Ministry review of the Waasigan transmission line environmental assessment

Summary of our review

Who

Hydro One Networks Inc. (Hydro One)

What

Hydro One is proposing to construct, operate and maintain a new double-circuit 230 kilovolt (kV) transmission line between Lakehead Transformer Station (TS) in the Municipality of Shuniah and Mackenzie TS in the Town of Atikokan, and a new single-circuit 230 kV transmission line between Mackenzie TS and Dryden TS in the City of Dryden.

The total length of the Waasigan transmission line (project) would be approximately 360 kilometres (km). The proposed project would also include the separation of approximately 1 km of the double-circuit section of the existing 230 kV transmission line outside of Mackenzie TS in Atikokan (circuits F25A and D26A) into two separate single-circuit transmission lines.

Modifications would be required to the existing Hydro One stations that serve as connection points for the project.

When

The Environmental Assessment (EA) was submitted on November 17, 2023. The comment period for the EA ended January 19, 2024. Indigenous communities were given an extension until February 19, 2024, to provide comments.

Hydro One revised the EA following extensive comments from Indigenous communities, government agencies and stakeholders during the final EA review period and resubmitted an amended EA to the ministry on May 1, 2024.

Where

The transmission line would be located along an approximately 360 km corridor between Shuniah and Dryden in Northwestern Ontario.

Why

Industrial activities in Northwestern Ontario, particularly in the mining sector, are expected to drive strong electricity demand growth in the coming decades. Coupled with changes in the region’s supply and the connection of remote communities previously reliant on diesel generation to the electricity grid, the province forecasts a need for new supply to meet future demand in Northwestern Ontario.

Implementation of the project would support growth and maintain reliable electricity supply to areas west of Thunder Bay and north of Dryden.

Conclusions

The amended EA was prepared in accordance with the approved amended terms of reference and contains the information necessary to assess the potential environmental effects of the proposed project. The amended EA demonstrates that Hydro One will be able to meet its primary objective of providing for future electricity delivery needs in Northwestern Ontario set out in its amended terms of reference.

The ministry is proposing conditions be imposed if the amended EA is approved to ensure that Hydro One carries out the project in accordance with the amended EA. Indigenous communities, the public, agencies and stakeholders with an interest in the project would continue to be engaged.

1. Environmental assessment process

The Environmental Assessment Act (EAA) sets out a proponent-driven planning process designed to incorporate the consideration of the environment into decision-making by assessing the effects of a proposed project on the environment. In Ontario, the EAA sets out the general requirements for the preparation of an Environmental Assessment (EA), as well as the Ministry of the Environment, Conservation and Parks’ (MECP/ministry) evaluation process. For those proponents and projects subject to the EAA, the requirement of the EAA must be met before the project can proceed.

Proponents are required to address the potential effects of the preferred project on the natural, social, cultural and economic environments to ensure the protection, conservation and wise management of the environment. The EA helps decision-makers to determine, on the basis of the environmental effects, if a project should proceed, and if so, how the potential environmental effects can be managed.

EAs may identify a problem or opportunity, consider alternative ways of addressing the problem or opportunity, evaluate the environmental effects of the alternatives and select a preferred project from the alternatives. The proponent must consider actions to avoid, reduce and mitigate potential environmental effects. In preparing the EA, the proponent completes various studies and consults with Indigenous communities, government agencies, and the public to evaluate the alternatives and determine the preferred project. If the project is approved, the proponent is required to monitor the implementation of the project to demonstrate compliance with standards, regulations and conditions of the EAA approval.

On February 22, 2024, amendments to the EAA came into force and revoked Part II of the EAA. Pursuant to the transition provisions for these amendments, if a proponent has given a terms of reference to the Ministry under subsection 6(1) of the EAA in respect of a project and no decision has been made under section 9 or 9.1 of the EAA, the project is now deemed to be a Part II .3 project. As this is the case for this project, pursuant to these transition provisions the proposed project is deemed to be a Part II .3 project.

1.1 Terms of reference

Completing the EA process involves two separate steps — the terms of reference (ToR) and the EA. The first step requires the proponent to prepare and submit a ToR to the MECP for review and decision by the Minister of the Environment, Conservation and Parks (minister). The ToR is the work plan or framework for how the EA will be prepared.

The amended ToR was prepared pursuant to section 17.4(2)(C), which requires the proponent set out in detail the requirements for the preparation of the EA in the ToR. These requirements may differ from the requirements set out in section 17.6(2) of the EAA, which sets out what are commonly referred to as the generic requirements for an EA.

Hydro One conducted a focused EA because the proposed project is intended to address the Independent Electricity System Operator’s (IESO) need for a new transmission line between Lakehead TS and Dryden TS Mackenzie TS in Northwestern Ontario. The IESO, which operates the provincial power system, oversees Ontario’s electricity market and plans for Ontario’s future energy needs.

By proceeding pursuant to section 17.4(2)(C) of the EAA, the proponent was able to focus the assessment for the EA on:

• Providing a process to identify and assess alternative route alignments (alternative methods) for the transmission line
• Assessing potential environmental effects and benefits of the alternatives

On February 18, 2022, the former Minister of the Environment Conservation and Parks approved Hydro One’s amended ToR. The amended ToR established the framework for the preparation of the EA, including a description of the purpose and rationale for the project, which is to provide enough electricity to meet future demands in Northwestern Ontario, identifying and evaluating potential environmental effects (both positive and negative), and proposing mitigation measures and a consultation plan for obtaining input from Indigenous communities, government agencies, and the public.

1.2 Environmental assessment

After receiving the minister’s approval on the amended ToR, Hydro One proceeded to carry out the EA for the transmission line, which was prepared in accordance with the approved amended ToR and the requirements of the EAA.

Hydro One conducted consultation and data collection on the EA study areas from summer 2022 to spring 2023. Hydro One presented its preferred route for the transmission line to Indigenous communities and the public at a series of in-person open houses in Thunder Bay, Atikokan, and Dryden from January 16-18, 2023. A draft EA was circulated to Indigenous communities, agencies, and posted on the project website for review and comment in May 2023. The public circulation of the draft EA was a commitment made by Hydro One and documented in the amended ToR.

Hydro One received comments from Indigenous communities, stakeholders and the government review team (GRT) during the draft EA stage. Hydro One submitted its final EA to the ministry without engaging in an issues resolution process with Indigenous communities and stakeholders and the GRT, resulting in outstanding comments unresolved in the final EA.

On November 17, 2023, the final EA was made available for a 9-week public review and comment period, ending on January 19, 2024. The ministry granted Indigenous communities an extension until February 19, 2024, to provide comments. Indigenous communities, agencies, and members of the public raised concerns about the project which were forwarded to Hydro One for a response.

Based on comments that were submitted, including requests from Indigenous communities, agencies, and landowners to relocate project components, Hydro One was required to revise its EA and re-submit it to the ministry. Hydro One submitted the amended EA on May 1, 2024. All comments sent to the ministry will be considered by the minister before a decision is made on the project.

1.3 Ministry review

The EAA requires the ministry to prepare a review of the amended EA, known as the Ministry Review (review). The review sets out the ministry’s evaluation of the EA, including whether the EA has been prepared in accordance with the approved amended ToR, meets the requirements of the EAA, and whether the evaluation in the EA is sufficient to allow the minister to decide whether to approve the proposed project. 

The review outlines whether the information in the EA supports the recommendations and conclusions for the selection of the proposed project.  Ministry staff, with input from the EA, evaluate the technical merits of the proposed project, including the anticipated environmental effects and the proposed mitigation measures. The review also provides an overview and analysis of the Indigenous community, agency, and public comments on the EA and the proposed project.

Following the EA comment period, the regulated deadline to complete the review was extended because Hydro One required additional time to respond to comments and revise its EA documentation before the ministry could publish the review. Refer to section 3.3 of this review for more details.

The minister considers the review when deciding on the application. The minister’s decision whether to approve the project described in the EA will be made after the end of the final five-week review comment period. The minister’s decision is subject to the approval of the Lieutenant Governor in Council.

The review provides an opportunity for Indigenous communities, the EA, and the public to see how their concerns with the EA and the proposed project have been considered. During the review comment period, anyone can submit comments on the EA, the project, and the review. In addition, anyone can request that the minister refer the EA, or any matter relating to the EA, to the Ontario Land Tribunal for a hearing. Requests for a hearing must be made during this comment period. The minister will consider any requests for a hearing and determine in their sole discretion taking into account subsection 17.18(2) if a hearing is necessary.

A notice of completion of the review was issued indicating that this review has been completed and is available for a five-week comment period through the government of Ontario’s website, Ontario.ca. Copies of the review have also been distributed electronically to potentially affected or interested Indigenous communities, the EA, and those who made comments on the EA submission.

2. The proposed project

2.1 Background

The IESO completed an assessment of Northwestern Ontario’s electricity forecast, which identified additional capacity will be required in the region. The IESO and Hydro One have identified this project as essential to support growth and maintain a reliable electricity supply to areas west of Thunder Bay and north of Dryden. Industrial activities in Northwestern Ontario, particularly in the mining sector, are expected to drive strong electricity demand growth in the coming decades. Considering these changes in demand and the connection of remote communities previously reliant on diesel generation to the electricity grid, the IESO forecasts a need for new supply to meet future demand in Northwestern Ontario.

The IESO directed Hydro One to proceed with the planning of a new double-circuit 230 kV line to be constructed in two phases; Phase 1 would be between Lakehead TS and Mackenzie TS, and Phase 2 would be a new single-circuit 230 kV line between Mackenzie TS and Dryden TS. The IESO has also directed Hydro One to include the separation of two existing 230 kV transmission circuits out of Mackenzie TS in Atikokan (circuits F25A and D26A). Approximately 1 kilometre of this double-circuit section of transmission line needs to be separated into two single-circuit sections (without sharing structures), as required by transmission line planning standards.

The IESO directed Hydro One to prioritize the construction of Phase 1 with a target in-service date as close to the end of 2025 as possible. The IESO recommended that Phase 2 go into service as soon as practical after Phase 1 based on updated demand forecasts. Both Phases of the project are considered in the EA.

While Hydro One is identified as the proponent for the project, Hydro One is working in partnership with nine First Nations that will have the opportunity to invest in 50% of the Waasigan transmission line project; eight of those communities make up the Gwayakocchigewin Limited Partnership (GLP)—Migisi Sahgaigan (Eagle Lake First Nation), Fort William First Nation (Anemki Wajiw), Nigigoonsiminikaaning First Nation, Ojibway Nation of Saugeen, Lac La Croix First Nation (Zhingwaako Zaaga’Igan or Gakijiwanoong), Lac Seul First Nation (Obishikokaang), Seine River First Nation (Chima’aganing), and Wabigoon Lake Ojibway Nation (Waabigonii Zaaga’igan)—and one additional First Nation, Lac des Mille Lacs First Nation (Nezaadikaang).

If EA approval is granted, Hydro One will still require other legislative approvals to construct and operate the project. Refer to section 5.1 of this review for more details.

2.2 Purpose

The purpose of the project is to support growth and maintain reliable electricity supply to areas west of Thunder Bay and north of Dryden, recognizing the need and rationale/justification for the project as previously established by the province through analysis and decisions, including the Ministry of Energy’s Long-Term Energy Plan and the IESO recommendations. Implementation of the project is identified as a provincial priority.

2.3 Study areas

The EA used three study areas identified in the approved amended ToR: the project footprint, local study area, and regional study area to identify and assess potential impacts to the environment.

The project footprint

The project footprint is established to identify the physical area required for the project’s construction and operations, and includes the following project components: transmission line right-of-way (ROW), expansion of the existing Lakehead TS, Mackenzie TS and Dryden TS within Hydro One property, separation of approximately 1 km of the existing 230 kV transmission line circuits out of Mackenzie TS, temporary and permanent access roads, water crossings, equipment and materials laydown areas, temporary construction camps and offices, temporary land rights areas such as pull sites, aggregate pits, and helicopter pads.

Local study area

The local study area encompasses the area within which most effects of the project are expected to occur and are likely to be measurable. The local study area is the primary focus of data collection to characterize the existing environment. The local study area for most criteria (defined in the amended EA as components of the environment that are considered to have economic, social, biological, conservation, aesthetic, or cultural value) includes lands within approximately 1 km of the project footprint.

Regional study area

The regional study area includes areas beyond the local study area (generally up to approximately 5 km or more from the project footprint). This area was used to measure broader-scale existing environmental conditions and provide a regional context for the maximum predicted geographic extent of direct and indirect effects from the project (for example, changes to downstream water quality, migratory ranges, or changes to the economy, including regional employment and incomes). Cumulative effects from the project in combination with past, present, and reasonably foreseeable future developments are typically assessed at this larger spatial scale.

2.4 Description of the proposed project

Hydro One considered alternative route alignments during the development of the approved amended ToR. A preliminary preferred alternative route alignment was presented to the public on January 3, 2023, and the final preferred alignment was confirmed by Hydro One’s revised amended EA submission on May 1, 2024.

The project would be located along an approximately 360 km corridor between Lakehead TS in the Municipality of Shuniah and Dryden TS in the City of Dryden (see Figure 1—project location). The proposed ROW for the project would be approximately 46 metres (m) wide. In some sections of the ROW, additional width may be required depending on the specific location of the new transmission line, the local terrain, distance between the transmission structures and specific contractor requirements. The proposed ROW for the project generally follows existing transmission lines in the area (see appendix 3.0—B to the amended EA  [PDF] for detailed maps of the project footprint).

The project includes the following main components:

• new overhead Alternating Current (AC) 230 kV transmission lines and associated components (for example, tower structures) that would be located within a typical 46 m wide transmission line ROW, approximately 360 km in length
• modifications to existing infrastructure at the Lakehead TS, Mackenzie TS and Dryden TS, and separation of the existing 230 kV transmission lines (circuits F25A and D26A) out of the Mackenzie TS in Atikokan
• development of temporary supportive infrastructure associated with construction including, but not limited to, temporary access roads, temporary workspaces (including helicopter staging areas), construction camps, laydown areas, and waterbody crossings
• development of aggregate pits to support the project
• development of associated permanent infrastructure, such as access roads and waterbody crossings, to support the operation and maintenance stage of the project

3. Results of the ministry review

The review provides an analysis of the amended EA. This review is not intended to summarize the EA, nor present the information found in the EA. For information on the evaluation process used to assess the alternatives, please refer to the amended EA. The amended EA and supporting documentation outline the EA planning process and demonstrates how the proponent selected the preferred project.

The purpose of the ministry review is to determine whether:

• the EA has met the requirements of the ToR and the EAA
• there are any outstanding issues with the EA
• the proposed undertaking has technical merit

Must haves in the EA:

• the EA must be prepared in accordance with the approved ToR
• the EA must include all the basic EAA information requirements
• the EA must demonstrate where all the additional commitments in the ToR were met, including studies and the consultation process

3.1 Conformance with ToR and EAA

3.1.1 Ministry analysis

The ministry coordinated an analysis of the amended EA with the GRT that, in part, looked at whether the amended EA was prepared in accordance with the amended ToR. The ministry has concluded that the amended EA followed the framework in the approved amended ToR and meets the requirements of the EAA and any commitments made in the amended ToR were met by the proponent. 

Appendix A summarizes this analysis.

3.1.2 Consultation

Section 17.3 of the EAA states:

When preparing proposed terms of reference and an environmental assessment, the proponent shall consult with such persons as may be interested.

One of the key requirements of the EAA is consultation with Indigenous communities, agencies, and the public during the preparation of the EA. The proponent is responsible for meeting its consultation requirements prior to submitting the EA to the ministry and the consultation must be carried out in accordance with the consultation plan in the approved amended ToR. 

Hydro One’s consultation program included:

• establishing a project website with EA documentation
• distribution of notices (notice of commencement, notice of public open house)
• hosting three public open houses and one community drop-in session
• consultation with agencies and organizations
• review of field plans by agencies and Indigenous communities
• agency workshops
• engagement with Indigenous communities and groups
• circulating notices via local newspapers and mail outs
• newsletter updates
• publishing the draft EA for review and a comment period from May 17, 2023 to July 7, 2023

Hydro One documented its consultation activities adequately in the amended EA. Section 4.0 of the amended EA provides an overview of the consultation activities, with the complete consultation record documented in its Record of Consultation.

Following submission of the EA to the ministry, the ministry undertook consultation in accordance with the EAA, beginning on November 17, 2023 and ending on May 14, 2024 when agencies confirmed that all comments have been addressed. Indigenous communities, the GRT, and members of the public had an opportunity to review the EA and submit comments to the ministry regarding the fulfillment of ToR requirements, the EA, and the proposed project. Comments received by the ministry during the EA comment period were forwarded to Hydro One for a response, and Indigenous communities and the GRT confirmed that their comments had been addressed following Hydro One’s submission of an amended EA on May 1, 2024. A summary of the comments received along with Hydro One’s responses is included in Tables 1 to 4 of Appendix B to this review. Tables 1 to 3 have been provided to Indigenous communities, stakeholders and the GRT for its review and are available to the public upon request to the ministry (see “making a submission” at the end of this review for contact information).

Government review team

Consultation with the GRT occurred throughout the EA process. This included:

• pre-submission discussions
• technical meetings with ministry staff and key members of the GRT
• alternative routing surveys
• community open house discussions and completed comment forms
• GRT workshops
• comments received through the proponent’s project phone number and email
• comments received during the review period for the draft EA were discussed

Hydro One received comments from the GRT, including the MECP, the Ministry of Natural Resources and Forestry (MNRF), the Ministry of Tourism, Culture and Sport (MTCS), and the Ministry of Citizenship and Multiculturalism (MCM) during consultation on the EA. Themes identified in these comments included:

• feedback on the alternative route evaluation methodology to determine a preferred route
• a need to better understand the project design, including how the project will relate to existing transmission line easements and the role of the project within the electricity system
• questions about how the project may affect the environment, including potential impacts to wildlife, recreation and tourism, built and cultural heritage, visual aesthetics, water quality, human health and community wellbeing
• feedback on engagement activities, tools and messaging to date
• input regarding route alignments and visual effects from the transmission line, including interest in the visual effects assessment request to highlight how commitments made in the amended ToR were fulfilled in the EA
• interest in the construction mitigation measures identified in the environmental protection planning document
• input to include relevant regulations and approvals to be reflected in the final EA report

A summary of consultation with the GRT during the preparation of the amended EA is included in section 4.0 of the amended EA and its Record of Consultation.

Following the formal submission of the EA to the ministry, GRT members were provided with a copy of the final EA for review. Comments from MECP, MCM, MNRF, the Ministry of Mines (MINES), and the Lakehead Region Conservation Authority (LRCA) were received during the comment period and forwarded to Hydro One for a response and subsequently addressed in Hydro One’s revisions made to the amended EA. Refer to section 3.3. of this review or Appendix B regarding these comments.

Public consultation

Hydro One used a variety of methods to consult with the public including public notices, establishing a project website, conducting three public open houses and a community drop-in, as well as direct community engagement via mail-outs and newspapers. The Notice of Commencement of EA was issued on March 9, 2022. The public open houses were held from May 3 to 5, 2022, from January 16 to 18, 2023, and from June 13 to 22, 2023. The community drop-in session was held from April 18 to 19, 2023. A summary of consultation with public stakeholders during the preparation of the EA is included in Section 4.0 of the EA and its Record of Consultation.

Hydro One received feedback from a group of residents in the Kaministiquia area called Neighbours on the Line (NOTL). NOTL raised concerns about the preliminary preferred route that was publicly presented during the preparation of the EA on January 3, 2023, and suggested an alternative route alignment for the project. Hydro One considered and evaluated the alternative alignments put forth by NOTL, and this is documented in Appendix 2.0—C of the EA. The evaluation conducted by Hydro One concluded that the NOTL proposed routes have more disadvantages than advantages and will not be carried forward.

Hydro One also received comments from a group of residents in the Shebandowan Lake area called the Shebandowan Lake Camper’s Association (SLCA). SLCA raised concerns related to impacts to the natural environment and Shebandowan Lake, visual impacts, and impacts to property values. Hydro One met with SCLA three times between February 22, 2023, and April 18, 2023 to discuss their concerns and possible refinements that could be made to the preliminary preferred route.

Themes identified in comments received from the public included:

• feedback on the alternative route evaluation methodology to determine a preferred route
• input from property owners impacted by or in the vicinity of the preliminary preferred route
• need to better understand the project design, including how the project will relate to existing transmission line easements and the role of the project within the electricity system
• how the project may affect the environment, including to wildlife, recreation and tourism, built and cultural heritage, visual aesthetics, water quality, human health and community wellbeing
• feedback on engagement activities, tools and messaging to date
• concerns related to the use of herbicides for building and maintaining the line
• input regarding route alignment and visual effects from line, including interest in the visual effects assessment
• comments regarding potential for trespassing or unauthorized access through the corridor adjacent to private properties

Hydro One made the draft EA and its supporting documents available on the project website for members of the public for comment from May 17, 2023 to July 7, 2023.

The notice of submission of the final EA was issued on November 17, 2023, and was circulated to the project contact list as well as posted on the project website. The ministry received comments from nine members of the public. Refer to Section 3.3. of this review or Appendix B regarding these comments.

Indigenous community consultation

In addition to the requirement in the EAA that the proponent consult with interested persons, the ministry delegated to the proponent the procedural elements of the Crown’s duty to consult with Indigenous communities whose existing constitutionally protected rights may be impacted by the proposed project.

The following Indigenous communities were identified for consultation purposes:

• Eagle Lake First Nation (Migisi Sahgaigan)*
• Fort William First Nation (Anemki Wajiw)*
• Gakijiwanong Anishinaabe Nation (formerly Lac La Croix)*
• Lac Seul First Nation (Obishikokaang)*
• Ojibway Nation of Saugeen*
• Seine River First Nation (Chima’aganing)*
• Nigigoonsiminikaaning First Nation (Red Gut)*
• Wabigoon Lake Ojibway Nation (Waabigonii Zaaga’igan)*
• Lac des Mille Lacs First Nation (Nezaadikaang)
• Mitaanjigamiing First Nation
• Couchiching First Nation
• Grand Council Treaty #3
• Northwestern Ontario Métis Community (NWOMC) and Region 2
• Red Sky Métis Independent Nation

While Hydro One is identified as the proponent for the project, Hydro One is working in partnership with a total of nine First Nations, eight of which make up Gwayakocchigewin Limited Partnership (GLP) (marked with an asterisk above) and one additional First Nation, Lac des Mille Lacs First Nation (Nezaadikaang).

Formal study notices were circulated to Indigenous communities. Correspondence from Hydro One invited the communities to participate during the ToR phase of the EA and each round of EA consultation. In addition to the formal study notices and open houses, Indigenous communities were given draft studies to review throughout the planning process, including cultural heritage reports, and surveys were administered to gather feedback on the preferred route alignment. Additional engagement activities were undertaken during the preparation of the EA to obtain input from the identified Indigenous communities, including follow-up calls and emails to communities to verify receipt of materials, and circulation of the draft EA.

Hydro One offered the opportunity for Indigenous communities to undertake Indigenous knowledge studies to inform the EA process. To support this, Hydro One offered financial assistance through community-specific capacity funding agreements to assist with Indigenous participation in the EA process including, but not limited to, document review, supporting engagement logistics, coordinating community input and participation, and community-led gathering and recording of Indigenous knowledge. Capacity funding agreements were offered to, and discussed with, all participating Indigenous communities and organizations throughout the EA phase of the project to advance participation. Capacity funding agreements were signed with most communities during the EA phase.

Themes identified in the comments from Indigenous communities included:

• concerns related to herbicide use when building and maintaining the transmission line
• requests for commitments related to monitoring, restoration and communication during construction
• interest in reviewing the construction mitigation measures Environmental Protection Planning document and associated monitoring plans
• importance for the integration of Indigenous knowledge in the final EA

Following the submission of the final EA to the ministry, comments were received from the GLP, Grand Council Treaty #3, Mitaanjigamiing First Nation, Couchiching First Nation, and Northwestern Ontario Métis Community (NWOMC) and Region 2. Refer to section 3.3. of this review or Appendix B regarding these comments.

Ministry conclusions on the consultation program

The EAA requires that the proponent consult with all interested persons during the preparation of the EA, provide a description of consultation activities undertaken by the proponent, and document consultation results. Overall, the ministry believes that Hydro One provided sufficient opportunities for Indigenous, government agency, and public consultation during the preparation and finalization of the amended EA. Hydro One has committed to continue to engage with Indigenous communities during detailed design of the proposed project. 

The ministry is satisfied that the amended EA consultation that was undertaken is consistent with the Codes of Practice for Consultation in Ontario’s EA Process and best practices, meets the requirements of the EAA, and followed the consultation plan outlined in the approved amended ToR.

3.2 EA process

EA is a planning process that requires a proponent to identify a problem or opportunity, consider alternative ways of addressing the problem or opportunity, evaluate the potential environmental effects of alternatives against criteria, and select a preferred alternative based on the results of the evaluation.

Hydro One followed a logical and transparent decision-making process to select the preferred method to identify ways to construct a new transmission line to support electricity demand in Northwestern Ontario and maintain reliable electricity supply to areas west of Thunder Bay and north of Dryden. Below is a summary of the EA process followed, including the study areas used, and the methodology for assessing alternatives and environmental effects.

Please refer to Appendix A of this review for the ministry’s analysis of how the EA has met the requirements of the EAA and has been prepared in accordance with the approved amended ToR.

3.2.1 Focused EA

Hydro One prepared its amended EA in accordance with section 17.4(2)(C) of the EAA, which resulted in an EA that “focused” on the consideration of alternative transmission line routes and methods to carry forward into the EA. The amended ToR provided justification for limiting the examination of alternatives through an analysis of alternatives available to Hydro One for achieving the recommendations of the IESO.

The amended ToR set out a methodology for evaluating and comparing alternative routes based on their potential effects and for determining the preferred route in the EA.  Alternative route alignments were evaluated according to a set of natural, socio-economic, Indigenous and technical criteria. The final list of alternative route evaluation criteria and indicators was refined at the beginning of the EA with input from Indigenous communities, government agencies and members of the public. A preferred route was then selected based on the comparison of alternative transmission line corridors, and a preliminary project footprint was then developed for a preferred route and assessed in more detail in the EA.

3.2.2 Description of the Environment in the Study Areas

A preliminary description of the existing environment was provided in the amended ToR. The amended ToR contained a commitment that a more detailed description of the existing environmental conditions would be prepared as part of the EA to assess the potential effects of the alternatives on the environment. 

Section 5.3 of the amended EA describes the spatial and temporal boundaries within which potential environmental effects of the project are expected to occur, including the project footprint, local study area, and regional study area.

A description of the existing environment has been completed for each environmental criterion to provide the baseline for determining the potential effects resulting from the project. The study methods, specific data sources, and the existing environment in which the project will be constructed, operated and maintained, are described in detail in Sections 6.0 and 7.0 of the amended EA, along with the results of field surveys completed in support of the effects assessment:

• Section 6.1—Geology
• Section 6.2—Surface water
• Section 6.3—Groundwater
• Section 6.4—Vegetation and wetlands
• Section 6.5—Wildlife and wildlife habitat
• Section 6.6—Fish and fish habitat
• Section 6.7—Air quality
• Section 6.8—Greenhouse gas
• Section 6.9—Acoustic environment
• Section 7.1—Land and resource use
• Section 7.2—Community well being
• Section 7.3—Economy
• Section 7.4—Aesthetics
• Section 7.5—Archaeological resources
• Section 7.6—Built heritage resources

The ministry is satisfied that a broad definition of the environment was considered and a description of existing environmental conditions in the study areas was provided.

3.2.3 Assessment of alternative methods

Section 2.2 of the amended EA describes that alternative methods were identified and considered to address specific concerns raised by Indigenous communities and stakeholders, such as property owners and municipalities, to avoid or minimize project effects on natural and/or socio-economic features.

The following alternative methods were evaluated in the EA:

1. Alternative route evaluation.
2. Separation of circuits F25A and D26A west out of Mackenzie TS.
3. Alternative route segments through provincial parks and conservation reserves.
4. Preliminary preferred route feedback and local route refinements.

1—Alternative route evaluation

Alternative route alignments were compared using a project footprint that includes associated infrastructure (for example, access roads, laydown areas, temporary construction camps, etc.). As such, Hydro One developed a preliminary project footprint for each alternative route identified in the amended ToR so they could be compared to select a preferred project footprint for further analysis in the EA.

Determination of a preferred project footprint included an assessment of:

• viable transmission line alignments (for example, follow existing linear features to avoid disturbances)
• the siting of transmission structures (for example, design limitations of towers)
• the siting of laydown areas and construction camps (for example, avoidance of sensitive land uses)
• alternative transmission structure types (for example, practicality and cost)
• alternative access and construction plan (for example, accessibility for helicopters and heavy equipment to construct and maintain the line)
• aggregate sites (for example, proximity to existing aggregate sites as potential sources of aggregate)

The alternative route evaluation included a multi-criteria option analysis approach to support the identification of a preferred route for the project. The alternative route analysis used the criteria and indicators provided in the amended ToR to identify the route that is most preferred from the perspective of four criteria categories; Indigenous culture, values, and land use, the natural environment, the socio-economic environment, and technical and cost considerations. Alternative routes were compared for each criteria category and ranked to determine the preferred route.

2—Separation of circuits F25A and D26A west out of Mackenzie TS

Hydro One was directed by the IESO to separate the existing 230 kV transmission circuits, including developing a new ROW not parallel to the existing transmission line or expanding the existing ROW to the north or south side of the existing transmission line ROW.

As a part of this alternative method, considerations for whether to develop a new ROW not parallel to the existing ROW or to expand the ROW to the north or south included:

• evaluating the effects to the natural environment, such as amount of vegetation clearing
• technical design considerations, such as terrain
• assessing the constraints of existing transmission lines and the required connection location of the new transmission line at Mackenzie TS

When considering the alternative of creating a new ROW not parallel to the existing line, it appeared that the disadvantages included increased habitat fragmentation on the landscape, increased overall project footprint (i.e., longer ROW), and increased construction impacts (i.e., increased requirement for new access). Hydro One determined that the preferred alternative was to expand the existing ROW to minimize adverse effects on the environment.

When considering whether to expand to the north or the south of the existing transmission line, Hydro One determined that the preferred alternative would be to relocate circuit F25A to the south side of the existing transmission line. This was determined to be preferred as relocating D26A to the north of the existing transmission line would involve relocation of distribution assets from Atikokan Hydro, requiring additional cost and construction impacts. In addition, Hydro One determined that constructability is more favourable on the south side (i.e., less tree clearing and more favourable soil conditions). Therefore, due to the south side having more advantages from a natural environment, technical and cost perspective, to accommodate this separation Hydro One proposed that the ROW will be expanded to the south.

3—Alternative route segments through provincial parks and conservation reserves

The project, as proposed, would cross Turtle River-White Otter Provincial Park, Campus Lake Conservation Reserve and Quetico Provincial Park (access road use only). Hydro One assessed different ways of implementing the project to minimize impacts to provincial parks and conservation reserves.

During project planning, each protected area was reviewed by Hydro One individually to determine the appropriate and feasible mitigation measures that could be implemented to decrease potential adverse effects on the environment. Hydro One identified site-specific design changes that would limit adverse effects in the provincial parks and conservation reserves.

4—Preliminary preferred route feedback and local route refinements

Hydro One considered local route refinement suggestions from Indigenous communities, agencies, landowners, or stakeholders following the public release of the preferred route alignment.

Alternative route alignment suggestions from Indigenous communities, agencies, community organizations, and affected landowners were considered by Hydro One using the alternative route evaluation approach to determine the advantages and disadvantages of the requested change, and its effects.

Do-nothing alternative

The do-nothing alternative was also considered as a benchmark comparison associated with the analysis in the amended EA of the advantages and disadvantages of proceeding with the preferred alternative. As a result, the ministry gained an understanding of proceeding with the project versus a do-nothing scenario in this regard.

3.2.4 Assessment of environmental effects

Hydro One describes the potential effects considerations of the project in section 8.0 (Net Effects) and section 9.0 (Cumulative Effects) of the amended EA. The amended EA includes a summary of the net effects assessment for each of the environmental criterion (natural environment, socio-economic environment, cultural environment, and built environment), an assessment of cumulative effects and advantages and disadvantages of each alternative. The amended EA assesses both positive and negative effects of the alternatives. The evaluation method included identifying proposed mitigation measures to minimize or avoid any potential negative environmental effects of the preferred project being considered as part of the EA process. The amended EA identifies the net effects of the project during both construction and operation.

Natural environment net effects include changes to surface water and groundwater quality and quantity, ecosystem loss or alteration, dust and air emissions, habitat loss, vehicular collisions, noise and vibration impacts, and greenhouse gas emissions. Socio-economic environment net effects include changes to protected areas and land use, access and public safety, aesthetics, noise and emission nuisances, and employment opportunities. Cultural and built environment net effects include changes to lands used for culturally sensitive purposes and changes to properties with potential cultural heritage value.

Proceeding with the project is predicted to cause net effects to the environment. However, when taking into account the implementation of the mitigation measures described in sections 6.0 and 7.0 of the amended EA, Hydro One determined that the net effects associated with the project can be mitigated by standard and site-specific environmental protection measures which will be included in the Environmental Protection Planning (EPP) document. Development of the EPP is a commitment of the amended EA and is described in more detail in the following section (3.2.5) of this review.

3.2.5 Monitoring and commitments

A description of future commitments to mitigate impacts and environmental effects monitoring is provided in section 10.0 (Monitoring and Commitments) of the amended EA. Monitoring strategies were developed so that environmental effects can be monitored during construction, operation, and maintenance of the transmission line to confirm that predicted net effects are not exceeded, unexpected negative impacts are addressed, and mitigation measures are effective.

Section 10.2 (Environmental Protection Planning) of the amended EA describes that an EPP would be developed and implemented for the project, which describes the industry standards, best management practices (BMPs), and site-specific mitigation for environmental protection that would be implemented during the construction of the project to avoid or reduce potential environmental effects on the natural and socio-economic environments.

The EPP would also summarize site-specific mitigations that would be implemented, as required, for sensitive locations where additional actions beyond activity-specific mitigations are warranted. These sensitive locations include, but are not limited to: provincially significant wetlands; fish and aquatic habitat; areas of natural and scientific interest; woodlots and significant woodlands; significant wildlife habitat; significant valley lands; significant species at risk habitat; fish and fish habitat; and, provincial parks and conservation reserves.

The EPP would be provided to affected Indigenous communities and agencies for review and input at least 90 days in advance of construction. The project’s compliance with the EPP and the requirements of project-specific permits, approvals and agreements are a commitment of the amended EA.

Monitoring during the operation and maintenance phase of the project is addressed through the project effects and EA compliance monitoring activities outlined in Section 10.4 of the amended EA. The complete list of environmental commitments identified during the EA stage for the project are summarized in Appendix 10.0—A (Commitments) of the amended EA. These commitments are in addition or supplemental to the construction monitoring activities summarized in Table 10.6—1 (Construction Monitoring Program) of the amended EA.

The amended EA commits to an on-going compliance monitoring program. The results of the compliance monitoring program will be reported to the MECP and/or the appropriate review agency and will include implementation of mitigation measures and completion of commitments.

3.2.6 Ministry conclusions on the EA process

Overall, the ministry is satisfied with the proponent’s decision-making process and that the process is consistent with the requirements of the EAA and the approved amended ToR.  The amended EA confirms the need for the project, provides a description of the environment potentially affected which considers the EAAs broad definition of the environment, and considers alternative methods for delivering the project related to transmission line alignments, including alterations and revised routes proposed by Indigenous communities, stakeholders, landowners and members of the public. The amended EA identifies the potential effects of alternatives along with mitigation measures and assesses them based on their relative advantages and disadvantages. Net effects of the project are identified in the amended EA and monitoring measures are proposed to manage environmental effects.

3.3 Comments on the project

3.3.1 Key issues

Issues and concerns from Indigenous communities, the GRT, and the public regarding the proposed project were received by the ministry during the review and comment period that followed the submission of the final EA. All comments received, along with the responses provided by Hydro One, are included in Tables 1 to 3 in Appendix B of this review.

This section of the review summarizes only the key issues that were raised during the EA process that required Hydro One to make changes to the proposed project infrastructure, resulting in Hydro One revising its EA documentation and resubmitting an amended EA to the ministry on May 1, 2024. A detailed table of these comments and Hydro One’s responses is included in Table 4 in Appendix B of this review.

Government review team comments

Proximity to Steep Rock Mine

MNRF raised concerns with the location of transmission line infrastructure (for example, towers) in proximity to the former Steep Rock Mine site. MNRF provided information on design refinements necessary to avoid impacts at the site, which Hydro One agreed to implement as a new commitment (#949) in the revised Appendix 10.0A of the amended EA.  MNRF was satisfied with the revised commitment and had no further concerns. The ministry is satisfied that the concern raised by the MNRF was addressed by Hydro One by revising sections of the EA and its mapbooks and including a new commitment in the amended EA.

Aesthetic Impacts to Quetico Provincial Park

Ontario Parks raised concerns regarding the accuracy of the statement in section 7.4.7.3.1.3 of the EA that the visual impact of the transmission line to Quetico Provincial Park, would be low, and requested the section be revised to include a discussion about the impacts the project would have on park users.

Hydro One agreed to revise the wording in the section to note that given the park’s wilderness classification, the volume of park users and that structures may be visible in new areas depending on the structure height, the visual impact to Quetico Provincial Park, would be “moderate”.

Ontario Parks reviewed the revised section 7.4.7.3.1.3 of the amended EA and had no further concerns. The ministry is satisfied that the concern raised by Ontario Parks was addressed by Hydro One through revisions to the EA.

Addendum to Appendix 7.6 (Cultural Heritage Existing Conditions and Preliminary Heritage Assessment Impact)

MCM commented that property specific Cultural Heritage Evaluation Reports (CHER) are required to be completed by Hydro One to establish whether 621 McGogy Road, 71 Kivilahti Road, and 342 Silver Falls have cultural heritage value per Ontario Regulation 9/06 or 10/06 of the Ontario Heritage Act. In addition, the MCM noted that a “Provincial Heritage Property” is located in the vicinity of the project (Shebandowan Lake Control Dam).

Based on this information provided by the MCM, Hydro One reviewed the locations of these properties in relation to the project footprint and found that direct impacts are anticipated to 342 Silver Falls Road if the project is implemented. No potential direct or indirect impacts were identified to 621 McGogy Road, 71 Kivilahti Road, or the Shebandowan Lake Control Dam.

An addendum to Appendix 7.6 (Cultural Heritage Existing Conditions and Preliminary Heritage Assessment Impact) of the EA was prepared by Hydro One to document these new findings related to 342 Silver Falls Road, 621 McGogy Road, 71 Kivilahti Road and Shebandowan Lake Control Dam, and included in the amended EA. The amended EA includes a commitment to complete a Cultural Heritage Evaluation Report, and possible Heritage Impact Assessment, prior to construction, for 342 Silver Falls Road to determine whether this property has cultural heritage value or interest.

MCM confirmed that it has reviewed the addendum to Appendix 7.6 in the amended EA and has no further concerns. The ministry is satisfied that the comment has been addressed.

Public comments

Nine members of the public provided comments to the MECP on the final EA, related to:

• requests to consider alternative route alignments for the transmission line, including routes proposed by residents group “Neighbours on the Line”
• concerns related to adequacy of EA consultation and transparency in the development of the preferred route alignment
• question about what is being done with the wood being cut from the transmission line ROW
• concerns about the use of easements
• concerns about impacts on wildlife, groundwater and water quality, wetlands local roads, and construction disruptions.
• concerns about aesthetic and noise impacts
• concerns about the use of herbicides and vegetation clearing
• questions about the land compensation process

The ministry forwarded all public comments to Hydro One for a response, which is included in Appendix B—Table 2 of this review. In its response, Hydro One demonstrated how the concerns and questions raised were considered in the development of the EA, and where the information can be found in the amended EA documentation.

The ministry is satisfied that all public comments raised during the final EA were addressed by Hydro One and there are no outstanding concerns that cannot be addressed through commitments made in the EA.

Private landowner impacts

During the development of the EA, Hydro One consulted with landowners near the proposed project about potential impacts to private property. Hydro One reached out to several landowners to discuss agreements to use of the owners’ lands for this project. Through those discussions and negotiations the landowners made several comments and requests which led to changes to the project.

One landowner that was to be directly impacted by the proposed project requested a revised routing around their property near Plateau Lake. Hydro One agreed to make a routing change that would shift the proposed transmission line slightly to avoid impacts to this landowner’s property. This version of the project was presented to the public on November 17, 2023, with the submission of the EA.

Following the end of the public comment period of the EA on January 19, 2024, it came to Hydro One’s attention through a comment from a different adjacent landowner that the change Hydro One made to avoid impacts for the previous landowner created an impact to the adjacent landowner’s property.

In response, Hydro One proposed a new routing change that would shift the alignment of the transmission line slightly so it would rejoin and parallel the existing transmission line corridor in the area before reaching the boundary of the affected landowners’ properties, which would minimize impacts to both of the parcels. Both landowners confirmed with Hydro One that they support the proposed refinement. Hydro One indicated that no new potential effects or mitigation measures would be required for this change and the overall conclusions of the EA and determination of significance for all environmental components remain unchanged. The new routing has been updated in the sections of the amended EA and its map books.

The ministry is satisfied that the concerns raised by the landowners were addressed by Hydro One through changes made to the amended EA.

Indigenous community comments

The ministry followed up with all Indigenous communities during the public review period of the EA. Responses were received from all communities indicating whether the community had comments to provide on the EA or not. The GLP, Grand Council Treaty #3, Mitaanjigamiing First Nation, Couchiching First Nation, and Northwestern Ontario Métis Community (NWOMC) and Region 2 submitted comments. Lac des Mille Lacs First Nation (Nezaadikaang) and Red Sky Métis Independent Nation confirmed with the ministry that they had no comments on the EA. A complete table of all comments received, and Hydro One’s responses can be found in Appendix B — Table 3 of this review.

White Otter Camp location

Hydro One received a comment from Wabigoon Lake Ojibway Nation noting culturally sensitive concerns with the proposed White Otter Camp location based on its proximity to White Otter Lake.

As a result of the concerns, Hydro One assessed other sites in the general area (approximately 5 km) to evaluate other possible locations of the White Otter Camp further away from White Otter Lake. Hydro One proposed a change to relocate the White Otter Camp to a location immediately adjacent to its formerly proposed location. This new location is in the local study area described in the EA report and was presented to Wabigoon Lake Ojibway Nation for its review. Hydro One’s contractor (Valard) met with Wabigoon Lake Ojibway Nation Chief and Council who confirmed they had no concerns with the proposed new White Otter Camp location.

Hydro One also included a new commitment (Commitment #782) in the EA that restricts access and construction for purposes of the project to specific areas near White Otter Lake.

The GLP (representing Wabigoon Lake Ojibway Nation) confirmed with Hydro One that Wabigoon Lake Ojibway Nation has no outstanding comments or concerns with the new White Otter Camp location. All Indigenous communities reviewed the revised location and confirmed they had no concerns with the White Otter Camp relocation in writing with Hydro One, which is documented in the amended EAs revised Record of Consultation.

The ministry is satisfied that the concern raised by Wabigoon Lake Ojibway Nation was addressed by Hydro One through changes to the EA, including revisions to sections of the EA and its mapbooks, and a new commitment in the amended EA to avoid impacts to White Otter Lake at the recommendation of Wabigoon Lake Ojibway Nation.

Northwestern Ontario Métis Community (NWOMC) and Region 2 name change

NWOMC and Region 2 requested a minor name change in the final EA report. The name was formerly listed as “Métis Nation of Ontario” and has been requested to be changed to “Northwestern Ontario Métis Community (NWOMC) and Region 2”.

Hydro One addressed the comment by revising the following sections of the final EA with the name change. The ministry is satisfied that the request to updated references to NWOMC and Region 2 in the EA was addressed by Hydro One through changes to the EA, including revisions to sections 6.9, 7.3, and 7.8 in the amended EA.

Updated Appendix 10—0A (Commitments List)

Hydro One received general feedback from Indigenous communities, as well as the GRT, following a review of the final EA raising concerns about the number of commitments (over 900) and the ability to track and report on them. Concerns were also raised about redundant and duplicative commitments.

The commitments list included in the final EA report included instances where the commitment wording is similar or nearly identical. Hydro One updated the list to resolve these instances either by removing a duplicate commitment or by merging similar commitments to allow better management of the commitments by Hydro One and Hydro One’s construction contractor (Valard) and for EA compliance monitoring by MECP and Indigenous communities.

To resolve comments on the Final EA Report, Hydro One updated Appendix 10.0—A (Commitments) to include additional and revised commitments. Hydro One and the GLP worked together on proposed changes to the commitments. The GLP provided these requested changes to MECP on January 31, 2024. The proposed changes include new commitments and additions to existing commitments.

MECP has no concerns with Hydro One’s revision to Appendix 10.0A (Commitments Table) and is satisfied that the changes to consolidate and revise the commitments is in response to specific comments raised by Indigenous communities.

3.3.2 Conclusion

Hydro One responded to, and addressed, all comments received during the EA submission comment period on the final EA study report. As a result of comments that requested changes be made to proposed project infrastructure, Hydro One revised its documentation and project commitments and resubmitted an amended EA to the ministry on May 1, 2024. The ministry is of the opinion that the Waasigan transmission line would be designed and operated to comply with the ministry’s standards and that the environmental effects of the proposed project would be managed through the commitments made in the amended EA, through conditions of approval, or through additional work that must be carried out by Hydro One in support of future approval applications, if the amended EA is approved.

4. Summary of the ministry review

The review has explained the ministry’s analysis of the Waasigan transmission line amended EA.

This review documents the ministry’s conclusion’s including:

• That the amended EA complies with the requirements of the approved amended ToR and has been prepared in accordance with the EAA. The amended EA provides sufficient information about the project and its potential impacts to enable a decision to be made about the application to proceed with the project.
• That the amended EA includes: an assessment and evaluation of alternative methods to arrive at the preferred project, an assessment the potential environmental effects of the alternative methods and the preferred alternative, an assessment of the advantages and disadvantages of the preferred alternative, and provides a description of mitigation and monitoring measures to address the potential negative environmental effects of the proposed project
   
• That appropriate opportunities were provided for the Indigenous communities, GRT and the public to participate and comment during the development of the EA. Concerns raised by Indigenous communities, the GRT, and the public have been considered and addressed by the proponent in the amended EA, or a commitment has been made to consider the concerns further through future discussions, commitments and permitting and approval processes.
• If approval of the project is obtained under the EAA, standard conditions of approval are recommended for the implementation of the project (see section 4.1.1 below).

4.1.1 Proposed conditions of approval

The ministry proposes to include several standard conditions of approval should the project be approved to proceed:

• general requirements to comply with the amended EA and commitments made
• documentation requirements for the public record
• compliance monitoring provisions for the proponent to conduct and report on
• preparation of a complaints protocol to respond to all complaints received during construction and operation

The ministry is proposing a condition of approval that requires Hydro One to follow its EA change procedure as set out in section 11.3 of its amended EA, which describes a change management process for components of the project that could deviate from what is described in the amended EA.

This list is not exhaustive and additional conditions may be proposed subject to further review and consultation. During the five-week review comment period and prior to the ministry making a recommendation to the minister regarding approval of the project, additional conditions may be proposed to ensure that the environment remains protected.

5. What happens now

The review will be made available for a five-week comment period. During this time, all interested parties, including Indigenous communities, the GRT, and members of the public can submit comments to the ministry about the proposed project, the amended EA and/or the review. At this time, anyone can make a written request that the minister refer either all or part of the amended EA to the Ontario Land Tribunal for a hearing if they feel their environmental concerns have not been considered.

At the end of the review comment period, ministry staff will make a recommendation to the minister regarding approval of the project. When making a decision, the minister will consider the requirements set out in the EAA, including the purpose of the EAA, the amended EA itself, the review of the amended EA, comments received during the formal comment periods, in addition to other matters the minister may consider relevant.

The minister will make one of the following decisions:

• give approval to proceed with the project
• give approval to proceed with the project subject to conditions
• refuse to give approval to proceed with the project

Prior to making that decision, the minister may also refer either part of or the entire EA to mediation or refer either part of or the entire EA to the Ontario Land Tribunal for a decision.

The minister’s decision on the application is subject to the approval of the Lieutenant Governor in Council.

5.1 Additional approvals required

If EAA approval is granted, Hydro One will still need to obtain other legislative approvals to design, construct and operate this project. Section 1.7.2.1.4 (Other Relevant Provincial Legislation, Permits, Approvals and Authorizations) Table 1.7-1 of the amended EA outlines all additional approvals that may be required, such as:

• environmental compliance approvals (ECA) and registration to the air and noise environmental activity and sector registry (EASR) under the Environmental Protection Act
• ECAs and permit to take water (PTTW) under the Ontario Water Resources Act
• authorizations and work permits under the Provincial Parks and Conservation Reserves Act
• land use and work permits under the Public Lands Act
• burn permit under the Forest Fires Prevention Act
• permit under the Pesticides Act
• permits and authorizations under the Fish and Wildlife Conservation Act and Lakes and Rivers Improvement Act
• licenses, permits and agreements under the Crown Forest Sustainability Act
• exemptions and aggregate permits under the Aggregate Resources Act
• withdrawal request from the Mining Act
• permits under the Public Transportation and Highway Improvement Act
• compliance with the Ontario Heritage Act

These approvals cannot be issued until approval is given under the EAA.

5.2 Modifying or amending the proposed project

The ministry is proposing a condition of approval that requires Hydro One to follow its EA change procedure as set out in section 11.3 of its amended EA, which describes a change management process for components of the project that could deviate from what is described in the amended EA.

The proposed "limits of work" for specific changes and activities where a new EAA approval would not be required are outlined in section 11.3.1.2 of the amended EA and include minor refinements to the project footprint, use of access roads, changes to temporary construction staging areas, and aggregate site relocations. The mitigation measures and monitoring requirements outlined in the amended EA would apply to any design refinements considered under the limits of work, and Hydro One has committed to notification and consultation with Indigenous communities, and affected stakeholders and landowners where required.

For any change to the proposed project as described in the amended EA that is outside of the limits of work outlined in section 11.3.1.2 of the amended EA, a new EAA approval may be required.

Making a submission

A five-week public review period will follow the publication of this review.  During this time, any interested parties can make submissions about the proposed project, the EA, or this review. Should you wish to make a submission, please email stephen.deneault@ontario.ca and address it to:

Kathleen O’Neill, Director 
Environmental Assessment Branch
Ministry of the Environment, Conservation and Parks
Re:  Waasigan Transmission Line Environmental Assessment
Attention:  Stephen Deneault, Project Officer

Your privacy

All personal information included in a submission—such as name, address, telephone number and property location of requester—is collected, maintained and disclosed by the ministry for the purpose of transparency and consultation.  The information is collected under the authority of the Environmental Assessment Act or is collected and maintained for the purpose of creating a record that is available to the general public as described in section 37 of the Freedom of Information and Protection of Privacy Act.  Personal information that is submitted will become part of a public record that is available to the general public unless a request is made that personal information remain confidential. 

Public record locations

The public record for this environmental assessment can be reviewed during normal business hours at the following ministry office:

Ministry of the Environment, Conservation and Parks
Environmental Assessment Branch
135 St. Clair Avenue West, 1^st Floor
Toronto, Ontario

• Tel: 416-314-8001
• Toll-free: 1-800-461-6290
• Fax: 416-314-8452

Appendix A: Environmental Assessment Act requirements

Requirements in Ontario Regulation 53/24: General and Transitional Matters

Summary of the EA

Ontario Regulation 53/24: section 4(1)

EA must contain a brief summary of the EA organized in accordance with the matters set out in subsection 17.6 (2) of the Act.

Analysis of the EA

The EA includes an executive summary (ES—1 to ES—24) organized in accordance with the matters set out in subsection 17.6 of the Act.

1. List of proponent-led studies

Ontario Regulation 53/24: section 4(1)

EA must contain a list of studies and reports which are under the control of the proponent, and which were done in connection with the project or matters related to the project.

Analysis of the EA

The list of studies and reports which are under control of the proponent and were undertaken in connection with the EA are listed in Appendix 5.0—A.

Sections 6.0 and 7.0 of the EA contain the information sources (list of studies, reports and additional data sources) that were used to develop the evaluation criteria used in the EA report.

2. List of additional studies

Ontario Regulation 53/24: section 4(1)

EA must contain a list of studies and reports done in connection with the project or matters related to the project of which the proponent is aware and that are not under the control of the proponent.

Analysis of the EA

The list of studies and reports which are not under control of the proponent and were undertaken in connection with the EA are listed in Appendix 5.0—A.

Sections 6.0 and 7.0 of the EA contain the information sources (list of studies, reports and additional data sources) that were used to develop the evaluation criteria used in the EA report.

Section 12.0 of the EA contains a list of references and works cited for the EA report.

3. Maps

Ontario Regulation 53/24: section 4(1)

Where the environmental assessment is for a project with a fixed location, at least two, well marked, legible and reproducible maps showing the location of the project and the area to be affected by it.

Analysis of the EA

Figure 1.1—1 in section 1.1 of the EA shows the project location in Northwestern Ontario, between Thunder Bay and Dryden. Section 2.2.1.4 of the EA Report contains maps of the preferred transmission line route by sections:

• Section 1—Thunder Bay Area
• Section 2—Thunder Bay to Atikokan
• Section 3—Atikokan Area
• Section 4—Atikokan to Dryden

Figure 2.2—6 in section 2.2.1.4 of the EA contains a map of the preferred route in its entirety.

Figures 7.1—1, 7.1—2, 7.1—3, and 7.1—4 in section 2.1.4.2 of the EA contains maps of the project footprint, local study area, and regional study area used in the EAs evaluation of environmental effects.

The maps included in the EA are full-page and legible.

The proponent maintains an interactive map on its website that is available to the public, Indigenous communities, and stakeholders.

Problem / opportunities

1. Identify an existing problem or opportunity and purpose of the project:

Environmental Assessment Act section 17.4(2)(c), 17.6(2)(a) and 17.6(2)(b)(i) and (ii).

The EA must contain a description of the purpose of the project. This should include an explanation of the problem or opportunity that prompted the proposed activity.

The EA must include a description of a statement of the rational for the project and its alternative methods.

If a specific project has been identified provide a brief description.

Analysis of the EA

The EA is required to follow the ToR, section 5.1 of the ToR outlines the project description. A overview of the project is included in section 1.1 of the EA, which explains that the need for a new transmission line in Northwestern Ontario was determined and confirmed by the Ministry of Energy and the Independent Electricity System Operator (IESO) to support growth and maintain reliable electricity supply in Northwestern Ontario.

The IESO directed Hydro One to proceed with the planning of a new double-circuit 230 kV line between Lakehead TS and Mackenzie TS (Phase 1), a new single-circuit 230 kV line between Mackenzie TS and Dryden TS (Phase 2).

The purpose of the project, as described in section 1.6.2 of the EA, is to support growth and maintain reliable electricity supply to areas west of Thunder Bay and north of Dryden, recognizing the need and rationale/justification for the project as previously established by the province through analysis and decisions, including the Ministry of Energy’s Long-Term Energy Plan (LTEP) and the Independent (IESO) recommendations.

The IESO directed Hydro One to prioritize the construction of Phase 1 with a target in-service date as close to the end of 2025 as possible. The IESO recommended that Phase 2 go into service as soon as practical after Phase 1 based on updated demand forecasts. This recommendation was provided so Northwestern Ontario is well positioned to provide reliable and sustainable electricity to support economic growth in the region west of Thunder Bay.

The rationale for the project, as described in section 1.6.1 of the EA, is that the project, if fully implemented, would provide enough electricity to meet future demands in Northwestern Ontario and would implement the Ministry of Energy’s and the IESOs recommendation to construct Phase 1 and 2 of the project.

Alternatives

1. Description and statement of the rationale for the alternatives methods

Environmental Assessment Act section 17.4(2)(c), and 17.6(2)(b)(ii).

Alternative methods include a description of different ways of implementing the project (locations and designs).

A reasonable range of alternative methods should be identified and outlined.

Analysis of the EA

As part of the development of its amended ToR, Hydro One identified alternative transmission line routes that could meet the needs of the project.

The amended ToR set out a methodology for evaluating and comparing alternative routes based on their potential effects and for determining the preferred route in the EA.

Alternatives route alignments were evaluated according to a set of natural, socio-economic, Indigenous, and technical criteria. The final list of alternative route evaluation criteria and indicators was refined at the beginning of the EA with input from government agencies, Indigenous communities, and members of the public. A preferred route was then selected based on the comparison of alternative transmission line corridors, and a preliminary project footprint was then developed for a preferred route and assessed in more detail in the EA.

Section 2.2 of the EA describes that alternative methods were identified and considered to address specific concerns raised by Indigenous communities and stakeholders, such as property owners and municipalities, to avoid or minimize project effects on natural and/or socio-economic features.

The following alternative methods were evaluated in the EA:

1. alternative route evaluation
2. separation of circuits F25A and D26A west out of Mackenzie TS
3. alternative route segments through provincial parks and conservation reserves
4. preliminary Preferred Route Feedback and Local Route Refinements 

Alternative route evaluation (section 2.2.1 of the EA)

This alternative method involves assessing the alternative routes that were identified during the amended ToR using the criteria and indicators provided in the amended ToR to identify a preferred transmission line corridor from Indigenous, natural, socio-economic and technical perspectives. Alternative route alignments were compared using a project footprint that includes associated infrastructure (for example, access roads, laydown areas, temporary construction camps, etc.). As such, Hydro One developed a preliminary project footprint for each alternative route identified in the amended ToR so they could be compared to select a preferred project footprint for further analysis in the EA.

Determination of a preferred project footprint included an assessment of:

• viable transmission line alignments (for example, follow existing linear features to avoid disturbances)
• the siting of transmission structures (for example, design limitations of towers)
• the siting of laydown areas and construction camps (for example, avoidance of sensitive land uses)
• alternative transmission structure types (for example, practicality and cost)
• alternative access and construction plan (for example, accessibility for helicopters and heavy equipment to construct and maintain the line).
• aggregate sites (for example, proximity to existing aggregate sites as potential sources of aggregate)

The alternative route evaluation included a multi-criteria option analysis approach to support the identification of a preferred route for the project. The alternative route analysis leveraged the criteria and indicators provided in the amended ToR to identify the route that is most preferred from the perspective of four criteria categories; Indigenous culture, values, and land use, the natural environment, the socio-economic environment, and technical and cost considerations. Alternative routes were compared for each criteria category and ranked to determine the preferred route.

Separation of circuits F25A and D26A west out of Mackenzie TS (section 2.2.2 of the EA)

Hydro One was directed by the Independent Electrical System Operator (IESO) to include the separation of two existing 230 kV transmission circuits out of Mackenzie TS in Atikokan (circuits F25A and D26A). Approximately 1 kilometre (km) of this double-circuit section of transmission line needs to be separated into two single-circuit sections (without sharing structures), as required by the North American Electric Reliability Corporation (NERC) transmission planning standard.

This alternative method involves considering the separation of the existing 230 kV transmission circuits, including developing a new right-of-way (ROW) not paralleling the existing transmission line or expanding the existing ROW to the north or south side of the existing transmission line ROW.

Considerations for whether to develop a new ROW not paralleling the existing ROW or to expand the ROW to the north or south include:

• effects to the natural environment, such as amount of vegetation clearing
• technical design considerations, such as terrain
• constraints of existing transmission lines and the required connection location of the new transmission line at Mackenzie TS

When considering the alternative of creating a new ROW not paralleling the existing line, the disadvantages included increased habitat fragmentation on the landscape, increase overall project footprint (i.e., longer ROW), and increased construction impacts (i.e., increased requirement for new access). It was determined that the preferred alternative was to expand the existing ROW to minimize adverse effects on the environment.

When considering whether to expand to the north or the south of the existing transmission line, it was determined that the preferred alternative would be to relocate circuit F25A to the south side of the existing transmission line. This was determined to be preferred as relocating D26A to the north of the existing transmission line would involve relocation of distribution assets from Atikokan Hydro, requiring additional cost and construction impacts. In addition, constructability is more favourable on the south side (i.e., less tree clearing and more favourable soil conditions). Therefore, due to the south side having more advantages from a natural environment and technical and cost perspective, to accommodate this separation the ROW will be expanded to the south.

Alternative route segments through provincial parks and conservation reserves (section 2.2.3 of the EA)

The project is proposing to cross Turtle River-White Otter Provincial Park, Campus Lake Conservation Reserve and Quetico Provincial Park (access road use only). This alternative method involves assessing and minimizing impacts of the project to provincial parks and conservation reserves.

During project planning, each protected area was reviewed individually to determine the appropriate and feasible mitigation measures that could be implemented to decrease potential adverse effects on the environment. Hydro One has identified site-specific design changes to limit adverse effects in the provincial parks and conservation reserves.

Preliminary preferred route feedback and local route refinements (sections 2.2.4 to 2.2.8)

This alternative method involves reviewing local route refinement suggestions from Indigenous communities, agencies, landowners, or stakeholders following the public release of the preferred route alignment.

Alternative route alignment suggestions from Indigenous communities, agencies, community organizations, and affected landowners were considered using the alternative route evaluation approach to determine the advantages and disadvantages of the requested change, and its effects.

The ministry is satisfied that a reasonable range of alternative methods were described in the EA and evaluated using a broad range of environmental criteria and measures.

Evaluation

1. Description of the environment for the project and alternatives

Environmental Assessment Act section 17.6(2)(c)(i) and 17.4(2)(c).

Proponents must consider the broad definition of the environment including the natural, biophysical, social, economic, built and cultural conditions. The EA must provide a description of the existing environmental conditions in the study area.

The EA must identify those elements of the environment that may be reasonably expected to be affected, either directly or indirectly, by the proposed project and/or the alternatives.

Analysis of the EA

A preliminary description of the existing environment was provided in section 4.0 of the amended ToR. The amended ToR contained the commitment that a more detailed description of the existing environmental conditions will be prepared as part of the EA to assess the potential effects of the alternatives on the environment.

Section 5.3 of the EA describes the spatial and temporal boundaries within which potential environmental effects of the project are expected to occur.

A description of the existing environment is completed for each environmental criterion to provide the baseline for determining the potential effects resulting from the project. The study methods, specific data sources, and the existing environment in which the project will be constructed, and operated and maintained, are described in detail in Sections 6.0 and 7.0, along with the results of field surveys completed in support of the effects assessment:

• 6.1—geology
• 6.2—surface water
• 6.3—groundwater
• 6.4—vegetation and wetlands
• 6.5—wildlife and wildlife habitat
• 6.6—fish and fish habitat
• 6.7—air quality
• 6.8—greenhouse gas
• 6.9—acoustic environment
• 7.1—land and resource use
• 7.2—community well being
• 7.3—economy
• 7.4—aesthetics
• 7.5—archaeological resources
• 7.6—built heritage resources
   

The ministry is satisfied that a broad definition of the environment was considered and a description of existing environmental conditions in the study area was provided.

2. Description of the potential environmental effects for alternatives

Environmental Assessment Act section 17.4(2)(c), and 17.6(2)(c)(ii).

The EA must include a description of the effects that will be caused or might reasonably be expected to be caused to the environment. Both positive and negative environmental effects should be included.

The EA must identify methods and studies used to analyze the potential environmental effects. The methods used are contingent on the type of project.

Impact assessment methods and criteria used during the evaluation should be identified.

The methods chosen must be clear, traceable and replicable so that interested parties can understand the analysis and logic used throughout the EA.

Analysis of the EA

Potential environmental effects, both positive and negative, were identified during the EA. Section 8.0, Table 8.0-1 (Summary of Net Effects Assessment), section 9.0 (Cumulative effects) and section 11.2 (Advantages and Disadvantages) of the EA include a summary of the net effects assessment for the environmental criterion, an assessment of cumulative effects and advantages and disadvantages of each alternative.

The EA assesses both positive and negative effects of the alternatives. The evaluation method included identifying proposed mitigation measures to minimize or avoid any potential negative environmental effects of the preferred project being considered as part of the EA process. The EA identifies the net effects of the project during both construction and operation.

The EA provided a description of the effects that may be caused to the environment. The evaluation method in the EA used to determine what the effects to the environment may be is clear, traceable, replicable and appropriate for a transmission line project.

3. Description of the actions necessary to prevent, change, mitigate or remedy the environmental effects for the alternatives

Environmental Assessment Act section 17.4(2)(c), and 17.6(2)(c)(iii).

A description of future commitments, studies and a work plan may be included as part of the actions necessary to prevent, change, mitigate or remedy environmental effects for each alternative for the ultimate purpose of comparing them.

Analysis of the EA

A description of future commitments to mitigate impacts and environmental effects monitoring is provided in section 10.0 (Monitoring and Commitments) of the EA. Monitoring strategies were developed so that environmental effects can be monitored during construction, operation, and maintenance of the transmission line to confirm that predicted net effects are not exceeded, unexpected negative impacts are addressed, and mitigation measures are effective.

Section 10.2 (environmental protection planning) describes the project’s Environmental Management System (EMS) which provides a framework for the environmental protection plan (EPP) inclusive of mitigation measures, management plans and contingency plans, monitoring activities, and follow-up programs proposed in the Final EA Report. This section also provides an associated list of commitments for the project. Both the natural and socio-economic environments are considered in the monitoring framework and the associated list of commitments. These monitoring and management plans and EA commitments are also referenced throughout the Final EA Report, where applicable.

The complete list of environmental commitments identified during the EA stage for the project are summarized in Appendix 10.0—A. These commitments are in addition or supplemental to the construction monitoring activities summarized in Table 10.6—1.

An on-going compliance monitoring program is proposed to demonstrate compliance with the commitments made in the EA report. The results of compliance monitoring would be reported to the MECP and/or the appropriate review agency and would include implementation of mitigation measures and completion of commitments.

4. Evaluation of advantages and disadvantages to the environment for the project and alternatives

Environmental Assessment Act section 17.4(2)(c), and 17.6(2)(d).

The preferred alternative should be identified through this evaluation.

Analysis of the EA

Section 11.2 (Advantages and Disadvantages) Table 11.2—1 identifies the advantages and disadvantages between the alternative to proceed with the project or not. The EA presents a summary of the differences between each alternative method and summarizes the advantages and disadvantages of the preferred alternative based on the net effects of the preferred alternative.

The EA adequately describes the advantages and disadvantages of the proposed project to the environment based on potential environmental effects.

5. Description of consultation with interested stakeholders

Environmental Assessment Act section 17.4(2)(c), and 17.6(2)(e).

A description of any consultation that about the project and the results of that consultation must be documented. The description should include consultation methods used, frequency of consultation, dates that events occurred, target audience, descriptions of key milestones for which stakeholders are providing input, comments received.

The EA must identify any Indigenous community consultation efforts that have been made including methods for identifying potentially interested Indigenous communities, who was consulted, when and how consultation occurred and any comments received from Indigenous communities.

The EA should outline conflict resolution techniques used by the proponent to resolve outstanding issues with any stakeholders. There must be clear documentation as to how issues and concerns have been addressed.

Analysis of the EA

A description of stakeholder consultation is included in section 4.0 (Engagement Summary) of the EA, which includes the methods used to identify and gain input from stakeholders, the frequency of consultation, and a description of key engagement milestones was provided.

Key consultation methods included distribution of public notices, public open houses, mailings, working groups, and a project website.

Section 4.5 (Indigenous Engagement) of the EA describes the consultation undertaken with Indigenous communities. Potentially Indigenous communities that were consulted on the basis that they have or may have constitutionally protected Aboriginal or treaty rights that may be affected by the project were:

• Grand Council Treaty #3
• Eagle Lake First Nation (Migisi Sahgaigan)
• Fort William First Nation (Anemki Wajiw)
• Gakijiwanong Anishinaabe Nation (formerly Lac La Croix)
• Lac Seul First Nation (Obishikokaang)
• Ojibway Nation of Saugeen
• Seine River First Nation (Chima’aganing)
• Nigigoonsiminikaaning First Nation (Red Gut)
• Wabigoon Lake Ojibway Nation (Waabigonii Zaaga’igan)
• Northwestern Ontario Métis Community (NWOMC) and Region 2
• Mitaanjigamiing First Nation
• Couchiching First Nation
• Lac des Mille Lacs First Nation (Nezaadikaang)
• Red Sky Métis Independent Nation

While Hydro One is identified as the proponent for the project, Hydro One is working in partnership with nine First Nations that will have the opportunity to invest in 50% of the Waasigan transmission line project; eight of those communities make up the Gwayakocchigewin Limited Partnership (GLP) – Migisi Sahgaigan (Eagle Lake First Nation), Fort William First Nation (Anemki Wajiw), Nigigoonsiminikaaning First Nation, Ojibway Nation of Saugeen, Lac La Croix First Nation (Zhingwaako Zaaga’Igan or Gakijiwanoong), Lac Seul First Nation (Obishikokaang), Seine River First Nation (Chima’aganing), and Wabigoon Lake Ojibway Nation (Waabigonii Zaaga’igan) — and Lac des Mille Lacs First Nation (Nezaadikaang).

Letters and emails were sent to each of the communities advising of notices, open houses, and draft reports which took place throughout the planning process. The EA demonstrates how public/agency input received throughout the EA process informed the results of the EA.

The EAA requires that proponents consult with all interested persons during the preparation of the EA and report on the results of that consultation. The ministry is satisfied that the proponent appropriately carried out the consultation plan in accordance with the Code of Practice: Consultation in Ontario’s Environmental Assessment Process (2014) that was committed to in the approved amended ToR.

Overall, the ministry is satisfied that the public, agencies and Indigenous communities had opportunities to comment and provide input on the EA throughout the process.

Selection process

1. Proposed project

Description and statement of the rationale for the undertaking:

Environmental Assessment Act section 17.4(2)(c), and 17.6(2) (b) (i) and (c).

The description of the project should specify what the proponent is seeking approval for under the EAA.

The description should include information on the location, attributes, dimensions, emissions etc.

The evaluation process should identify which is the preferred project.

Analysis of the EA

Section 11.1 of the EA describes that Hydro One is seeking EA approval for a proposed new double-circuit 230 kV transmission line between the Lakehead TS in the Municipality of Shuniah and the Mackenzie TS in the Town of Atikokan, and a new single-circuit 230 kV transmission line between the Mackenzie TS and the Dryden TS in the City of Dryden.

Considering the preferred route that was selected, the project includes the following main components:

• new overhead alternating current (AC) 230 kV transmission lines and associated components that will be located within a typical 46 m wide transmission line right-of-way (ROW), approximately 360 km in length
• modifications to existing infrastructure at the Lakehead TS, Mackenzie TS and Dryden TS, and separation of the existing 230 kV transmission lines (circuits F25A and D26A)out of the Mackenzie TS in Atikokan
• development of temporary supportive infrastructure associated with construction including, but not limited to, temporary access roads, temporary workspaces (including helicopter staging areas), construction camps, laydown areas, and waterbody crossings
• development of aggregate pits to support the project
• development of associated permanent infrastructure, such as access roads and waterbody crossings, to support the operation and maintenance stage of the project
   

The EA documents how the preferred project and route alignment addresses the problem and opportunity statement, explained in section 1.1 of the EA as the need for a new transmission line in Northwestern Ontario as determined and confirmed by the Ministry of Energy and the Independent Electricity System Operator (IESO) to support growth and maintain reliable electricity supply in Northwestern Ontario.

In the EA, Appendix 10.0—A details commitments to future work. Standard conditions including compliance monitoring and reporting, and public record-keeping are recommended by the ministry to require that all commitments in the EA are carried out.

Other approvals

1. Additional Approvals

Outline additional approval requirements. Provide sufficient detail about the nature of the approval.

Analysis of the EA

If EA approval is granted, the proponent will still require other legislative approvals to construct and operate the project.

Section 1.7.2.1.4 (other relevant provincial legislation, permits, approvals and authorizations) Table 1.7—1 of the EA outlines additional approvals that may be required, such as environmental compliance approvals, permit to take water, authorizations, work permits, and agreements from the MECP, MNRF, Ministry of Mines, MTO, Ministry of Labour, Ministry of Health, and MCM.

Appendix B: Submissions received during the initial comment period

Table 1: Agency comment summary table

To be provided with an electronic copy of this table, please contact Stephen Deneault, Project Officer, Environmental Assessment Branch, at stephen.deneault@ontario.ca or 437-247-2443.

Table 2: Public comment summary table

To be provided with an electronic copy of this table, please contact Stephen Deneault, Project Officer, Environmental Assessment Branch, at stephen.deneault@ontario.ca or 437-247-2443.

Table 3: Indigenous communities comment summary table

To be provided with an electronic copy of this table, please contact Stephen Deneault, Project Officer, Environmental Assessment Branch, at stephen.deneault@ontario.ca or 437-247-2443.

Table 4: Amendments to the final environmental assessment

To be provided with an electronic copy of this table, please contact Stephen Deneault, Project Officer, Environmental Assessment Branch, at stephen.deneault@ontario.ca or 437-247-2443.