IESO: Long-Term 2 RFP – August 20, 2026

By Linda Heron on Monday, August 31st, 2026

Big Falls – Victory – stopped a proposed hydroelectric project on a sacred site!

MEM knows. Its own policy paper calls hydroelectricity non-dispatchable with limited to no flexibility, records the surplus it helps create and the exports sold at or below zero, and concedes that new hydroelectric generation needs longer lead times and long-term certainty than other resources.¹⁵ The policy framework actually driving this procurement is worse. The Ministry’s June 2025 Energy for Generations makes no mention of climate change at all.³¹ ORA said so in its filed feedback of 12 March 2026, and says it again: an electricity plan that does not read the province’s own climate science is not planning.⁵ Ontario’s own Climate Change Impact Assessment, published by another ministry of the same government, rates electrical power generation infrastructure in the highest-risk category for all future time periods, and names increasing temperatures and reduced hydroelectric output as a consequence of drought.¹²

That assessment was not a report to one ministry. It came with a commitment from the government as a whole. The then Minister of the Environment, Conservation and Parks (MECP) wrote, in his message launching it, that “climate change requires a whole-of-government approach, and as we build Ontario, it is vital we do so in a way that will protect the well-being of current and future generations, safeguard the natural environment, ensure food and water security, enhance infrastructure and strengthen our economy.”³² Safeguard the natural environment. Ensure water security. Strengthen the economy. All three in one sentence, from this government, about this assessment.

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ERO 026-0419: Invitation to Municipalities to Register Potential Interest in Implementing a Water and Wastewater Public Corporation Model

By Linda Heron on Tuesday, August 11th, 2026

Posted in Sustainability, Drinking Water, Statement of Env. Values, Environmental Registry, River Concerns, Waste Water Treatment Facilities, Government, Environmental Compliance Approval, Sewage, Urban Development, Water Quality, Policy & Process, Safe Water Act, Sewage

The notice asks municipalities why they are interested in the model and how they anticipate it “will improve” their services; what their fiscal circumstances are; what steps they are taking on infrastructure; how independent governance “would benefit” their systems; how their proposal “improve[s] efficiency and generate[s] economies of scale”; and whether they are “willing to merge your water and wastewater systems into a public utility with surrounding systems.”¹

Not one question asks about risk. Not one asks about drinking water sources, receiving waters, watersheds, climate resilience, affordability for low-income households, First Nations, or the Crown’s duty to consult. Not one asks what happens if the model does not work. The questions are written so that only a municipality already inclined toward the model can answer them, and only in its favour.

The sixth question is the one that reveals the destination. Merging systems “with surrounding systems” is regional consolidation of municipal water and wastewater utilities. That is a far larger proposal than the notice describes, and it has not been consulted on.

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ERO 019-2487, Supporting Guide to Calculate the Design Sewage Flow for Subsurface Sewage Works Subject to Section 53 of the Ontario Water Resources Act, and ERO 026-0643: Replacing Table 5-3 in the Design Guidelines for Sewage Works (2008)

By Linda Heron on Tuesday, August 11th, 2026

Posted in Environmental Registry, Regulatory, River Concerns, Rivers at Risk, Waste Water Treatment Facilities, Fisheries, Environmental Compliance Approval, Sewage, Environmental Protection Act, Urban Development, Water Quality, Ontario Water Resources Act, Policy & Process

ORA submits this letter in response to both postings together, because they are one instrument. ERO 019-2487 proposes the draft Design Sewage Flow Guide (the Guide), and ERO 026-0643 proposes to revoke Table 5-3 of the Design Guidelines for Sewage Works, 2008, and replace it with Table 1 of that same Guide.¹,² Neither can be assessed without the other.

ORA supports a clear, modern, well-evidenced guide for large subsurface sewage disposal systems. Applicants deserve certainty, and the Ministry of the Environment, Conservation and Parks (the Ministry) deserves complete applications. Much of the draft Guide does useful work, particularly the design options for modular systems, flow balancing, alternating drainfields and reserve areas.

ORA does not support the proposal as drafted, for one central reason. The numbers that come down are prescriptive. The protections that would make lower numbers safe are advisory. A subsurface sewage system that is undersized does not fail quietly. It surfaces, and it reaches ditches, streams and rivers. The recommendations below are offered to correct that imbalance, and none of them should be read as support for the reduced values in Table 1.

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ERO 026-0329: Technical Guide, River and Stream Systems: Flooding Hazard Limit, and Technical Bulletin, Special Flooding Hazard Conditions in River and Stream Systems

By Linda Heron on Sunday, August 9th, 2026

Posted in Technical Bulletins, Hydroelectric, Environmental Registry, Regulatory, Climate Change, River Concerns, Dams, Rivers at Risk, Flooding, GHG Emissions, Regulatory Submissions, Land Use, Species at Risk, Water Quality, Policy & Process, Renewable Energy on Crown Land

24 June, 2017 – An extreme rain event caused the dam to fail when all the stop logs could not be removed.

ORA has reviewed both draft documents. We are strongly opposed to this proposal and we ask the Ministry of Natural Resources (MNR) to withdraw it.¹ The hydrology and hydraulics chapters of the Technical Guide are a real improvement on the 2002 edition and should be retained and completed; however, the Technical Bulletin should not proceed in its current form. It reverses a provincial policy that exists to keep people and communities out of harm’s way, it does so in a document that no one is required to follow, and it does so without a single word about the environment, about Indigenous communities, or about who pays when a dam or water retainment structure fails.

This is a public safety matter. Loss of life and loss of property are what is at stake, and this proposal goes against the public interest.

ORA has made it clear that we are strongly opposed to this proposal and that it should be withdrawn. In the event MNR moves forward regardless, the recommendations below are offered as a fail-safe to mitigate the Ministry’s mitigation efforts. None of them should be read as support for the proposal.

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ERO 026-0670: Proposal to Update the Statement of Environmental Values for the Ministry of Energy and Mines

By Linda Heron on Thursday, August 6th, 2026

Posted in Sustainability, Biodiversity, Statement of Env. Values, Aquatic Life, Environmental Registry, Climate Change, River Concerns, Dams, Energy, Rivers at Risk, Government, Fisheries, Species at Risk, Water Quality

Vermilion River – Our grandchildren’s future with water!

ORA has reviewed the draft Statement of Environmental Values (SEV) for the Ministry of Energy and Mines (MEM) and the two statements it would replace. The Environmental Registry notice says the climate change content of the former statements has merged into the new document.¹ It has not merged. It has been cut. The draft removed the commitment to sustainable development, the commitment to reduce greenhouse gas emissions, the commitment to help Ontarians prepare for the impacts of climate change, and the commitment to engage with communities in their preferred language. It replaces the word evaluate with the word consider. And it never once mentions water.

This matters now more than at any point in the past thirty or more years. One ministry now sets Ontario’s energy priorities, directs what the province procures to meet them, and decides which mineral projects proceed. Both sides of that mandate run on water. Both change rivers. ORA’s position is that the largest single long-term risk to ratepayers, taxpayers, the climate and Ontario rivers is more hydroelectric development, followed closely by the mine waste that will be left behind. An SEV that does not mention water, rivers, fish or cumulative effects cannot manage either risk.

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UNFCCC: Call for Input Comments for Article 6.4-MEP 014-A03

By Linda Heron on Sunday, July 12th, 2026

Posted in ORA Submissions, Hydroelectric, River Concerns, Energy, Regulatory Submissions

Comment 9: Installed capacity is not an adequate basis for hydropower eligibility.

Section no. (as in the document): Cover note, section 3.1 (applicability to scales of activity); and 4. Applicability

Paragraph / Table / Figure no.: Paragraph 8(b) (options B1.1, B1.2, B2); and paragraph 17

Comment (including justification for change): The proposed options assess hydropower applicability primarily using installed capacity thresholds, such as 15 MW or 50 MW. Installed capacity is not an adequate basis for deciding whether a hydropower activity should be eligible. Most hydro facilities reach their rated capacity only during the freshet, a high-flow period that typically lasts eight to ten weeks, and generate well below capacity for the rest of the year. A small run-of-river may generate only 15 to 30 percent of installed capacity (North of Dryden Integrated Regional Resource Plan, 2015, Ontario Power Authority and IESO). In fact, during the hottest days of the summer when air conditioners are humming, these run-of-river dams often have to shut down completely because there is not enough flow to turn the turbines. Consequently, a capacity figure says little about actual generation, operating mode, or emissions.

A capacity threshold also produces a perverse outcome. Small facilities greatly outnumber large ones: of the 224 waterpower facilities the Ontario Waterpower Association records in Ontario, 28 percent are under 1 MW and a further 38 percent are 1 to 10 MW, so 66 percent are 10 MW or smaller, the largest share of the fleet. Meeting a given generation target through many small dams, therefore, harms many more rivers than a single larger facility on a larger river, which has more water to moderate its impacts. ORA’s own experience bears this out: 34 proposed waterpower facilities, all under 10 MW, often in a cascading series of facilities to increase output, on 19 Ontario rivers represented roughly 115 MW of installed capacity but only about 57 MW of net output, since proponents themselves plan for about 50 percent net capacity. That is many fragmented rivers for very little actual power (Ontario Rivers Alliance, Hydro Impacts 101: The Trade-offs, page 32). That net output is also likely to decline further over the dam’s operating life, as climate change reduces and shifts river flows through drought, reduced snowpack and earlier runoff, so a capacity figure overstates both current and future generation (Canada’s Changing Climate Report, 2019). Eligibility should be based on storage, drawdown, operating mode, and measured emissions, not on installed capacity.

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IESO: Long Lead-Time RFP: Questions and Comments

By Linda Heron on Friday, July 10th, 2026

Posted in Long Lead-Time, IESO, ORA Submissions, Hydroelectric, Aquatic Life, Climate Change, River Concerns, Dams, Energy, Rivers at Risk, Industry, Class EA for Waterpower, GHG Emissions, Water Quality, Watershed Planning

The hydro-only energy stream is not reconciled with the IESO’s own August 2025 modelling.

The LLT energy stream is restricted to new hydroelectric resources, yet the IESO’s own August 2025 Hybrid Resource Portfolio Equivalency Assessment found that wind/solar/BESS portfolios served 99.5%–99.98% of the peaky-need scenario and 99.7%–99.9% of the baseload-need scenario, and that a gas + wind/solar/BESS portfolio served 100% of load at a lower net present value than the gas-only option in seven of ten weather years. The IESO has not publicly reconciled that modelling with a decision to create an exclusive 40-year procurement lane for new hydro, together with the new transmission required to connect those projects to the grid. Citing the Directive does not discharge the IESO’s public-interest obligation to show that new hydro is necessary, least-cost and superior to lower-risk alternatives.

Nor has the IESO published any comparable analysis testing new hydro against wind, solar and BESS portfolios; the reconciliation gap is therefore wider, not narrower.

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IESO: Long-Term 2 RFP – June 16, 2026

By Linda Heron on Friday, July 3rd, 2026

Posted in Long Term 2, IESO, Alternatives, ORA Submissions, Hydroelectric, Regulatory, River Concerns, Dams, Energy, Rivers at Risk, Industry, GHG Emissions, Water Quality

ORA’s central concern is that LT2 is being used, alongside the LLT RFP and roughly 1,800 kilometres of “priority” transmission, to advance ratepayer-backed repowered and new hydropower generation as quickly as possible, without a consolidated accounting of what it will cost ratepayers, in dollars and in emissions. Cost, emissions, public health impacts, fuel price exposure, and stranded asset risk are not external to affordability and reliability; they are a huge part of it. Environmental Defence made the same point in this engagement, cautioning that procurement frameworks “should not treat these externalities as irrelevant to affordability or reliability.” ORA agrees. The IESO’s own Hybrid Resource Portfolio Equivalency Assessment found that a portfolio of wind, solar and battery energy storage systems (BESS) can meet system needs “with 99.50 to 99.98 percent of load served” in every weather year modelled, and “can provide both baseload and peak power.” Wind, solar and BESS are cheaper, cleaner and faster to deploy than hydroelectricity, and far cleaner than gas.

IESO: Regional Electricity Planning in the Northwest Region – June 11, 2026

By Linda Heron on Wednesday, July 1st, 2026

Posted in Transmission, IESO, IRRP, Alternatives, ORA Submissions, Hydroelectric, Climate Change, River Concerns, Dams, Energy, Rivers at Risk, GHG Emissions

The IRRP is the planning vehicle that is meant to consider a broad range of options, including non-wires alternatives. ORA asks the IESO to hold to that purpose in the Northwest. Several large transmission builds are already underway or contemplated for the region: the $1.2 billion dollar Waasigan line, in service between 2026 and 2027,² the Red Lake line north of Dryden, a 230 kV double-circuit build that nearly quadruples the area’s capacity, roughly 400 MW, and is expected in the early 2030s, a planned 230 kV line toward the Greenstone area, and the recently completed East-West Tie at about $777 million. The IESO has not published a cost estimate for the Red Lake line, though it almost certainly holds one; CBC reports it at $830 million. For scale, the province’s new Barrie-to-Sudbury bulk line is estimated at $1.4 to $1.6 billion. These are multi-billion-dollar commitments. A wind, solar, and battery storage package sized to a remote community’s need costs a fraction of a long transmission build and can be deployed far sooner, so communities are not left waiting years for power that a local resource could deliver.

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IESO: Regional Electricity Planning in the Northwest Region – June 11, 2026

By Linda Heron on Wednesday, July 1st, 2026

The Chute, First Falls, Ivanhoe River – Photo by Mark Clement

During the June 11 webinar, ORA asked why wind, solar, and battery energy storage systems (BESS) could not supply some remote communities directly, rather than waiting on long transmission builds, when those resources are cheaper, cleaner, and faster to deploy. The IESO answered that this is “exactly the kind of options and considerations this planning process is meant to consider,” and confirmed that such supply resources “can certainly be done in a shorter timeframe” and “are a key aspect to helping address some of those more near-term needs” for remote communities.¹ ORA welcomes that answer and writes to ensure it is carried into the demand forecast, the scenarios, and the plan that follows.

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