ERO 026-0427, Fortifying Ontario’s Economy: A vision for protecting Ontario, strengthening economic sovereignty, and securing global leadership in critical minerals.

By Linda Heron on Tuesday, June 16th, 2026

A Vermilion River Otter, By Al Oman

A strategy that halves review time, proposes permit-by-rule, ignores its own climate science, weakens species law, short-changes public and Indigenous consultation, commits to century-long methane-emitting reservoir infrastructure over its own innovative and green alternatives, and treats Indigenous consent as an equity transaction, is not protecting Ontario’s economy. It is mortgaging Ontario’s watersheds, its climate resilience, and its relationships with First Nations against a demand the public was never asked to approve. It does all of this to fast-track projects, while the courts are still being asked whether the very laws that enable it are constitutional.

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ERO-026-0415: Proposed Amendments to the Environmental Assessment Act (Comprehensive Environmental Assessment Process), as proposed by Bill 105, Provincial Opportunity and Worker Empowerment Rights Act, 2026

By Linda Heron on Wednesday, May 20th, 2026

Posted in Bill 105, Proponent Led Process, ORA Submissions, Hydroelectric, Environmental Registry, River Concerns, Dams, Energy, Rivers at Risk, GHG Emissions, Regulatory Submissions, Environmental Assessment Act, Species at Risk, Water Quality

Photo by Mark Clement

ORA urges the Ministry to withdraw these proposed amendments. The three changes set out in Schedule 2 of Bill 105 would eliminate the mandatory Ministry Review of the proponent’s environmental assessment (EA) document; the right of any person to request an independent hearing before the Ontario Land Tribunal (OLT); and the requirement for Lieutenant Governor in Council approval of the Minister’s EA decisions. Taken together, these amendments would concentrate final environmental approval authority in a single political office, remove every public mechanism for seeking independent adjudication of EA decisions, and eliminate the only independent expert analytical check in the entire Comprehensive EA process.

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ERO-026-0300: Proposed Planning Act, City of Toronto Act, 2006, Building Code Act, 1992 and Municipal Act, 2001 Changes (Schedules 1, 2 and 7 of Bill 98, the Building Homes and Improving Transportation Infrastructure Act, 2026)

By Linda Heron on Thursday, May 14th, 2026

Posted in Sustainability, Biodiversity, Ontario Building Code, Bill 98, MZOs, ORA Submissions, Aquatic Life, Environmental Registry, Regulatory, Climate Change, River Concerns, Fisheries, GHG Emissions, Land Use, Species at Risk, Municipal, Planning Act, Species at Risk Act

ORA’s concern is direct and practical. MZOs have been used in Ontario to authorize development on or adjacent to sensitive wetlands, floodplains, and river corridors, in some cases over the objections of CAs and local municipalities. The notice requirement has been the only mechanism by which organizations like ORA can identify when a proposed MZO amendment affects a river system, place concerns on the public record, and seek to influence the Minister’s decision before it is made. Removing notice does not constrain the use of MZOs; it makes their use invisible until it is too late. For watershed and river protection purposes, an MZO amendment process with no public notice is a process with no meaningful public participation at all.

ORA submits that notice requirements for MZO amendments and revocations must be retained without qualification. If the government’s concern is administrative efficiency, notice can be provided through streamlined electronic means with a fixed and short comment window. Removing public notice entirely is not a proportionate or defensible administrative reform.

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ERO-026-0301 and ERO-026-0302: Proposed Amendments to the Municipal Act, 2001 and the Safe Drinking Water Act, 2002 Respecting Communal Drinking Water and Wastewater System Municipal Consent Requirements (Schedule 4 of Bill 98, the Building Homes and Improving Transportation Infrastructure Act, 2026)

By Linda Heron on Thursday, May 14th, 2026

Posted in Bill 98, ORA Submissions, Environmental Registry, Regulatory, Climate Change, River Concerns, Rivers at Risk, Fisheries, Municipal, Planning Act, Provincial Policy Statement, Species at Risk Act

These two positions are irreconcilable. ERO-026-0301 says water infrastructure must remain publicly owned. ERO-026-0302 states that municipalities must approve non-municipal water infrastructure, potentially privately owned and operated, on demand once prescribed criteria are met. A government that prohibits private ownership in one part of its water policy framework while mandating municipal approval of private systems in another is not following a coherent policy direction. It is advancing the incremental privatization of water and wastewater service delivery, one subdivision at a time, under a framework designed to make each individual approval appear routine.

ORA submits this letter to both contact addresses, the Intergovernmental Relations and Partnerships Branch for ERO-026-0302 and the Local Government Policy Branch for ERO-026-0301, precisely because the government’s fragmented consultation structure has ensured that neither branch is required to evaluate what the other has posted. These two offices are on the same floor of the same building in the same Ministry. The contradiction between their respective proposals is invisible to the process that is supposed to catch it. ORA is placing it before both branches simultaneously so that it cannot be evaluated in the absence of the other half of the picture.

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ERO-026-0304: Draft Projection Methodology Guideline (PMG), 2026 to Support Implementation of the Provincial Planning Statement, 2024 (Bill 98)

By Linda Heron on Thursday, May 14th, 2026

Posted in Sustainability, Biodiversity, Bill 98, ORA Submissions, Aquatic Life, Environmental Registry, Regulatory, Climate Change, River Concerns, Rivers at Risk, Fisheries, GHG Emissions, Conservation Authorities Act, Species at Risk, Urban Development, Planning Act, Policy & Process, Provincial Policy Statement

West Credit River Brook Trout – Photo by Steve Nokams

ORA submits comments on ERO-026-0304 as part of a coordinated response to the Bill 98 legislative package. ORA has submitted separately on ERO-026-0315 (April 24, 2026), ERO-026-0313, ERO-026-0300, and ERO-026-0301/0302 (all May 14, 2026).⁶,⁷,⁸,⁹ The Projection Methodology Guideline (PMG) is foundational to this package: the land quantum it produces is the primary input driving (ary Expansion (SABE) decisions in official plan updates across Ontario. A methodology that systematically omits environmental constraints from its land supply calculations will generate land need figures that are overstated, ecologically unjustified, and will provide a spurious quantitative basis for designating development onto natural heritage lands, floodplains, river corridors, and watershed recharge areas that cannot and should not be built upon.

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ERO-026-0312: Proposed Changes to Support Standardizing of Parkland Requirements Under the Planning Act (Bill 98)

By Linda Heron on Thursday, May 14th, 2026

Posted in Biodiversity, Bill 98, ORA Submissions, Aquatic Life, Environmental Registry, Regulatory, Climate Change, River Concerns, Dams, Energy, Fisheries, Flooding, GHG Emissions, Land Use, Species at Risk, Planning Act, Policy & Process, Provincial Policy Statement

The Ontario Provincial Climate Change Impact Assessment (OCCIA 2023) documents increasing precipitation intensity, hydrological volatility, and flood frequency across Ontario.⁴ The Auditor General of Ontario’s 2022 report on urban flood risk documented billions of dollars in flood-related municipal infrastructure losses and found that existing floodplain mapping substantially underestimates actual flood risk in many communities.⁵ Flooding events in spring 2024 and spring 2026 across the Sudbury, Ottawa, and Lake Erie watersheds caused widespread municipal infrastructure damage and emergency costs. Municipalities that accept floodplain-adjacent land as parkland will inherit maintenance liability and public safety responsibility for lands that are demonstrably at increasing flood risk.

ORA submits that floodplain-adjacent lands, including valley lands and riparian corridors that fall within but near the boundary of identified hazard areas, should be explicitly ineligible for developer-identified parkland credit, not merely eligible on an undefined condition.

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ERO-026-0313: Streamlining the Information and Material That Planning Authorities Can Require as Part of a Complete Application (Bill 98)

By Linda Heron on Thursday, May 14th, 2026

Posted in Sustainability, Biodiversity, Bill 98, ORA Submissions, Aquatic Life, Environmental Registry, Regulatory, Climate Change, River Concerns, Rivers at Risk, Fisheries, GHG Emissions, Land Use, Species at Risk, Water Quality, Planning Act, Policy & Process, Provincial Policy Statement

Beyond the environmental risk, this proposal represents a significant and troubling shift in where municipal planning authority in Ontario resides. Local municipal councillors, planners and Conservation Authorities (CAs) possess on-the-ground knowledge of their watersheds, floodplains, and natural heritage systems that no standardized provincial list can replicate. They know which river reaches flood unpredictably, which unclassified wetlands provide critical flood attenuation, and which development proposals require additional study because of conditions unique to the local landscape.

Removing municipalities’ legal authority to act on that knowledge, and substituting a provincial uniformity standard in its place, moves decision-making away from the communities that must live with the consequences of planning decisions and toward a provincial administration that is not accountable to local conditions. This is not an administrative convenience; it is a transfer of authority over local environmental risk from the local governments best positioned to understand it, to a provincial government that has demonstrated, through the volume and pace of these interconnected regulatory changes, that its priority is development speed rather than environmental stewardship.

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One Project, One Review: Co-operation Agreements for the Assessment of Major Projects

By Linda Heron on Friday, November 7th, 2025

Posted in Dam Removals, ORA Submissions, Hydroelectric, Bills, River Concerns, Dams, Energy, Waste Water Treatment Facilities, Government, Fisheries, GHG Emissions, Regulatory Submissions, Mining, Environmental Bill of Rights, Environmental Protection Act

Vermilion River – Our grandchildren’s future with water!

ORA’s recommendations call for enforceable public-participation standards, clear cumulative-effects gatekeeping, transparent reasons for any federal withdrawal, Indigenous-led consultation processes, and a national commitment to freshwater conservation and resilience. While ORA’s work spans mining (including Ring of Fire), hydropower, wastewater-treatment facilities, and dam-safety issues, these examples illustrate, rather than shift, the focus to the urgent need for fair, transparent, science-based federal oversight.

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How to Truly “Build Canada Strong”

By Linda Heron on Thursday, May 29th, 2025

While constitutional change is never easy, the right to a healthy environment is a moral imperative that Canada can no longer afford to ignore—our laws must finally reflect what science and justice demand.

Over 150 countries recognize these environmental rights in law. As the United Nations notes, Canada’s delay is ‘inconsistent with its human rights obligations’[i]—a constitutional gap that perpetuates harm.”

As the UN and Supreme Court affirm environmental rights globally, Canada’s Constitution remains an outlier—a failure we must rectify. From wildfires to poisoned waterways, Canadians are paying the price for this omission. Constitutional change is not optional—it’s survival.

[i] UNEP, Environmental Rule of Law: Global Assessment (Nairobi, 2019), 23. Continue reading →

Omnibus Bill 5 & Associated ERO Notices: 025-0409, 025-0416, 025-0418, 025-0389, 025-0396

By Linda Heron on Friday, May 16th, 2025

Posted in Bill 5, Mining Act, Electricity Act, ORA Submissions, Environmental Registry, Regulatory, Regulatory Submissions, Endangered Species Act, Environmental Assessment Act, Environmental Bill of Rights

The ORA is writing in response to Omnibus Bill 5, Protecting Ontario by Unleashing the Economy Act, 2025, introduced to the Ontario Legislature on April 15, 2025, and its associated schedules and Environmental Registry of Ontario (ERO) postings. ORA strongly opposes this sweeping omnibus bill, which undermines Ontario’s environmental protections, public and Indigenous rights, and constitutional and legal obligations. Bill 5 and its related schedules represent a regressive and dangerous rollback of vital environmental safeguards and democratic oversight mechanisms.

Bill 5 and its associated schedules and ERO postings represent a sweeping and unprecedented attack on Ontario’s environmental rule of law, public participation rights, and Indigenous sovereignty and rights. The Protecting Ontario by Unleashing the Economy Act, 2025, is misinformation—it does not protect Ontario but rather dismantles the province’s core environmental, legal, and democratic foundations.

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