30 Main Street,Bishops Mills, RR#2 Oxford Station,Ontario K0G 1T0http://pinicola.ca

14 December 2011

Ministry of EnergyAttention: Fareed Amin, Ontario Deputy MinisterEmail: 2yearFITreview@ontario.ca

Re: Review of Feed-In Tariff (FIT) Programme

Dear Mr. Amin:

My wife and I have been studying the question of the appropriate level of technology for human occupancy of Ontario since we moved to Bishops Mills in 1978, as I was finishing my Ph.D. in geographic variation, and she was finishing her first book, an ecological survey of Canada. You can review our publications at http://pinicola.ca/NEWCVP.pdf We haven't participated very much with the conservation bureaucracy or conventional environmental activism, but have tried to provide dispassionate evaluations of human interactions with environmental situations and with populations of other species.

Since 1986, we've been advocating “photovoltaic roofing” as a way of generating electricity without increasing the human ecological footprint, and so we were pleased to see the recent proliferation of solar arrays under the Green Energy Act, even though most of these were carelessly situated in previously open fields, rather than on the roofs of existing buildings.

In many situations it has been amazing to us how nominally "green" initiatives are undertaken as if they were "ordinary business opportunities," without acknowledgement that it's the recognition of environmental complexity that makes an undertaking "green," or that complexity-denying "business as usual" is the problem for which environmentally-aware enterprises are trying to compensate.

The implementation of the FIT in many hydroelectric projects is an example of this. As documented by the Ontario Rivers Alliance,1 many of these projects will not produce any net electricity, and are economic only under the present schedule of the FIT. Hydroelectric impoundments are still attended by all of the problems which led environmentalists to struggle so fervently against them in the 1960s and 1970s. These problems include deposition of sediment, changes in water temperature, algal buildup in impounded water, fluctuations in water level, breaking the genetic continuity of stream-inhabiting species & preventing their migrations, release of methyl-mercury, and others. None of them have been solved, especially in the sketchy environmental assessments of many of the proposed “run of the river” hydro plants. Since 1986 there has been the additional problem of Dreissena Zebra and Quagga

1 http://ontarioriversalliance.ca/

mussels, and the ecosystem-wrecking buildup of their populations behind dams.

If the Green Energy Act is to produce really “green” energy it is imperative that all the environmental consequences of the proposed projects be dispassionately evaluated by adequately funded reviews by MNR and MoE, as well as through thorough consultation with the whole local community, and by seeking out scholars and naturalists with knowledge about the sites & situation sof the proposed projects.

An example of the kind of damage to which a rushed onset of such projects can lead is the extinction of the Almonte population of Two-lined Salamanders (Eurycea bislineata) by the recent expansion of the Mississippi River Power Corp (“Green power for our community...”) hydro plant there. I discovered this population in 1997, published an account of it, and reported it to the Ontario Herpetofaunal Summary, but when the new plant was built, on the site of the salamander population, no attempt was made to protect the Salamanders, or to contact me, and letters about this to the company building the plant went unanswered.

I'm concerned, for a current example, about the rash of proposals for FIT-dependent dams and hydro plants that will disrupt Sturgeon populations across northern Ontario. This is a case where one “species at risk” is essential for the survival of another “species at risk.” Sturgeon are the host fish for the rare and beautiful deepwater mussel, Obovaria olivaria, or Hickorynut, which has recently been designated “Endangered” by COSEWIC. This species has been wiped out by Zebra Mussels in the Detroit and most of the St Lawrence rivers, but persists in the unimpounded stretches of the Ottawa River, and has recently been discovered in the Mississagi River, flowing into Lake Huron. Surveys of freshwater Unionid mussels in northern Ontario are difficult to conduct and have been totally inadequate,2 so it’s vital to assess every Sturgeon population for associated Obovaria, as well as for its own sake, before anything is done to disrupt the Sturgeons' life cycle (other species of mussel will be inventoried in the process of looking for Obovaria).

The significance of this for the FIT programme is that it's only the biased FIT that justifies the construction of many of these dams. A biased FIT is useful in launching new technologies such as photovoltaics or wind power, but hydro is an old technology which is damaging at the best of times, and free-flowing streams are a limited resource, inexorably diminished by the construction of every dam and weir. Ontario has seen this with the extinction of the Lake Ontario Atlantic Salmon, and the deplorable condition of Eels in Lake Ontario and the Ottawa River, and it's improper to allow a misapplied FIT to launch another generation of stream degradation.

Sincerely,

Frederick W. Schueler, Ph.D.Research Curator

2 See Schueler, Frederick W., 2000. Ligumia recta, Leptodea fragilis, and Anodontoides ferussacianus, new to the Lake Nipissing Drainage, Ontario. Triannual Unionid Report 19:21. http://ellipse.inhs.uiuc.edu/FMCS/TUR/TUR19.html#p21