The Ministry of Energy uses…

ERO number

012-8840

Comment ID

4382

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

The Ministry of Energy uses only three criteria when determining where future and current generation facilities will be constructed according to a representative at the November 3rd public consultation session held in Peterborough. The three criteria are: distribution availability, resource availability and those willing to lease land.  According to the same representative, impacts to the environment as well as negative economic, social and cultural impacts on communities that multiple industrial energy generation projects inflict is not the responsibility of the Ministry of Energy.

Over the past seven years, Ontario has signed numerous agreements with energy producers guaranteeing revenue even when energy production has to be curtailed due to environmental conditions or problems with the grid.

There is no land planning consideration or measure of what the cumulative impact will be from hundreds of generating stations plunked helter-skelter across rural Ontario.  It appears the LTEP has no plans to institute energy generation facilities within urban areas where arguably they should be constructed and where there is greatest public support.

To date there are hundreds of industrial facilities dotting the rural landscape across Ontario in various geographic zones and within various ecosystem regions. According to the IESO, as of June 30, 2016 there are 3588 generation contracts without any consideration of their overall impact on Ontario’s landscape; 110 were for large scale wind energy facilities.

According to one media report,  a developer stated that, “ more concrete was poured for the project than was used to build the CN Tower – 36,472 cubic metres, and that  in addition 70 kms of gravel access roads were created and 35 km of new transmission lines. http://www.chathamthisweek.com/2014/06/25/south-kent-wind-project-officially-opens

One of the wind energy projects proposed under the now ‘suspended’ but not cancelled LRP2 program, if approved will cover 12,000 acres. http://www.wellingtonadvertiser.com/comments/index.cfm?articleID=32815

This proposed 63 turbine project covering 12,000 acres on hold until the LRP2 program is re-instituted will have installed capacity of 100 MW which will be produced intermittently. By contrast, the Darlington Nuclear Station which is the second largest energy generating station in the Province creates 3,480 megawatts of carbon-free electricity covering a fraction of land at 480 hectares or 1200 acres.

Over the past 6 years, thousands of letters of objection were sent to various government ministries and both Premiers objecting to the plan to industrialize the Oak Ridges Moraine for 4 large scale wind energy facilities and 1 solar facility. Rural residents and environmental organizations such as STORM (Save the Oak Ridges Moraine) continuously sought to stop the cutting down of over 2500 mature trees along wildlife movement corridors and in designated significant woodlands.    First Nations peoples vigorously sought to protect their traditional hunting and gathering grounds granted under Treaty 20 knowing the plans of the industrial developers include decimating habitat for 12 species at risk, wiping out area raptors and endangering medicinal and food plants including species at risk butternut trees.

The MOECC recognized that the ministry received record numbers of comments of concern and objection posted on the EBR seeking denial of approval of these energy facilities on the Moraine. Additional concerns raised included the planned elimination of savannahs and open country bird habitat, redirecting and preventing and contaminating water flow to trout streams as well as threatening hydraulic connections to designated significant wetlands, the construction of many kilometers of new roads and 1000 ton permanent concrete bases and 30,000 pilings will have on sensitive surface and groundwater resources on the Moraine.  The Cham Shan Buddhists met with the former Minister of Energy Chiarelli  pleading for a halt to the 3 energy projects stating that construction of the industrial energy facilities through visual and noise pollution will prevent the build-out of their unique 100 million dollar project.   Instead, like rural residents and First Nations, the Buddhists were dismissed in favour of providing tens of millions of taxpayer dollars to companies for an intermittent energy source even when not producing energy.

http://www.cbc.ca/news/thenational/buddhist-temple-project-in-rural-ontario-threatened-by-wind-turb ines-1.3655375

The Ontario Energy Board does not have the ability to reject applications based on environmental concerns and the EBR appeal process is cumbersome with an unfair, often untenable burden placed on residents who are faced off against developers with deep financial pockets. Even still there have been dozens of appeals filed which should send a clear message to the Ministry to stop the industrialization of rural Ontario.

The MOECC  (verified by staff) does not look at the cumulative environmental impact of REA applications.

Since O. Reg 359/09 strips municipalities of the ability to determine the suitability or possible locations for industrial development and the ability to veto projects that are determined not to be in the best interest of the community, there needs to be master plan in place similar to the MAH’s Places to Grow Act unfortunately also amended under O. Reg. 359/09 as are 19 other Acts.

•Building Code Act, 1992;

•Conservation Land Act;

•Co-operative Corporations Act;

•Energy Conservation Leadership Act, 2006;

•Environmental Bill of Rights, 1993;

•Greenbelt Act, 2005;

•Ministry of Natural Resources Act;

•Ontario Energy Board Act, 1998;

•Places to Grow Act, 2005;

•Public Lands Act; and•Clean Water Act, 2006;

•Conservation Authorities Act;

•Electricity Act, 1998

•Energy Efficiency Act;

•Environmental Protection Act;

•Ministry of Energy Act;

•Niagara Escarpment Planning and Development Act;

•Ontario Water Resources Act;

•Planning Act;

•Provincial Parks and Conservation Reserves Act, 2006.

I attended one of the LTEP ‘public’ sessions and when suggested the MoE might step back and take a look at the overall picture and the cumulative impact with an eye to sustainable development, I was told by a senior MoE rep that this suggestion would not be taken back to the Minister because this would mean an overhaul of the current procurement system. (so much for valuing public consultation).

While the revised LRP program stipulates the applicant needs to demonstrate that Site Considerations Information is to be collected this is only done by conducting preliminary desktop studies to determine the presence of certain environmental features at the proposed project site. This is meaningless unless there is some veto power from the MOECC and MNRF.  Unfortunately neither the MOECC nor the MNRF has  complete or in-depth data on species at risk. Every developer will argue through their own consultants (on their payroll)there will be no environmental harm no matter where the project is sited even in the most environmentally sensitive lands like the Oak Ridges Moraine.  The MOECC’s role is to expedite the application process (confirmed by staff).

The MoE in consultation with conservation authorities, municipalities, landowners, the MOECC and the MNRF needs to draw out a specific land use map that would organize energy development only into specific areas identified as having the least environmental and least cumulative impact such as brownfields or other such environmentally bankrupt lands.

Continuing on the topic of environmental degradation in the name of energy security, the internet is filled with dozens of media reports of tree butchery and wide-scale poisoning of vegetation by Hydro One and Ontario Land Clearing across Southern Ontario.  Many of the media reports indicate perfectly healthy trees have been mangled and/or cut down without providing any demonstrable measure of increased safety or prevention of power failures. This is a very costly exercise that infuriates the populace and degrades the environment.

All too often the larger picture is lost to tunnel vision focussed on immediate political gains with disastrous results.

The online survey is a terrible disappointment.  The questions are seemingly directed to ‘blame the victim”.  There has been extensive media coverage recently of the financial challenges and heartbreak energy users across the Province face despite doing everything possible to cut energy consumption.  People are going to extraordinary lengths to decrease energy consumption to no effect.

The online survey seemingly directs the current high cost and responsibility of conservation onto the shoulders of consumers instead of re-examining  flawed government policies pointed out by various energy experts over the years and which have continually been ignored.

When energy consumption drops due to conservation, the Global Adjustment fee must be increased to make up the difference. So the less power Ontarians use, the higher their electricity costs must be in order to cover the minimum revenues energy producers are guaranteed.

In addition, consumers like myself are being penalized further being one of the over 50,000 households disconnected from smart meters because Hydro One has difficulty obtaining information. We are paying for these meters that do us no service. We are further penalized by now paying higher utility costs based on usage and a median rate per kilowatt. For those of us who routinely restricted electricity consumption over 80 % of the time to off-peak hours under TOU, we now pay higher bills – why are we being financially penalized for faulty equipment? We are also penalized for living in rural Ontario by paying exorbitant delivery charges.

http://globalnews.ca/news/2808094/sky-high-hydro-rates-an-absolute-crisis-for-rural-ontario/

Ontario government's polling found 94% of residents wanted relief from hydro bills http://www.cbc.ca/news/canada/toronto/ontario-hydro-polling-1.3848893

The temporary offer of an 8% reduction will not fix the long-term problem and ratepayers will have to pay for this reduction in some form.  It appears that the Province is failing to listen to energy experts and the Auditor General and solutions proposed by these external reviewers. Why?

So… what do residents such as I want included in a long-term energy plan?

Recommendations:

1.Provide affordable energy without continual periodic nickel and dime increases that accumulate to much more than the government touted ‘no more than a cup of coffee’ increase especially in rural areas. Delivery charges need to be re-examined and made more equitable.

2. Terminate temporary band-aid reactionary solutions after continual increases exasperate consumers to the point of public outrage; opt instead for a long-term sustainable plan based on the input and modelling from recognized energy experts. Listen to expert opinion – listen to the Auditor General.

2. Those disconnected from the smart meter program will be compensated.

3.The MoE  will step back and engage in a sustainable land-planning strategy and mapping for future energy facilities before any new LRP applications are accepted;  a strategy that considers the cumulative environmental, social, cultural and economic impact on communities first.

4. An end to the needless tree mangling, cutting and poisoning of ground vegetation under the line clearing plan – this very expensive practice has not proven to be effective and is the constant cause of frustration and anger on the part of residents – a different forward thinking holistic strategy needs to be adopted.

5. Concentrate industrial renewable energy projects such as wind and solar in urban and industrialized areas along the Lake Ontario shoreline where both wind and solar resources are optimum and there is public support.

6. Respect First Nations. The LRP application format opens the door to manipulation by developers for projects that are of no actual direct benefit to First Nations communities. First Nations should dictate what is needed to sustainably service their community and then there should be a bidding process and plan to make that happen.

7. Keep utilities in private hands.  Stop the privatization of small utilities as well as selling the remainder of Hydro One… listen to the majority of Ontarians. https://keephydropublic.ca/

[Original Comment ID: 196716]