Waterkeeper submits final comments to the Joint Review Panel regarding the Darlington New Nuclear hearing
On May 17th, 2011, Lake Ontario Waterkeeper made our final submission to Joint Review Panel for the Darlington New Nuclear Power Plant hearing regarding the Environmental Assessment and Licence to Prepare a Site (CEAA Registry # 07-05-29525).
Overview
Lake Ontario Waterkeeper stands by the expert evidence and analysis that we have provided through this process to date, including our written comments, expert reports, and presentations to the Joint Review Panel. The public hearing highlighted and reinforced the importance of the issues we raised, and the solutions offered by OPG were shown to be inadequate. Waterkeeper offers this final submission to assist the Panel with its deliberations. Should the members of the Joint Review Panel [the Panel] require any further information or clarification, Waterkeeper is happy to provide that upon request.
OPG failed to meet the burden imposed on proponents under the Canadian Environmental Assessment Act. The impact of this proposal on fish and fish habitat was shown to be extensive and significant, raising compliance issues with the Fisheries Act. Attempts by OPG to justify the extensive aquatic impacts highlighted the fundamental problem with this proposal: the chosen site is incompatible with the proposal for a new nuclear plant.
Had the requirements of the CEAA been met by this hearing process, the inappropriate siting choice could have been remedied through consideration of alternative sites. Instead, the requirements of the CEAA were not met. Where the siting decision was set in stone before the process began, most details fundamental to describing the project, including the reactor technology and cooling water system, were excluded from consideration.
The result is an inadequate hearing process that cannot support a valid environmental assessment or licencing decision by this Panel or the Minister of the Environment.
In addition to the comments presented below, Lake Ontario Waterkeeper fully echoes and endorses the submissions of the Canadian Environmental Law Association [CELA] with respect to the failure to fulfill the requirements of the CEAA in this environmental assessment.
Read our complete submission to the Joint Review Panel here.