SUBJECT: Environmental…

SUBJECT: Environmental Registry Posting - IESO Pathways to Decarbonization Study
ERO 019-6647
Thank you for the opportunity to provide input and advice on the Environmental Registry posting
regarding the IESO’s Pathways to Decarbonization Report (P2D). By way of introduction
Biigtigong Nishnaabeg, owners of Kagiano/Twin Falls planton the Kagiano River, major partner
of the Umbatta Falls plant on the White River, and benefactor to the Wawatay Plant on the
Black River. As well as other potential hydroelectric opportunities within our traditional territory.
As such, we are pleased to see a specific reference in the posting to Ontario Power
Generation’s “Northern Ontario Hydroelectric Opportunities” Report (NOHO). In our view, taken
together, these reports and the government’s policy response can and should provide the basis
for strategic and sustained investment in realizing the province’s waterpower potential in the
immediate, near and long term.
Our comments on the posting are as follows:
1. Realizing the potential of new hydroelectric generation in Ontario.
Biigtigong Nishnaabeg, supports the development of new hydroelectric generation in
Ontario by private, Indigenous, municipal and government-owned developers as well as
partnerships between the range of owners. This range and diversity of ownership is already
the case for Ontario’s 224 existing hydroelectric facilities and is a core strength of the
industry in the province. Ontario’s heritage hydroelectric fleet moderates electricity prices
today and the planned and predictable addition of new hydro (expansions, upgrades,
retrofits and greenfield) will have the same effect for decades to come.
Importantly, new investment in “Made in Ontario” hydroelectricity – already the backbone of
system reliability – is investment that stays in communities, regions, and the province. An
estimated seventy-five percent (75%) of investment in new hydro and ninety percent (90%)
of investment in sustaining existing assets remains in Ontario.
2. Recognizing the imperative of Indigenous and Community participation.
It is our expectation that, particularly for new northern hydro development, Indigenous and
other communities will be proponents of or partners in new hydroelectric projects. While
“early” engagement is certainly expected, as important is “ongoing” engagement as a project
moves from a high-level concept to the planning and potential development stages. It is
insufficient to limit engagement to only the early stages of a potential project.
Hydroelectric development can create lasting economic and social benefits to Indigenous
communities and enable other significant regional economic benefits. Though every
community has unique needs and perspectives on specific projects, the public and
communities are generally supportive of hydroelectric development, provided it is done
responsibly, there is meaningful, early participation, and community benefits that further
economic and social progress.
3. Beginning work now on planning and sitting for new waterpower facilities.
Based on our experience, we strongly agree with the P2D recommendations that “Sector
partners should begin planning and siting work to identify potential new hydroelectric
projects”, and “Preliminary work should begin now so that options are available for the
future.” In addition to early engagement, per above, this will require policy alignment and
capacity across provincial government agencies with regulatory responsibilities, relevant to
predevelopment, environmental assessment and permitting. In the case of hydroelectricity,
the Ministries of Natural Resources and Forestry and the Ministry of Environment and Parks
are of particular importance. This engagement can only happen with provincial agencies
working hand in hand with indigenous communities within their traditional territories, keep in
mind the indigenous peoples have always been stewards of the land and water. Similarly,
procurement mechanisms from the IESO must be designed to support long lead-time, long lifespan
assets and, recognition of the socio economic factors to the indigenous
communities.
4. Taking a planned and measured approach to reduce costs.
Experience suggests that a planned and predictable cadenced approach to
predevelopment, procurement and permitting that begins now and is implemented over a
period of a decade or more will best ensure a cost-effective build out of hydroelectric
resources. Ontario has experienced the “boom and bust” approach and witnessed its
negative effects on prices and on the loss of expertise and skills in the system. There is a
need now to re-establish and sustain the capacity of the industry, partners and communities
to reduce costs over time.
Again, thank you for the opportunity to comment.
Sincerely;
Chief Duncan Michano
Biigtigong Nishnaabeg &
Director Begetekong Power Co