Small Water Power Development’s Ugly Side

There is a widespread popular support in Ontario for the proposition that the province should dam more rivers to increase our supply of hydro-electric power generation. A minority of Ontario citizens are concerned that this development will have unacceptable consequences. The most articulate expounder of this perspective is the Ontario Rivers Alliance (ORA).  I recommend ORA’s trenchant critique of the role of industry in setting the rules for water power development, ORA’s analysis of the economic implications of current developments for consumers, their assessment of the deficiencies of the Green Energy Act, and particularly ORA’s impressive analysis of the destruction of the basic principles of sound Environmental Assessment — where Ontario was once a leader.

16 Comments

  1. Correction – the industry does not “set the rules” – Waterpower development is planned through a “Class Environmental Assessment” process pursuant to the provisions of the Environmental Assessement Act. (like Conservation Authority, Municipal, Transmission and other projects). Our Association took the lead in developing the Class EA over a period of years through significant consultation – a process tantamount to an individual EA. As a result we created a much more rigorous and technology-specific framework than previously existed(Regulation 116/01). We continue to supplement the planning framework with best management practices ranging form Species at Risk to Aboriginal Community Engagement. I, and our sector, take our social licence very seriously. The fact that we have decided to lead rather than follow does not result in “the destruction of the basic principles of sound Environmental Assessment”.

    Paul Norris
    President
    Ontario Waterpower Association
    Ontario Waterpower Association

    • Mr. Norris, I was pleasantly surprised to see your, and the OWA’s committment to the social licence concept. My understanding of this is that you, as an ex MNR employee, believe that any project’s success will and must depend upon approval within local communties and with stakeholders.

      I must report to you that after now dealing with two of your hydro developer members, your membership does not consider that a social licence is applicable. Rather, the message from OWA members is loud and clear: we are instituting a Grand Public Policy (Green Energy Act) and have captured or will capture control over the regulators at MNR and MOE. Local communities, municipalities and stakeholders will have no control and their input does not matter.

      Hydro projects are scientifically proven to cause severe ecological and environmental damage. In fact, while Ontario pursues a policy of building more dams, our neighbours in the United States have recognized the ecological, environmental and economic damage caused by dams and are in the process of removing existing dams.

      A hydro project, particularly a peaking project, is an Eviction Notice to many aquatic, amphibious and terrestrial species, including threatened and endangered species. Evicted along with these species are the local stakeholders including business operators who depend upon these species and water quality for their economic survival.

      One of your members issued three Notices of Completion last fall. All of these were rejected by the MOE. This led to a unique situation where MNR staff are now coaching the OWA proponent to ensure they meet the intent of the Environmental Assessment Act!

      Now, we face a proponent who is partnered with a regulator to guarantee regulatory approval against a network of stakeholders who disagree with the project! What has happened to an unbiased Public Service?? Is this the social licence you refer to as taking very seriously??

      Beyond local community approval, for a social licence to endure and reach a broad level of ongoing social acceptance, there has to be a win – win formula.

      If we look at the FIT contract price, these new peaking hydro projects are more expensive than wind power. If allowed to continue in its present format, we, the consumer, can expect to pay 18 cents/kw for hydro, which is 14.5 cents/kw above regulated OPG prices and 4.5 cents/kw above wind power.

      These escalating costs will negatively affect each consumer’s disposible income and perhaps more importantly, negatively affect business competiveness and municipalities’ costs. The consumer, including business, now faces a quadruple hit — rising costs, increased taxes, reduced services and potential job losses and a reduced standard of living!

      IS THIS YOUR VISON OF SOCIAL LICENCE? Is the OWA willing to consider any suggested solutions that can build a true social licence?

      SHOW LEADERSHIP AND DO THE RIGHT THING!

  2. I remain under the understanding that Reg 116/01 still remains relevant to all “waterpower” projects >200MW – if this understanding is incorrect, I hope someone will reply with inclusion of the public notification of its repeal, amendment or replacement that I’ve “missed”.

    The “waterpower project” concerns referenced by Mr. Adams’ post and the ORA are justifiably focused on the number of proposed SMALL waterpower (hydroelectric) projects that would NOT be commonly subject to an Individual Environmental Assessment (ie: those <200MW) and/or even moreso, those among these <200MW now made far more lucrative by their additional 200MW (ie: whose criteria put them in Category C) are all subject to an Individual Environmental Assessment. However, NO waterpower projects >50MW are eligible for contracts under the FIT program. Those projects are so not likely to be the derivation of Ontario Rivers Alliance concerns – as they appear to be the preferred focus of the previous respondent, Paul Norris.

    Unless something I remain unaware of has changed since I personally discussed this topic at length last summer, with provincial Ministry of Energy experts and regarding the pumped storage project Northland Power proposed here in Marmora (related story here: http://www.intelligencer.ca/ArticleDisplay.aspx?e=3231416 ) – to obtain “energy project” facts that had avoided local public exposure, discussion or publication like the plague – NO “waterpower” projects are exempt from all environmental assessment processes like some non-waterpower renewable energy projects whose criteria put them in Category A.

    Waterpower projects >200MW – like the Non-Renewable + Non-Green “pumped storage” project Northland Power has been pushing to obtain a contract for, in order to justify their building & operation of it here – by using the existing, spring-fed lake in Marmora’s abandoned mine pit for their lower reservoir (NOT to be confused with their “other” pumped storage project consideration further north and on Crown land) – has been quite consistently losing the “battle for contract-guaranteed payment” for years. Despite efforts to brand and promote it as equivalent to “renewable energy”, its “loser” status hasn’t changed since 2006.

    In retrospect, perhaps Northland Power may have been further ahead to have contented themselves with the past-predicted installed capacities for this “impractical” site’s pumped storage proposal, of 100 or 200MW (depending on which past reports you prefer) – rather than their having “upgraded” this proposal’s capacity to “would provide 400 megawatts of power for five hours” (excerpt from Toronto Star article “Mining for Megawatts in Marmora” published June 30, 2011) more recent proclamations – in spite of this being one of many such valuable provisions of cheap local amusement and entertainment since June 2011 by Northland Power?

    Had they left the estimated capacity for this “pumped storage” project proposed here in Marmora at < 200MW they might have got their precious contract by now, given that they MAY have gotten away with an "Environmental Screening" process like the "waterpower" projects that concern the ORA 😉

    • I’m replying to myself, in order to provide more logical “flow”, correct my typos, reduce rambling sentences and attempt clarification of some complexities. My apologies for further space consumption and any confusions – hope this re-presentation helps. The classifications and Categories A, B & C I’ve referred to are here:
      http://www.ecoissues.ca/index.php/Environmental_Assessment_Requirements_for_Electricity_Sector_Projects:_O.Reg._116/01

      Unless something I remain unaware of has changed since I personally discussed this topic at length last summer, with provincial Ministry of Energy experts and regarding the pumped storage project Northland Power proposed here in Marmora (related story here: http://www.intelligencer.ca/ArticleDisplay.aspx?e=3231416 ) – to obtain “energy project” facts that had avoided local public exposure, discussion or publication like the plague:
      NO “waterpower” projects are exempt from all environmental assessment processes.
      Only some non-waterpower renewable energy projects are, because their eligibility criteria puts them in Category A.

      I remain under the understanding that Reg 116/01 still remains relevant to all “waterpower” projects that are >200MW (Category C). If this is incorrect, I hope someone will reply to let me know whatever I’ve “missed”.

      The comments from Paul Norris appear to be focused on Category C “waterpower projects” that are >200MW. This baffled me because:
      The “waterpower project” concerns of the ORA and referenced in Mr. Adams’ post are justifiably focused on the number of proposed SMALL waterpower (hydroelectric) projects that would NOT be commonly subject to an Individual Environmental Assessment (ie: those <200MW, which puts them in Category B).

      I can understand how ORA concerns would justifiably be doubly focused on particularly those within Category B that are <50MW - because of their financially lucrative eligibility for the FIT program encouraging "breed like rabbits" quantities, in addition to their common exemption from that most rigorous type of environmental assessment.

      I can even better understand why many would find all this confusing. I obviously still have trouble explaining to others what I might otherwise still find confusing within my own mind, had I not urgently needed to sort out even more confusing details and had the benefit of several well-informed people with great expertise and sufficient patience to repeatedly help me until I "got it":

      Projects using water for storing energy do not necessarily fit Ontario's provincial criteria for appropriate definition as a "waterpower" project - if overlooked, a point capable of adding confusion to their being net energy consumers, so not equivalent to any other "energy project" that's capable of being a net producer, either. One such confusingly rare example is the >200MW Non-Renewable + Non-Green “pumped storage” project Northland Power has been pushing to obtain a contract for, in order to justify their building & operation of it here – by using the existing, spring-fed lake in Marmora’s abandoned mine pit for their lower reservoir (NOT to be confused with their “other” pumped storage project consideration further north and on Crown land). This proposal has been quite consistently losing the “battle for contract-guaranteed payment”. Over the years and despite recent efforts that errantly brand and promote this specific project under Northland Power development as equivalent to a “renewable energy project” in uninformed minds – the “loser” status of this site’s suitability for a pumped storage facility hasn’t changed since 2006.

      In retrospect, perhaps Northland Power may have been further ahead to have contented themselves with the past-predicted installed capacities for this “impractical” site’s pumped storage potential, of 100 or 200MW (depending on which past reports you prefer) – rather than having upgraded their specific project proposal’s capacity proclamations to “would provide 400 megawatts of power for five hours” (excerpt from Toronto Star article “Mining for Megawatts in Marmora” published June 30, 2011) – in spite of this being one of many such valuable provisions of cheap local amusement and entertainment since June 2011 by Northland Power.

      Had the estimated capacity for this “pumped storage” project proposed here in Marmora remained at < 200MW they might have their contract by now, given that they MAY have gotten away with an "Environmental Screening" process like the SMALL waterpower projects concerning the ORA, which appear to be net producers and actually "waterpower" projects by natural "flow" definition criteria. Gratefully, none of that applies here and now. But if I hadn't directly asked for and obtained the necessary facts and knowlege from "outside" that the majority here still lack, I'd have never known it and likely wouldn't have had a prayer of correctly interpreting the ORA concerns, nor their derivations.

  3. RE: “There is a widespread popular support in Ontario for the proposition that the province should dam more rivers to increase our supply of hydro-electric power generation.”

    Not from me, there isn’t.

    To me, it would make more sense to first run the long-existing ones at full capacity whenever/ if we need an increase in the supply (which is currently running excesses too often?) – rather than building MORE and adding to the FIT program “problems” generated for consumers. Too often these long-existing, small local dams are shut down in deference to bringing more costly wind and/or solar supply online… outrageous insult and financial injuries thus added to local operations, incomes and Ontario electricity consumers.

  4. Re: “The comments from Paul Norris appear to be focused on Category C “waterpower projects” that are >200MW”. This is incorrect. Such projects require an individual EA pursuant to Reg 116/01. The Class EA includes waterpower projects that were classified at “Category B” under the regulation. And yes, there are “Category A” projects as well – expansions of existing facilities which result in a less than 25% capacity increase. Reference Section 3.2 (Page 27) of the Class EA.

    • You need know that I’m just an everyday housewife, so may require more extensive explanation of your problem with my confusion, Mr. Norris.

      From your first comment: “Our Association took the lead in developing the Class EA over a period of years through significant consultation – a process tantamount to an individual EA.” Perhaps it would help me if you defined “tantamount” so I could figure out why an association would spend years developing something equal to what already existed (if “tantamount” is defined as equivalent), rather than just demanding all be subjected to an individual EA.

      From your last reply to me: First, my apologies for not clarifying that my comments pertained to only new projects and excluded expansions. With that said, I need clarification regarding this statement of yours: “The Class EA includes waterpower projects that were classified at “Category B” under the regulation.” My question here is … “includes waterpower projects that were classified at Category B” …Projects that comply with precisely what criteria (that I assume would thus put them in a Category B sub-category?)?

      Anyway, perhaps I’ll get to speak with you in person about all this right here in Marmora someday, since today I publicly requested our local council to arrange an open public meeting/ debate regarding the local “pumped storage” project proposed by Northland Power here in Marmora (that you opined about in a Belleville Intelligencer piece published Tuesday July 26, 2011 – the same day CHEX TV Peterborough had twice live-broadcast my local opposition to that project on their evening Newswatch Program, remember?)- now once again the intriguing chatter ringing through our village grapevine, since Northland Power and Hatch delegates kindly revitalized the local controversies at a local council meeting June 19, 2012:
      http://riffsandripplesfromzenrivergardens.blogspot.ca/2012/06/village-citizen-upset-over-marmora-mine.html

  5. First of all, thank you Tom Adams for your posting – much appreciated.

    Current lobbying practices provide Ontario Waterpower Association (OWA) with ample opportunity to have their agenda/s met, especially with the Green Energy rush pushing hydroelectric developments in numbers never before experienced in Ontario.

    OWA claims responsibility for the proponent led process coming into being in 2001 which, in the opinion of Ontario Rivers Alliance (ORA), has been a dismal failure, and has relegated the MNR and MOE to the role of mere facilitators of the approvals process. Also, OWA recently sent out a Media Release to announce its new “Best Management Practices Guide for the Mitigation of Impacts of Waterpower Facility Construction” – a collaborative project between the Ministry of Natural Resources, Department of Fisheries and Oceans, and OWA. Therefore, I think it is fair to say that the waterpower industry does have a huge influence on the regulatory end of things – and some could even say does “set the rules”. The fault isn’t with OWA in this regard, as they are doing the best they can for their industry – the fault lies with our government in allowing environmental protection to take a backseat to economic development and the Green Energy rush.

    ORA’s mission is to protect, conserve and restore healthy river ecosystems, and we strive to ensure that new and existing developments are environmentally, ecologically, and socially sustainable. At the moment there are 87 waterpower proposals going through the approvals process, with a large portion of these under 10MW, and are using modified peaking operating strategies that carry numerous negative ecological impacts, including reduced water quality and water quantity. Methylmercury production has been well documented from the creation of headponds on newly inundated land, and the frequent and extreme flow velocity and water level changes pose a significant threat to public health and safety. ORA fully supports green energy, however, we maintain that these modified run-of-river hydroelectric dams are not green energy, but instead are “dirty energy” and should be removed from the Green Energy Act.

    Kathy is correct – the generous FIT Program, with its 50% peaking bonus, has encouraged maximizing energy output at, and I like your expression “encouraging “breed like rabbits” quantities”, the expense of Ontario river ecosystems.

    To back this statement up – MNR suggest that Q80 is the desirable flow to maintain river health and sustainability, and yet “a key waterpower developer that has 33 of these 87 waterpower proposals says, “The key objective is that we want head and intermittent operations. Q80 will make it difficult to achieve intermittent operations which may result in an uneconomical run of river project.” So, ORA’s #1 question is: Will the rules be bent by allowing drastically reduced environmental flows in order to accommodate these modified run-of-river proposals?

    It is also important to note that often hydroelectric facilities are referred to as run-of-river operations, when in fact they are really cycling or peaking operations.

    There is much more that can be done in conservation, as well as upgrades and efficiencies to existing hydroelectric facilities. There are currently numerous Ontario Power Generation facilities that are not operating because funding incentives are being poured into these new “Green Energy” proposals. Let’s repair and make efficiencies to our existing hydroelectric dams, and at the same time incorporate fish bypasses and other corrective mitigation measures to improve riverine ecosystem health.

    Climate Change is upon us with river flows going lower and lower each year. Water is our most precious and essential resource and must be protected, now, and for our future generations.

    The Marmora application has been on our radar Kathy, but presently ORA has not been approached by any concerned citizens or organizations to assist. Please let ORA know if we can be of any assistance.

    Linda Heron, Chair
    Ontario Rivers Alliance
    http://www.OntarioRiversAlliance.ca/blog

    • Hi Linda, I am very grateful to learn that what is going on in Marmora has reached so many others’ radars since our local ordeal began. Thank you for the kind offer. I will point others here to your comment.

      Unless you respond otherwise in reply, I’ll assume your organization is already aware that the pumped storage project Northland Power has proposed building here in Marmora will not have any river or other natural water flow feeding into its upper reservoir (but the beautiful, existing lake in the abandoned open mine pit destined to become their lower reservoir is spring-fed, in spite of Northland Power’s repeatedly and more recently their “project engineer” from Hatch also publicly claiming that this lake developed from precipitation).

  6. Falling water presents an opportunity to generate electricity. Every opportunity should be assessed in a respectful and democratic manner with a view to providing maximum benefit to the community and Ontario as a whole.

    We are mobilizing people and financial resources to assess renewable energy opportunities with a view to providing benefit to communities in Ontario. We propose completing this project on a not for profit basis and this will require a strategic investment by government and donors.

    We propose that Ontario needs a Community Energy Act as outlined in the following links:

    Sign the Petition to ask members of provincial parliament to discuss the need for a Community Energy Act. https://www.box.net/shared/b6986206c85fcd3443e2

    See the proposed measures: https://www.box.net/shared/28839b06251095324835

    • This proposed “Community Energy Act” sees a world with even more government money directed toward the electricity sector than we have today. As governments develop more interests in industrial activities, the role of government in properly regulating these activities can only become more conflicted than it already is. As a consumer, I don’t vote for my next meal or pair of shoes, rather I use a more reliable procurement technology — I pay for them. The Community Energy Act would create an even more unstable electricity system than Ontario has today.

      • I respectfully disagree with Tom. I look forward to seeing Tom’s submission in a legislative committee if and when the proposal makes it past second reading. This is when the public will have an opportunity to voice there support and concerns. Failure to implement a Community Energy Act may lead to more social friction and expensive energy for the benefit of the super-rich.

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