As a professional who has…

As a professional who has worked for MECP, MNRF and now as an Environmental Consultant supporting the development, maintenance and upgrades of waterpower facilities; it is obvious that an operational site is not taking water from a natural source for use other than diverting the watercourse for the sole purpose of generating renewable energy. Therefore the requirement for a PTTW in addition to the approved plans and specifications as part of the Lakes and Rivers Improvement act is a redundancy in the permitting process and adds additional strain to MECP in an already delayed approval process.

After careful consideration of the development projects and PTTW considerations, the seepage water which has historically required a PTTW to return the seepage to it's natural source is also a redundancy in that the water is returned to it's natural source and an ECA addresses the treatment process and tracking of dewatering activity via metered pumping providing MECP with water quality and quantity records.

Furthermore, each construction and development phase requires a Plan to be approved by MNRF prior to commencement which allows adequate control and opportunity for MNRF to address additional water related concerns.

Overall, we support the proposed Waterpower Exemption to the PTTW for development and operations as diversion and water quality and quantities are accounted for in the LRIA and ECA process with monitoring and impact mitigation addressed during the EA and consultation.