Hamilton 350 is a climate action group guided by the necessity to stop global climate change. We look for the best ways for us to contribute to that goal. A strong argument can be made that the level of government that is the main obstacle to climate action in Hamilton is the same as in the rest of Ontario – the current provincial government.

The federal government is usually identified as the make or break climate decision-maker, but Canada is a federation where provincial governments wield a great deal of power. For example, Alberta pressure is a major reason the feds purchased and are expanding the Trans Mountain pipeline project. Pipelines inside Ontario like the recently withdrawn fracked gas one across the Beverly Swamp fall under provincial jurisdiction (specifically the Ontario Energy Board) whose policies are decided by the provincial government (hence climate change is not part of the OEB mandate). The rules governing endangered species, wetlands, forest protection, and wildlife habitat are provincial (or in some cases federal). The recent gutting of the Conservation Authorities is a clear case in point.

Legally and in many practical ways, cities are “children of the province”. The building code needs to be modernized to require net zero construction, but that code is set by the province, not the city. Facilitation of sprawl development (Ontario’s tar sands) is now clearly being driven by provincial growth policies and under Ford it is actually being dictated by the province. Most transportation emissions in our area are from travel between cities because nearly 40 percent of the Hamilton workforce is employed outside the city. That makes effective emission-limiting policies difficult for Hamilton to put in place.

So fighting climate change in Hamilton necessarily requires overcoming provincial obstacles.
The provincial attack on the Conservation Authorities touched a public nerve and resulted in a very large wave of opposition. Over 45,000 emails were sent in opposing the changes, and in late January over 1200 people attended a webinar on next steps in this fight (which is far from over – see: https://hamiltoncatch.org/articles/2021/01/18/conservation-authorities-battle-far-from-over.) Hamilton 350 and other climate groups have an opportunity to further engage this movement in climate action both locally and at the provincial level.

The fight for a safe climate cannot be separated from the fight for a healthy natural environment. The Conservation Authorities reflect an early recognition of our dependence on the health of the environment and our interconnectedness with the watersheds in which we live. The Hamilton Conservation Authority owns over 11,000 acres of mostly forested natural areas – far more than the city government – and the activities on those lands are much more sustainable (far more beneficial to non-human species) compared to city parklands which are overwhelmingly sports facilities and make very little contribution to climate or environmental stability.

The attack on the Conservation Authorities is part of a very damaging campaign by the current provincial government that started with eliminating the office of the environmental commissioner, ripping up the existing Ontario climate plans, and blocking green energy projects (even tearing down windmills in one location). In our area and other parts of the province, the Ford government is eagerly continuing colonial policies and seeking to criminalize Indigenous people and their allies (the attacks on the defenders of 1492 Land Back Lane are one example). In addition, the Ford government has essentially destroyed the environmental assessment process (put in place in 1969); is pushing ahead with major new highways (413 and Bradford Bypass) without assessments; and advancing enormous mining projects (Ring of Fire). It has ripped up provincial growth plans aimed at reducing urban sprawl and replaced them with pro-sprawl directives. In Hamilton this translates into plans to consume all the remaining farmland not protected by the Greenbelt and cover it with residential subdivisions. The Ford government has been issuing Ministerial Zoning Orders about once a week to override rules that restrict or limit environmental damage by developers. It has crippled the provincial Endangered Species legislation with ‘pay to slay’ rules that replace protection of wildlife habitat with the option of paying a fee to destroy them. And it has openly declared that Ontario ‘has already made sufficient contribution’ to reducing greenhouse gas emissions. The resignation of most of the Greenbelt Council shows they understand that this government is also an enemy of the Greenbelt.

Facts show that there’s more than a pandemic behind Enbridge’s abandonment of its proposed new fracked gas pipeline across the Beverly Swamp and rural Hamilton. Things have been going badly for North America’s biggest pipeline company right from the start of this project largely because of public opposition to the pipeline and to any expansion of fossil fuel infrastructure in the face of the climate emergency.

​Back in May, Enbridge was facing over 850 questions filed in the Ontario Energy Board (OEB) process and with just 15 minutes to go before it was required to provide answers, the company filed a letter asking the OEB for a pause in the hearings allegedly because of the pandemic.
The OEB readily granted the request. None of the 16 intervenors opposed the delay. So when Enbridge announced on October 22 that they were withdrawing their application but will likely re-apply next year, it looked quite fishy. Why didn’t the company just ask for a further ‘pause’ in the hearings? The pandemic is still going on and the OEB could hardly argue otherwise so almost certainly would have agreed to a further delay.

That suggests the pipeline project had a lot more problems than the pandemic. It’s not hard to find those numerous obstacles.

Public opposition to the pipeline began months before Enbridge filed its application with the OEB in late November of 2019. By that point, members of the Hamilton 350 Committee had formally delegated to Hamilton City Council as well as to the three conservation authorities from which Enbridge needed permit approvals.

One of those agencies – the Hamilton Conservation Authority (HCA) – owns the land across which nearly a tenth of the pipeline was scheduled to cross. And the HCA has repeatedly promised publicly that it buys land to ensure that “it will never be developed or bulldozed”. Hamilton 350 reminded the HCA board of this commitment as well as the climate emergency and recommended at least a thorough consultation with the HCA’s donors and membership rolls before granting the easement desired by Enbridge. In response, the board voted unanimously to delay granting the easement at least until Enbridge provided a full ecological study. It also required an independent peer review of that study.

Both of those documents were about to be released by the HCA for public comment days before Enbridge pulled the plug on the pipeline. It could be asked why the company went to the trouble and expense of the study at all if the pandemic was the only obstacle facing its project. Perhaps it was worried about the HCA insistence on a public review of the studies rather than the expected internal decision. Perhaps it was worried that there was even going to be a debate about whether it got the easement.

The day after the HCA voted on the easement delay, Hamilton City Council also voted unanimously to support the HCA position and to maintain its own role as an intervenor. Both the HCA and City Council advocated that the OEB consider upstream and downstream climate impacts of the pipeline and the gas scheduled to flow through it. Ten Hamilton citizen groups and over 150 individuals pushed the OEB for the same commitment to include climate change.
This was a long shot. The OEB had never examined climate change in its hundreds of hearings on fossil fuel pipelines. And Enbridge demanded that this not be allowed and that some of the intervenors be forced to stop asking about it, and be required to merge their intervention to reduce their role in the hearings. But the OEB cracked open the door. It delayed finalizing the hearing issues list and asked for comment on inclusion of climate issues.

Climate change was the last thing Enbridge wanted examined. The gas it is planning to transport through the pipeline came from fracking in Pennsylvania – an extraction process which some researchers argue makes the resulting gas a worse climate offender than coal, not to mention its intentional contamination of groundwater and very large amounts of surface water that is blasted into the earth to shake loose some gas. And of course burning gas, like burning coal and oil, pours carbon dioxide into the atmosphere where it increases the greenhouse effect and warms the planet.

In the end, the OEB decided that climate change is not part of its mandate – after all what could fossil fuels have to do with climate and why would the government agency overseeing pipelines have that in its mandate! However, it did concede that some issues related to climate such as the source of the gas could be challenged by intervenors. And some of them very much did so – helping to generate the massive number of questions that Enbridge was supposed to answer.

Public pressure also dealt a blow to Enbridge’s demand that it be given a “leave to construct” the pipeline by no later than April 30, 2020. A key piece of that deadline was convincing the OEB to hold a written hearing, rather than an oral one. Over Enbridge’s objections, the OEB agreed to hold an oral hearing. Hamilton City Council formally asked that take place in Hamilton. The OEB left the location decision to be determined later, but the prospect certainly would not have been welcomed by Enbridge. The April 30 deadline came and went and by the time the hearings were paused there were still weeks of OEB process still to come.

The company also stumbled and got caught on where the gas was coming from and where it planned to ship it using the new pipeline. When a representative paid a courtesy call to Hamilton City Council in June 2019, councillor John Paul Danko extracted the admission that pretty much all the gas was expected to come from fracking in Pennsylvania. Danko concluded “so it’s the dirtiest source possible”. Opponents of the pipeline immediately jumped on this admission and the label stuck despite seven Enbridge officials coming back to city council later and trying to sell a different story. In response to direct questions they said the gas could “come from anywhere” because there are pipes all across North America all linked together. Their story didn’t fly.

The extraction source turned into a bigger public relations problem for Enbridge when its OEB application explained the expected market for the gas. That included the New England states that are practically right next door to Pennsylvania. So why would the gas be shipped hundreds of kilometres west and north to Sarnia, then hundreds more across southern Ontario to Quebec only to be sold to Maine and other Atlantic coastal parts of the country it came from? In its OEB application Enbridge’s marketing consultant explained that there were difficulties in getting Pennsylvania fracked gas into those adjacent states that were expected to continue. 

They didn’t offer details of the difficulties but they are easy to determine. New York State, which lies along a long border immediately north of Pennsylvania, has banned fracking. They’ve also been blocking new gas pipelines through New York. In fact, while the OEB hearings were going on earlier this year New York ruled that a proposed new gas pipeline posed an unacceptable risk to New York waters and was inconsistent with the state’s climate commitments.

The scheme to use Ontario as a bypass for US gas going to the US turned into a real problem for Enbridge at the OEB hearings. Multiple intervenors jumped on it and demanded to know why Ontario gas users should help pay for a pipeline that was being used to supply US gas to US customers. These questions didn’t just come from intervenors who were concerned about the climatic impacts of a new pipeline. They came from groups representing businesses and residents who pointed to Enbridge’s plan to raise gas rates in Ontario by $120 million to cover the largest part of the projected $205 million cost of the pipeline.

The other market opportunity that Enbridge identified for its new pipe was the Ford government’s plan to replace some electricity generation by nuclear reactors with gas-burning power plants. That plan would reverse the huge gains in emission reductions achieved by shutting down all of Ontario’s coal-fired generation plants. If implemented, it would push up greenhouse gas emissions by 300-400 percent.

Not surprisingly, that brought on a lot more public opposition and exposed Ontario cabinet ministers to public outrage. The Ontario Clean Air Alliance jumped into the fight against the pipeline with a billboard and flyer campaign that saw over 15,000 “protect our climate” brochures distributed to homes in the Hamilton area, and many more delivered in Toronto and other parts of the GTA. More than 40 organizations have already signed onto to the OCAA demand for a cap on existing gas-fired power generation, and a complete phase out by the end of the decade.

This part of the stop-the-pipeline campaign has been endorsed by major national and provincial organizations such as the David Suzuki Foundation, Environmental Defence, the Council of Canadians, and the Canadian Environmental Law Association. It is now also bringing in municipal governments, including Kitchener and Halton Hills who recognize that dirtying Ontario’s electricity supply with more fossil fuels completely undermines local plans to shift energy use away from oil and gas. Why buy an electric car or put electric buses on transit routes if the electricity supply is made with the fossil fuels you are trying to avoid?

The route of the proposed pipeline through parts of the Beverly Swamp wetland generated more public opposition, including the Ontario Wilderness Society, the 600-member Hamilton Naturalists’ Club, Dundas Turtle Watch and others concerned about the dozens of rare floral and faunal species living in what is considered one of the two or three most important wetland complexes in Southern Ontario. A newspaper essay by the founding Chair of the Hamilton Conservation Authority demanded the project be blocked and noted it was the construction equivalent of an 8-9 lane highway. And that was just for the permanent easement pursued by Enbridge. An additional similar sized area was sought to accommodate construction staging. Provincial rules actually say no development is allowed in provincially significant wetlands although companies as large as Enbridge regularly get exceptions.

A large part of the pipeline route lies within the watershed of Spencer Creek, the largest stream in Hamilton which flows through and frequently floods urban Dundas. Opponents didn’t have any difficulty convincing residents that the construction project would likely make that worse – and that the clearing of hectares of forested area would exacerbate the climate change which has been driving increased flooding.

Provincial Green Party leader Mike Schreiner was an early vocal opponent, pursuing the Ford government in the legislature. The Greens went to on to generate a 6000-name petition against the pipeline, one of several multi-thousand name petitions collected over the last year. The MPP for the Dundas area, NDPer Sandy Shaw, came out swinging against the project along with her party’s environment critic Peter Tabuns. These provincial representatives are continuing to demand changes to the mandate of the OEB to include climate change.

All of this meant that Enbridge’s pipeline was facing far more opposition than the company might reasonably have expected for its 10 kilometre pipe through a low-population rural area. They would have expected no serious problems from the city or the conservation authorities, and a relatively short and easy ride through the OEB process for a pipeline of allegedly “clean natural gas”.

But times have changed and are continuing to change for the fossil fuel sector, including gas. As part of their climate actions some cities in the US are now banning the installation of gas lines into new homes. Fracking is increasingly being exposed for its gas leaks, water contamination and earthquake-generating impacts. Those gas leaks including from pipelines are rapidly pushing up atmospheric levels of methane which is many times more damaging than even carbon dioxide. The State of Maine has recently committed to installing at least half a million residential electric heat pumps by 2025 to cut gas use. And there are many signs that even governments are realizing that fossil fuels are a diminishing sector and must be phased out if we are to have a chance of avoiding catastrophic climate change.

And yes, we’re in a pandemic and at least temporarily it has cut fossil fuel use, especially oil, and battered prices and demand. Likely that pushed helped push Enbridge to abandon the pipeline. It’s a little harder to swallow their prediction that this is just a delay for a few months. The opposition is not going away. The climate crisis and all its effects are just going to get worse. 

September 19th, 2020

We are concerned for the safety and rights of the Haudenosaunee land defenders and the supporters (Indigenous, settlers and/or displaced) of 1492 Land Back Lane who have been protecting their lands since July 19th, 2020. We are also concerned for the safety and  rights of folks that took Highway 6 to defend their territory and to remove the O.P.P. from the Six Nations reservation. We are concerned for the safety and rights of those who have been criminalized so far and who continue to risk criminal or civil charges. As allies we have come to understand that many Six Nations community members feel as though proper consultation was not done prior to the development of McKenzie Meadows because consultation was limited to the band council. We hear the demands of the land defenders and their supporters. We support a moratorium on the development of unceded and disputed Six Nations territories. The settler government must stop the enforcement of the extended injunction against the named Jane and John Doe and Skyler Williams as of August 25th. The settler government must meet with the land defenders and supporters in accordance with the United Nations’ Declaration on the Rights of Indigenous Peoples and Canada’s promise for Truth & Reconciliation.

        Hamilton 350 recognizes the commitment, resilience, and tireless efforts of the 1492 Land Back Lane defenders and supporters to resist colonization. As a group comprised mostly of settlers, we know that this statement cannot stand alone and that we have much work to do. We are committed to educating ourselves and our community to understand the situation, where we are positioned relative, and how we can best help. We are also committed to building greater momentum within our community to pressure Foxgate Developments to not pursue civil litigation against any named individuals. The O.P.P. has arrested a number of land defenders and supporters including an independent Indigenous journalist and researcher in an effort to silence Indigenous media. The O.P.P. are part of our colonial system. It is our responsibility to hold them accountable for their divisive behaviour. They are actively continuing to use imperial force against Haudenosaunee land defenders and supporters involved in this land dispute and it must stop.

        We urge Hamilton community members to learn more about the Haldimand Proclamation and the responsibility of the “Government of Canada” to uphold treaty commitments, to educate themselves and their loved ones about Indigenous land sovereignty, and to continue to speak about what is happening at 1492 Land Back Lane. We encourage Hamilton community members to push settler governments to meet the demands of land defenders and to call their MPPs and the O.P.P. to demand an end to criminalizing Indigenous peoples engaged in land disputes. Moreover, Hamilton community members can provide material support to the land defenders at 1492 Land Back Lane, including physically visiting the site.

We’ve opened a new front in the fight against Enbridge’s fracked gas pipeline across rural Hamilton and the Beverly Swamp. The company’s main justification for this new pipe is to feed a plan by the Doug Ford government to greatly expand Ontario’s gas-fired electricity generation. That would push up greenhouse gas emissions by 300% by 2024.

Hamilton 350 Committee and 28 other provincial and national organizations are opposing Ford’s plans by pushing for a complete phase-out of gas-fired electricity in Ontario.

On Tuesday, July 28th, Hamilton 350 along with guests from Ontario Clean Air Alliance hosted a teach-in to explain and discuss this crucial campaign in the hopes of engaging people who want a fossil-free electricity supply in Ontario. Key pieces of the event included stopping the fracked gas pipeline across Environmentally Significant Areas (ESA) of rural Hamilton, and phasing out the use of natural gas to generate electricity by no later than 2030. To advance that goal, we want residents to press provincial politicians - party leaders and local MPPs - plus municipal councils to publicly support the phase out.

And, wow, we have to say, the show of support, those who came out, those who shared this event with your community, those who took the time to and space to learn how we can mobilize against this, seasoned activists, environmental experts, as well as a brave handful of young and concerned individuals who wish to help - we thank you! We thank all of you.

THANK YOU!!!

Now, let’s do this.

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Please Take Climate Action Now!

Today, the Hamilton 350 Committee and 28 other organizations from across the province have called for the phase out of gas-fired electricity generation in Ontario. This is a crucial step in cutting greenhouse gas emissions and ensuring a clean energy future, including no new fracked gas pipeline across Hamilton.

And there’s a specific step that every Ontario resident can take now to make this happen. Please use this action tool to call up your MPP and 4 party leaders and urge them to support the phase-out.

Enbridge’s fracked gas pipeline across rural Hamilton is intimately linked with the Ford government’s plans to ramp up the greenhouse gas pollution from Ontario’s gas-fired power plants by more than 300% by 2025 and by more than 400% by 2040.

To help fuel this massive increase in fossil fuel electricity and climate threatening pollution, the provincial government recently purchased 3 gas plants (for $2.8 billion). Enbridge hopes to build the new pipeline through Hamilton’s Beverly Swamp to funnel US fracked gas across Ontario and feed the Ford scheme. Enbridge says supplying gas-fired power generation is the main reason why it needs to build the Hamilton pipeline.

The pipeline construction sacrifices the ecological integrity of the Beverly Swamp and the headwaters of Spencer Creek which is Hamilton’s largest stream. The provincial gas ramp-up will reverse more than a third of the greenhouse gas reductions Ontario achieved by phasing out dirty coal. This will sabotage municipal government plans in Hamilton, Burlington and elsewhere to reach local climate objectives by using replacing oil, gas and coal with fossil-free electricity.

And both the pipeline and the gas ramp-up will raise consumer rates. Enbridge proposes to raise gas rates by $120 million to pay for the pipeline; and the provincial moves will keep electricity rates high when they can be lowered significantly. 

Fortunately, there is a better way to keep our lights on. We can meet Ontario’s 2030 climate targets and lower our electricity bills by phasing-out our gas-fired power plants by 2030 and embracing lower cost and cleaner options. And it will

Here is how we can do it:

*      Put in place an interim cap of 2.5 megatonnes per year on our gas plants’ greenhouse gas pollution and develop a plan to phase out all gas-fired electricity generation by 2030 to ensure Ontario meets its climate targets. Use this action tool to call up your MPP and 4 party leaders and urge them to support this.
*      Reverse shortsighted cuts to energy efficiency programs and stop under-investing in this quick-to-deploy and low-cost resource.
*      Ensure we maximize efficiency efforts by paying up to the same price per kWh for energy efficiency measures as we are currently paying for power from nuclear plants (e.g., up to 9.5 cents per kWh).
*      Return Ontario to leadership in developing increasingly low-cost renewable energy resources. It makes no sense to ignore our lower cost options for keeping our lights on while investing in high-cost nuclear rebuilds.
*      We should support renewable energy projects that have costs that are below what we are paying for nuclear power and work with communities to make the most of these economic opportunities.
*      Accept Quebec’s offer of low-cost 24/7 power from its massive waterpower system. Quebec has offered power at less than one-half the cost of re-building our aging Darlington and Bruce Nuclear Stations and Ontario can only benefit by making a long-term deal with its green energy-rich neighbour. 
*      Quebec’s system of reservoirs can also be used like a giant battery to backstop made-in-Ontario renewable power, eliminating the need to use gas-fired power plants.
*      Please use this action tool to call up your MPP and 4 party leaders.
 
Use the messages below to promote this campaign through social media:

• 29 groups call for #Ontario Gas-Fired Power Plant Phase-out https://www.cleanairalliance.org/gas29/ #onpoli #go100re #buyquebecpower #GreenPower4ON #actonclimate #energy #climate #nofrackedgas
• Support the call for the phase out of #Ontario’s gas-fired power plants. Contact your MPP and party leaders here: cleanairalliance.org/gas-action/ #onpoli #go100re #buyquebecpower #GreenPower4ON #actonclimate #energy #climate #nofrackedgas
• Ontarians want investments in #efficiency and #renewables, not #frackedgas from the US. #onpoli #go100re #buyquebecpower #GreenPower4ON #actonclimate #energy #climate #nofrackedgas

Please use the action tool yourself (and ask your friends and family) to call up your MPP and 4 party leaders: https://www.cleanairalliance.org/gas-action/.

For Immediate Release – July 13, 2020
Hamilton fracked gas pipeline feeds polluting electricity

Enbridge’s fracked gas pipeline across rural Hamilton is intimately linked with the Ford government’s plans to ramp up the greenhouse gas pollution from Ontario’s gas-fired power plants by more than 300% by 2025 and by more than 400% by 2040.

To help fuel this massive increase in fossil fuel electricity and climate threatening pollution, the provincial government recently purchased 3 gas plants (for $2.8 billion). Enbridge hopes to build the new pipeline through Hamilton’s Beverly Swamp to funnel US fracked gas across Ontario to feed the Ford scheme.

The pipeline construction sacrifices the ecological integrity of the Beverly Swamp and the headwaters of Spencer Creek which is Hamilton’s largest stream. The provincial gas ramp-up will reverse more than a third of the greenhouse gas reductions Ontario achieved by phasing out dirty coal. This will sabotage municipal government plans in Hamilton, Burlington and elsewhere to reach local climate objectives by using replacing oil, gas and coal with fossil-free electricity.

And both the pipeline and the gas ramp-up will raise consumer rates. Enbridge proposes to raise gas rates by $120 million to pay for the pipeline; and the provincial moves will keep electricity rates high when they can be lowered significantly. 

Fortunately, there is a better way to keep our lights on. We can meet Ontario’s 2030 climate targets and lower our electricity bills by phasing-out our gas-fired power plants by 2030 and embracing lower cost and cleaner options.

Here is how we can do it:
​

• Put in place an interim cap of 2.5 megatonnes per year on our gas plant’s greenhouse gas pollution and develop a plan to phase out all gas-fired electricity generation by 2030 to ensure Ontario meets its climate targets.
• Reverse shortsighted cuts to energy efficiency programs and stop under-investing in this quick-to-deploy and low-cost resource.
• Ensure we maximize efficiency efforts by paying up to the same price per kWh for energy efficiency measures as we are currently paying for power from nuclear plants (e.g., up to 9.5 cents per kWh).
• Return Ontario to leadership in developing increasingly low-cost renewable energy resources. It makes no sense to ignore our lower cost options for keeping our lights on while investing in high-cost nuclear rebuilds.
• We should support renewable energy projects that have costs that are below what we are paying for nuclear power and work with communities to make the most of these economic opportunities.
• Accept Quebec’s offer of low-cost 24/7 power from its massive waterpower system. Quebec has offered power at less than one-half the cost of re-building our aging Darlington and Bruce Nuclear Stations and Ontario can only benefit by making a long-term deal with its green energy-rich neighbour. 
• Quebec’s system of reservoirs can also be used like a giant battery to backstop made-in-Ontario renewable power, eliminating the need to use gas-fired power plants.

Enbridge’s proposed fracked gas pipeline across rural Hamilton is facing unexpected challenges from the COVID-19 pandemic and from the huge number of letters submitted to the Ontario Energy Board by individuals and organization opposed to the project. The process will now stretch at least into the summer.

During the “interrogatory” stage of the OEB hearings now underway, registered intervenors get to ask written questions of Enbridge. The company is required to respond – although it may argue some questions are illegitimate. Below we cite some of the more interesting questions facing the company.

As for the OEB schedule, it is going far later than the April 30 decision date demanded by Enbridge. An order issued by the OEB this week extends the question and answer period until the end of June, with hearings (which may still be oral) taking place sometime after that. The OEB decision responds to time extension requests filed by the Green Energy Coalition and Environmental Defence who are expected to file written evidence by a May 25 deadline. That will then be subject to questions by Enbridge as well as other intervenors. The OEB has ruled that answers to those queries can now be filed as late as June 29.

In addition to ecological and climatic concerns about the proposed pipeline, intervenors are pressing for explanations of why Enbridge has ruled out “demand-side management” measures (DSM) such as helping gas consumers to use less by improving efficiency and conservation.

For example, the Buildings Owners and Managers Association has asked “why did Enbridge not investigate specific DSM measures, tailored to the market to be served by the proposed pipeline, that would reduce demand/capacity in that market, and thereby offset some of the need for the proposed pipeline?” 
 
The Consumers Council of Canada has noted that “hundreds of comments from stakeholders opposed to the Project have been filed with the OEB and can be found in the web drawer. How does Enbridge Gas Inc plan to address this input? How is this consistent with the evidence which states that EGI has not identified any strong opposition to the Project?” The OEB staff have also noted the public opposition and want to know what plans Enbridge has to address this for individuals, interest groups and municipalities including the City of Hamilton.

Several intervenors are demanding further explanations from Enbridge about its sale of gas to the New England states, why Ontario gas customers should be subsidizing this, and if the proposed Hamilton pipeline would be necessary if Enbridge was only providing for Ontario customers. The Power Producers Association wants Enbridge to “please explain why Ontario ratepayers should bear the risks associated with expanding the Canadian gas transportation system for the benefit of US Northeast and other export customers.”

OEB staff are also asking “whether the decline in oil prices is expected to impact the financial viability of oil and gas producers in the Marcellus and Utica shale regions,” and “please indicate if Enbridge Gas has considered deferring the consideration of the expansion project in light of the significant uncertainty in the recent economic outlook for Canada and the U.S.” Similar questions about the impact of COVID-19 have been filed by several other intervenors including the Canadian Manufacturers and Exporters Association, the Building Owners and Managers Association, and the Association of Power Producers of Ontario.

And while the OEB has decided that climate change is not part of its mandate, there are questions related to how greenhouse gas emission policies will affect the viability of the pipeline. The Green Energy Coalition, for example is asking Enbridge to explain their “understanding of state and provincial commitments to reducing greenhouse gas emissions, and how those commitments would affect continued growth in gas shipments”, and whether the company expects “that California’s efforts to reduce natural gas use will provide a model for New York, New England and eastern Canada.” Some California municipalities have banned the installation of gas pipes into new homes.