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Document reference number: 329

Summary of IssuesOntario Pumped Storage Hydropower Project

The Summary of Issues outlines the key issues that the Impact Assessment Agency of Canada (IAAC) considers relevant for the federal impact assessment process for the Ontario Pumped Storage Hydropower Project (the project), as proposed by TC Energy (the Proponent). The proponent's response to the Summary of Issues will support decision-making by IAAC on whether an impact assessment is required under section 16 of the Impact Assessment Act. If an impact assessment is required, the key issues outlined below and the proponent's response will inform the scope of the impact assessment, and the development of the Tailored Impact Statement Guidelines and plans, as appropriate.

IAAC was informed by input from federal and provincial authorities, Indigenous groups, and the public received to date on the proponent's Summary of the Initial Project Description. The proponent is encouraged to review all submissions on the Canadian Impact Assessment Registry Internet site for the project (Reference Number 89803).

The proponent is required to submit a response that describes how it intends to address the key issues identified below as part of the development of its project. A high-level description is sufficient. Where relevant, the proponent is encouraged to identify if the key issues will be addressed through existing legislative and regulatory frameworks (i.e. legislation or regulation), by proponent commitments to best practices, policies or standards, or both.

Key Issues

Fish and Fish Habitat

• Concerns about effects to fish and fish habitat, including spawning habitat, from in-water construction and operation of the inlet/outlet structure, including sedimentation, turbidity, and resuspension of materials, changes to water quality, and loss or alteration of habitat resulting from lakebed disruption and shoreline modification.
• Concerns regarding increased risk of fish mortality or injury through entrainment and impingement, blasting, and changes to hydrodynamic conditions such as water circulation, temperature, and stratification in Georgian Bay.

Change to the Environment on Federal Lands

• Concerns regarding effects to species at risk, including increased mortality risk and loss or alteration of species at risk habitat, resulting in potential adverse effects on the survival and recovery of listed species.
• Concerns regarding changes to terrain stability resulting in potential risks of slope failure, erosion, and associated effects on federal lands.
• Concerns regarding bedrock excavation causing metal leaching and acid rock drainage, resulting in potential changes to groundwater, and surface water quality on federal lands.
• Concerns regarding changes to groundwater flow and levels, resulting in potential effects on groundwater–surface water interactions and environmental conditions on federal lands.
• Concerns regarding changes in air quality from construction activities, resulting in potential adverse effects on human health on federal lands.
• Concerns regarding increased noise and vibration levels from construction activities on federal lands.

Structures, Sites, or Things of Historical, Archaeological, Paleontological, or Architectural Significance to Indigenous Peoples

• Concern about disturbance or loss of heritage resources and uncertainty regarding identification, protection, and management of culturally significant sites.

Indigenous Peoples Physical and Cultural Heritage

• Concern about the impact of the project on the relationship with the land, including spiritual and cultural impacts

Indigenous Current Use of Lands and Resources for Traditional Purposes

• Concerns about effects to fishing, navigation, and harvesting, due to changes in access in Georgian Bay, availability, and quality of lands and resources.
• Concerns about cumulative effects of existing restrictions on access to the 4^th Canadian Division Training Centre in combination with this project, particularly to the current use of lands and resources for traditional purposes.

Indigenous Peoples' Health, Social, and Economic Conditions

• Concerns regarding effects to Indigenous health from environmental changes affecting water quality, resource quality and availability, and access to clean water and country foods.
• Concerns about effects to social and economic conditions from limiting access to lands and resources used for traditional purposes, affecting harvesting activities and associated livelihoods, and potentially undermining cultural continuity and community well-being.
• Concerns regarding changes to surface water quality resulting in potential effects to drinking water for Indigenous communities and associated impacts on health and well-being.

Indigenous Peoples Rights

• Concern about impacts to the exercise of rights of Indigenous Peoples, resulting from effects on lands, waters, and resources used for traditional purposes.

Community Well-Being and Infrastructure

• Concerns regarding influx of construction workers causing increased demand for housing, local services, and infrastructure, leading to more pressures on community capacity and well-being on federal lands and surrounding areas.
• Concerns regarding pre-existing contamination, and the potential for soil disturbance, overburden handling, stormwater runoff, and construction activities to cause changes to water quality in drinking water wells adjacent to the project.

Accidents and Malfunctions

• Concern about infrastructure malfunctions, accidents and failures, such as the upper ring dam, reservoir, conveyance systems, and spillways.

Appendix – Other Comments, Advice, and Recommendations

The following list provides other comments, advice, and recommendations for information purposes only. The proponent is encouraged to consult the Canadian Impact Assessment Registry Internet site for the project (Reference Number 89803) to review the original comments.

Other Comments

Alternatives to Consider

• Noted importance of considering alternative energy storage technologies and alternative means of carrying out the project, including whether alternative approaches could reduce environmental and social effects.

Indigenous and Stakeholder Consultation and Engagement

• Concerns regarding the adequacy, transparency, and effectiveness of engagement activities with Indigenous groups and stakeholders, including information sharing and the extent to which input is meaningfully incorporated into planning and decision-making.

Permitting and Authorizations Recommendations

• Transport Canada be consulted to ensure compliance with the Canadian Navigable Waters Act, particularly on the necessary permits and authorizations.
• Fisheries and Oceans Canada be consulted to ensure compliance with the Fisheries Act and the Species at Risk Act, particularly with regard to the necessary permits and authorizations.
• Environment and Climate Change Canada be consulted to ensure compliance with the Migratory Birds Convention Act, 1994 and the Migratory Birds Regulations, 2022 and the Species at Risk Act, particularly with regard to the necessary permits and authorizations.
• Natural Resources Canada be consulted to ensure compliance with the Explosives Act, particularly with regard to the necessary permits and authorizations.
• Crown-Indigenous Relations and Northern Affairs Canada be consulted to ensure compliance with the Dominion Water Power Act, particularly with regard to the necessary permits and authorizations.
• Department of National Defence be consulted to ensure that information necessary to enable a ministerial decision under the National Defence Act is provided.
• Ontario Ministry of the Environment, Climate Change and Parks be consulted to confirm applicable provincial approval requirements under the Environmental Protection Act, Ontario Water Resources Act, and Species Conservation Act, 2025.
• Ontario Ministry of Natural Resources be consulted to ensure compliance with the Public Lands Act and the Environmental Assessment Act, 1990.