you have two or more dams on one river, the negative cumulative effects are only amplified, and must always be considered together as one.
In order to meet the intent and spirit of the Canadian Environmental Assessment Act and the Ontario Environmental Assessment Act, the ORA requests that Xeneca meet their legal obligations under this legislation, and address the proposed Four Slide Falls GS, and McCarthy Chute GS, under one Environmental Assessment Report, and also take into account the existing Camp Lake Serpent River GS and Serpent River First Nation GS.
The cumulative effects of all facilities, water management practices, roads, transmission lines, diversions, as well as all resulting “Identified Residual Effects”, must be considered with a precautionary approach in order to protect the well-being of the Serpent River community, the environment, and the riverine ecosystem; and to comply with the EAA and the CEAA. These types of proposals must not be fast tracked, or policy and procedure skipped – there is too much at stake!
The experience of the ORA and the public in our dealings with Xeneca, has been challenging to say the least, and yet we have asked Xeneca to show their willingness to be cooperative by providing the ER reports in an unsecured format to aid in our commenting. However, not only have unsecured documents not been provided, but shortly after ORA informed Xeneca of our intent to comment on the Four Slide Falls GS ER, Xeneca demonstrated its unwillingness to cooperate by withdrawing information from the Serpent River ER. Appendix D and E were removed from Xeneca’s website and replaced with reduced versions, where
- Appendix D, Public Consultation – Xeneca removed 78 pdf pages; and
- Appendix E, Aboriginal Consultation – Xeneca removed 38 pdf pages.
Profits should never be maximized at the expense of the health and well-being of the community, or the riverine ecosystem.