I am writing to you today as…

I am writing to you today as a concerned citizen regarding the recent posting on the Environmental Registry of Ontario. ERO Number 019-0545. Waterpower Exemption from Permits to Take Water.

The first reading of the proposed amendment to the Ontario Water Resources Act, Bill 128 found at the link below had different wording than this more recent posting.

https://www.ola.org/sites/default/files/node-files/bill/document/pdf/20…).

Bill 128 reads as follows:

The taking of water for constructing, operating, altering, improving or repairing a dam within the meaning of the Lakes and Rivers Improvement Act if the dam is associated with the production of electricity and if the activity is done in accordance with an approval granted under that Act or in compliance with an order of the Minister that is made under that Act.

Why has the last sentence been removed from the more recent posting: " if the activity is done in accordance with an approval granted under that Act or in compliance with an order of the Minister that is made under that Act."

This last sentence ensures approvals or orders are in place. By removing this last sentence, are there instances where water power will be unregulated in Ontario? If so, I find that to be completely unacceptable particularly given our changing climate. Dams and infrastructure in Ontario must be prepared to adapt to changing conditions in this time of climate uncertainty. How can major infrastructure in Ontario be constructed without approvals or orders in place?

I also note that the words altering, improving or repairing a dam have been removed from the more recent posting. Why has constructing remained? In my opinion, if there was a reason to remove the other words, then construction should have been removed too. When a dam is altered, improved or repaired, will it still be subject to a Permit to Take Water? Why is construction treated differently? If a Permit to Take Water is not in place during construction, how will water resources be protected? What if the construction causes impacts? Will construction activities be to a certain standard? Will they be subject to inspection and environmental penalties? How will this be possible if they are operating without any oversight?

From my online searches, I do not see any public postings of the water management plans on the Environmental Registry. Does that mean that these plans are not subject to public comment or appeal? How will the public and particularly indigenous communities have an opportunity to comment on these large projects that completely change our environment? This posting does not seem to reflect the recent changes that are occurring regarding recognition of Indigenous rights.

I would also like to mention that I am disappointed in the level of detail provided in this recent posting. I did not find that the posting has described the changes in detail and given that this is a big change, I think more explanation and certainly more time for public comment would have been appropriate (30-days is insufficient). I also do not like that supporting materials are only available for viewing in person - everyone does not live in Toronto! Certainly, not the people affected by this proposal, which will predominately affect those in the North.

I would also like to bring to your attention the fact that there have been articles reporting research findings that indicate that hydropower is not considered to be "green" energy and dams have been shown to release large amount of greenhouse gases (methane). If this is true, and I am sure there are experts in your ministry that would know this, how can you justify paving the way for more dams to be established in Ontario when the rest of Canada is trying to curb greenhouse gas emissions?

I certainly do not support this proposal. It seems contrary to much of what Canada stands for (reducing greenhouse gases, recognizing Indigenous rights, having an open government where the public is aware of development activities and is provided with the opportunity to comment on them). I do not think that industry should be given a free pass to significantly alter what remaining undeveloped land we have. Given where we are as a country and what we know in terms of how the climate is changing, this proposal is a step in the wrong direction and a step, that I'm afraid, we won't be able to take back.

Thank-you and I hope you will re-assess this proposal.
A concerned resident of Ottawa, ON