Dear Sirs and Madam: I am…

Dear Sirs and Madam:

I am writing to express my concerns over the proposed Omnibus Bill 132, which would make multiple cuts to 14 different Acts reflecting legislation across several Ministries. The proposed changes in the Bill are sweeping and its potential consequences are highly concerning.

I am strongly opposed to the proposal to exempt waterpower from the requirement to obtain a Permit to Take Water (PTTW) under the Ontario Water Resources Act; as well as the proposal to transfer authority over to the Ministry of Natural Resources and Forestry to make a regulation to assess and monitor methylmercury. Methylmercury is just one aspect of the full protections that a PTTW provides, so I find this unacceptable.

Why should the government cut "red tape" so the waterpower industry can reap bigger profits at the expense of the environment and communities? Ontario needs sustainable development where industry has to answer for their pollution and damage to the environment, and where pollution is prevented instead of trying to clean it up or rehabilitate after the fact. Ontario needs to ensure the health and resilience of our freshwater lakes and rivers through sustainable use and science/based monitoring and reporting.

The Ministry of the Environment, Conservation and Parks (MECP) is an independent agency that administers a PTTW with the responsibility to ensure the fair sharing of water, that there is enough water available for aquatic ecosystems and for other water users. It requires annual monitoring and reporting to ensure water quality and water quantity, proper mitigation of any impacts, and a review every 10 years. A PTTW also provides an appeal process, proper engagement opportunities for stakeholders and a Duty to Consult with Indigenous peoples.

With 224 hydroelectric facilities and many more associated control dams, the environmental, social, cultural and economic impacts of this proposal would be widespread and significant. The MECP has the specific experience and mandate to manage water quality and water quantity as set out in their Statement of Environmental Values. It is important that key water protection policy is not fragmented by having more than one ministry responsible for this important oversight, and that the responsibility remains solely with the MECP.

I respectfully request that you reject the proposal to exempt waterpower from the PTTW program and that the MECP continue to require hydroelectric facilities to obtain a PTTW under the OWRA. I also request that you undertake meaningful consideration of the environmental concerns and recommendations of other organizations and individuals on all aspects of Bill 132. Thank you!

Strengthen environmental protections and make polluters pay!