You can view the Environmental Assesment PDF below or download it here.
The Save Georgian Bay Association issued the Strategic Environmental Assessment report – a group of concerned residents of the Georgian Bay community, with a core membership centered in Meaford. The entire 80-page report is posted as a webpage with a table of contents and search capability. It is also available as a pdf download. Below is an introduction and guide to the contents of the report.
Section 2.0 provides further information regarding our mission and membership. The report is issued in response to the DND’s request for public comment on TC Energy’s proposed project. It is presented as a screening-level environmental assessment to address the various environmental concerns of the proposed project as raised by the community and backed by professional construction, hydroelectric and environmental engineers.
It is recognized that the DND must adhere to directives on Environmental Stewardship, as further discussed in Section 3.0. These directives require that the DND consider the environment early in the planning process before any irrevocable decisions are made. Since neither the DND nor TC Energy prepared or publicly released any form of environmental assessment, Save Georgian Bay took the liberty to do so. On July 31, 2020, the assessment involving construction, hydroelectric and environmental engineers was presented to the Department of National Defence 4th Canadian Division Training Base Meaford, Ontario.
The report provides a brief overview of the proposed project in Section 4.0 and a discussion of the project rationale in Section 5.0. This report responds to the original TC Energy design. Since the creation and presentation of this report, significant changes have been made to the original design. In a nutshell, everything is hidden underground, but it’s still the same project, and all the claims made in this report do not change.
TC Energy publicly states that the project is needed to provide Ontario with needed electrical capacity, reduce electricity costs and greenhouse gas emissions, drive local economic benefits and growth, and store excess baseload generation. However, corporate profit is believed to be the only rationale for the project.
TC Energy has proposed a pumped storage plant located on the DND base without considering alternatives, yet alternatives do exist, as discussed in Section 6.0. A lot has happened in the energy sector since TC Energy started this process at least 5 years ago. Energy storage technologies and management strategies have progressed significantly over the past few years and will continue to do so. Pumped storage is a product from the 1960s. It is a proven technology and proven to cause significant adverse environmental impacts.
TC Energy commissioned a study to evaluate the electricity production and consumption for the proposed project. Section 7.0 summarizes the main findings. The DND directive requires DND operations to reduce energy use. The proposed project will not help the DND achieve that objective. On the contrary, the proposed project will increase energy use since it is a net consumer of electricity.
TC ENERGY PUMP STORAGE PLANT
July 2020 1-2
The report challenges the claim of TC Energy that this project is “One of Canada’s largest climate change initiatives.” As claimed, the proposed project will not reduce carbon levels in the earth’s atmosphere. In fact, it will likely increase carbon levels, as discussed in Section 8.0. Accordingly, it is recommended that the DND undertake a critical, independent expert review of TC Energy’s projected carbon savings before making any decision to advance this proposed project. Our research concludes a net increase in carbon emissions when all factors are considered. Furthermore, others have proposed viable alternatives that achieve the purpose of off-peak energy utilization while reducing carbon emissions and not harming the environment or posing a risk to human life.
Save Georgian Bay has engaged with the community to inform them of this project and share our findings, as discussed in Section 9.0. Unfortunately, the overwhelming message we receive from the community is opposition. They express concerns about how the proposed project will affect their community and impact the environment. We trust the DND has heard many of these concerns and will hear more as the comment period comes close – September 2020.
The Municipality of Meaford issued a document to the DND, dated June 1, 2020, expressing their concerns regarding the potential impacts to the community. These concerns reflect many of the messages we hear from the community, as discussed in Section 10.0. Meaford’s Official Plan establishes an ‘environment-first’ philosophy in the municipality. This means protecting significant natural heritage features and functions shall take precedence over development.
TC Energy’s proposed project can cause significant adverse environmental impacts to be terrestrial and aquatic environments, as discussed in Section 11.0. TC Energy did not adopt a proactive approach towards the environment. Instead, they’ve taken a reactive approach – propose the most straightforward and cheapest option and then react to public pressure as it arises. They’ve changed their original conceptual design because, in their words, ‘we listened”. If the community has to tell a proponent that their design will kill fish, then the proponent has failed in their prime objective of protecting the public, the community and the environment.
The proposed project includes the construction of a reservoir on top of the Niagara Escarpment immediately adjacent to the administrative buildings and barracks on the DND base. A perimeter rock-filled dam will hold 23 million cubic meters of water that will tower over the heads of several hundred families. As discussed in Section 12.0, failure of dams is rare, but the consequences are catastrophic when they occur. It’s not a question of “do dams fail?” although the record shows they do. It’s a question of “what are the consequences if the dam does fail?” Dams that fail within residential areas most likely cause fatalities.
TC ENERGY PUMP STORAGE PLANT
July 2020 1-3
The proposed project includes the construction of a new transmission corridor between Meaford and the connection point at Hydro One’s Essa Transmission Station. Both overland and subsea options are being considered, as discussed in Section 13.0. The Municipality of Meaford has declared their preference for the subsea option, considering all of the other impacts the municipality will experience as the host.
The DND’s directive on environmental protection and stewardship requires the DND to meet or exceed the letter and spirit of all federal laws, including the Impact Assessment Act, the Species at Risk Act, and the Fisheries Act. The Impact Assessment Act declares an authority cannot proceed with a project on crown land that may cause a significant adverse environmental effect. The Species at Risk Act declares that a project cannot harm the habitat of threatened or endangered species. The Fisheries Act declares that a project cannot cause fish mortality or destroy fish habitat. Both the original and revised conceptual designs do not comply with the requirements of these Acts. Instead, the project can cause significant adverse environmental effects, cause fish death, and destroy fish habitat. The DND, as per their directive, should therefore reject the proposed project outright.
If the DND is not prepared to reject the project at this time, DND must hold TC Energy to the highest standard of care possible. The importance of this expectation is presented throughout this Strategic Environmental Assessment. Section 14.0 includes information from a project review provided by Save Georgian Bay to the Mayor and Council of Meaford on March 17, 2020. These conditions were appended to June 1, 2020, submission from the municipality to the DND. The expectation defined by Meaford Council was clear, if DND accepts the proposal, then DND must require TC Energy to prove it can meet the requirements, commit to meeting the requirements, and follow through on that commitment. The sum of this report will demonstrate the damage this project would do to the environment, to the land, water and wildlife and to the community, and show that the proponent does not show the capability or will to effectively meet the standards, particularly in a first time effort to design and build a pumped storage facility.