Removing the requirement for…

Removing the requirement for waterpower facilities to attain a Permit To Take Water with the stated reason of duplication in the approvals is actually a gift for industry and ignores the best technical advise of water power experts inside and outside of both ministries that are unaffiliated with the industry. Unfortunately there are many areas where the Permit To Take Water and the Lakes and Rivers Improvement Act are not duplicative. will MNRF improve programs under LRIA with additional funding?

The health of biodiversity and endangered or threatened species should be a priority even when they are located out of the public eye. The high level of risk this proposal would be to some of the last undeveloped places in Ontario cannot be underestimated. Ontario should be protecting these ecosystems for future generations and not exploited for short term gains of one industry.

Water Management Plans do not incorporate controls for Ramping (rapid rates of change of water flow through turbines) and Peaking (operating a facility so water is released in relation to energy demand). These operational methods increase energy production but can have catastrophic to water dependent ecosystems. For these types of facilities, the Permit To Take Water includes conditions of approval to restrict peaking and ramping while still allowing the facility to meet peak power demands. The Lakes and Rivers Improvement Act approvals do not capture these type of day to day rapid changes in water release.

Protecting critical ecosystems and biodiversity while maintaining steady water levels in the reservoir and downstream should be a priority when updating approvals and plans under the Lakes and Rivers Improvement Act (for more information on ramping and peaking effects on ecosystems see https://www.hydroreview.com2009/07/01/flow-management-studying-ramping-….) How will MNRF Approvals under the Lakes and Rivers Improvement Act incorporate restrictions on rapid changes in lake water levels and stream flows downstream of the dam?

The majority of dam operating plans and water management plans do not include a minimum downstream river flow that considers the ecosystem needs and downstream water users. How will Approvals under the Lakes and Rivers Improvement Act consider downstream ecosystem and water user needs?

Where are the opportunities in LRIA for regular periodic public engagement? The Permit To Take Water process provides concerned citizens and Indigenous communities the right to appeal a Permit To take Water decision to the Environmental Review Tribunal. How will the public be notified of changes to a waterpower facilities operation and how will the public be engaged?

How will MECP verify commitments made by the water power industry in a Class Environmental Assessment are being implemented? Since MECP can not approve a Class Environmental Assessment for waterpower, commitments and refinements related to water quality, zone of influence, reservoir water levels, downstream river flows, as well as public and indigenous engagement are often left to the Permit to take water to enforce. If the these facilities not longer require a Permit to take water MECP should revise its Class Environmental Assessment process to include the ability to track the implementation of commitments made during the planning stage of building, repairing or expanding water power facilities.