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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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 Lead-Time RFP – February 26, 2026

By Linda Heron on Wednesday, March 11th, 2026

Posted in Long Lead-Time, Crown Land Use Policy, Algae, ORA Submissions, Hydroelectric, Site Release, Regulatory, River Concerns, Energy, Rivers at Risk, Government, Industry, Class EA for Waterpower, Water Quality, Renewable Energy on Crown Land

Lake Sturgeon stranded in a hydroelectric facility’s overflow channel.

In the February 26 Long Lead-Time (LLT) engagement, IESO staff confirmed that proponents are not required to include the flooded area or headpond in their LLT application and that inundation details can be left to the environmental assessment stage. That approach might be administratively convenient, but it is not acceptable for water-based projects with 40-year contracts. The headpond and inundation zone are not minor details; they are often the largest part of a hydro facility’s footprint, which can spread over the riverbank, affecting wetlands, private property, municipal infrastructure, upstream creeks and tributaries, and the full extent of aquatic habitat that will be flooded or subject to fluctuating water levels. Many hectares of previously dry land can be flooded to make these projects work and are key to generating power on demand, especially on smaller rivers under 10 MW.

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IESO: Long Lead-Time RFP – January 28, 2026

By Linda Heron on Wednesday, February 11th, 2026

Photo by Al Oman

ORA is increasingly concerned by the cumulative financial burden being placed on Ontario electricity ratepayers through IESO procurement and contract design choices. Across recent engagements, ratepayers have been positioned as the default risk absorber for:

Retention and monetization of environmental attributes and clean energy claims funded through ratepayer-supported contracts, even where those attributes are later used to meet industrial or policy objectives.

Stacking of multiple compensation mechanisms—energy payments, capacity payments, environmental attributes, and risk-mitigation provisions—for the same facility, without commensurate accountability for performance under real-world operating and climate conditions

Long-term fixed-price contracts for resources whose performance is declining under climate change.

Settlement mechanisms that compensate for non-delivery rather than enforcing performance discipline.

Escalating system costs associated with transmission expansion, deliverability constraints, and congestion management.

Stranded or underperforming assets locked into multi-decade contracts.

Policy-driven procurement volumes that exceed demonstrated domestic reliability needs.

ORA is concerned that ratepayers are financing the assets and contracts that generate those credits, only to be told the credits are “extra value”. Concerned that environmental benefits and clean energy attributes are being treated as additive system value even where the underlying resource is energy-limited, intermittently unavailable, or unable to perform during system stress events. When ratepayers fund long-term contracts, absorb hydrologic risk, and also underwrite environmental attributes for the same facility, the result is cost stacking rather than value creation. This approach obscures true system costs and further weakens the link between public expenditure and actual climate or reliability outcomes. Environmental attributes should not be used to mask or compensate for poor operational performance or climate vulnerability.

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IESO: Repowering Existing Hydroelectric Facilities – October 20, 2025

By Linda Heron on Thursday, November 20th, 2025

Posted in Long Term 2, IESO, Northern Hydro, Small Hydro, Hydroelectric, Regulatory, River Concerns, Dams, Energy, Rivers at Risk, Government, Industry, Class EA for Waterpower, Species at Risk, Water Quality, Renewable Energy on Crown Land

While there are limited theoretical benefits associated with repowering older hydroelectric facilities, these benefits do not withstand serious scrutiny when assessed through the lens of climate resilience, ecological integrity and sustainability, dam-safety obligations, and long-term system reliability. Ontario’s legacy hydro fleet—particularly facilities under 10 MW share common structural, hydrological, and environmental constraints that make repowering neither cost-effective nor aligned with modern electricity system needs.

These facilities rely on shallow, warming headponds highly vulnerable to drought, erratic inflows, and extreme precipitation events, producing increasingly unreliable and unpredictable generation. Their reservoirs continue to emit methane from decades of sediment accumulation, degrade water quality, and lack fish passage, perpetuating habitat fragmentation and cumulative watershed harm.

For these reasons, excluding facilities under 10 MW from repowering eligibility is both reasonable and evidence-based. Hydrologically and structurally, these aging dams experience worsening inflow volatility, growing climate-risk exposure, and escalating regulatory obligations, making repowering economically irrational once full sediment, safety, and environmental requirements are applied.

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ERO-025-0449 – Advancing New Hydroelectric Generation in Ontario

By Linda Heron on Thursday, June 12th, 2025

Posted in Sustainability, ORA Submissions, Hydroelectric, Aquatic Life, Environmental Registry, Regulatory, Climate Change, River Concerns, Dams, Energy, Rivers at Risk, Industry, Fisheries, Class EA for Waterpower, GHG Emissions, Water Quality

Abitibi River – Twin Falls GS

The ERO proposal frames hydroelectricity as a clean energy source that will help Ontario “harness its clean energy advantage.” This is misleading and inconsistent with current science. Hydropower reservoirs—especially those in temperate and boreal regions—are now recognized as significant emitters of methane, a greenhouse gas with a global warming potential 84 to 86 times more powerful than carbon dioxide over a 20-year period.[i]

The promotion of hydropower as “clean,” “renewable,” “zero-carbon,” and “non-emitting” is a common term used by governments and the waterpower industry to greenwash their dirty secret during this growing climate crisis.

[i] IPCC. Climate Change 2021: The Physical Science Basis. Cambridge University Press; 2021. https://www.ipcc.ch/report/ar6/wg1

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2025 Annual Planning Outlook: Demand Forecast October 30, 2024

By Linda Heron on Wednesday, November 13th, 2024

OPG alone has 66 hydroelectric facilities in Ontario with an additional 251 associated control dams supporting those facilities, and to highlight the lack of stewardship of the OWA and OPG and their powerful influence over politicians:

Ontario has 225 hydroelectric facilities and likely several hundred more associated control dams, yet there are only 2 operating fishways in all of Ontario. This is a consequential problem because dams are a major factor in the extirpation of Ontario’s Atlantic Salmon stock, one of the most important causes of significant anthropogenic mortalities and decline of Ontario’s American Eel, and a key threat to Ontario’s declining Lake Sturgeon populations.

No up-front decommissioning dollars are required to be made for removal of these hydroelectric dams when they become unsafe or extended drought conditions make them a liability to our children’s future with clean water. There are zero funds in place to remove them.

The OWA is responsible for amendments to the Class Environmental Assessment for Waterpower that can skip over public consultation if the proponent deems the project to be low risk. There are no low-risk hydroelectric projects, especially now that we are facing a future of rising temperatures, extreme rain events and extended droughts.

The OWA is also responsible for removing public consultation for proponents converting old control dams into new hydropower generation facilities.

Public consultation and meaningful engagement actually improve a project when stakeholders have input into how the project might benefit or negatively impact on local communities. Continue reading →

Request for Information: Long Lead Time Resources – Hydroelectric

By Linda Heron on Friday, November 1st, 2024

Posted in ORA Submissions, Hydroelectric, Regulatory, River Concerns, Dams, Energy, Rivers at Risk, Government, Industry, Fisheries, Class EA for Waterpower, Clean Energy Credits, GHG Emissions, Regulatory Submissions

When companies convey false, misleading or unsubstantiated claims of environmental benefits or clean, green, renewable, sustainable, or non-emitting, they are considered to be engaging in greenwashing.

Hydroelectric facilities will last for 100 years or more, so it is essential that full life-cycle costs associated with any new projects are carefully assessed in terms of sustainability, including GHG emissions, impacts to ecosystem services, fisheries, water quality and water quantity, as well as the eventual decommissioning of the facility. Decommissioning involves millions of dollars and is likely to be necessary sooner than expected. Rivers will be severely impacted as climate change progresses, and it is already happening in many regions of North America where rivers are drying up or not having enough flow to turn the turbines.

Again, it is important to remember that you can turn off a gas-fired generator when a cleaner technology comes along, (there are already much cleaner technologies), but a hydroelectric reservoir will keep on producing methane until the dam is removed – in 100 or 200 years or more.

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IESO Long-Term 2 RFP Engagement – April 4, 2024

By Linda Heron on Tuesday, April 23rd, 2024

Posted in Long Term 2, IESO, ORA Submissions, Hydroelectric, Aquatic Life, Regulatory, Climate Change, River Concerns, Dams, Energy, Rivers at Risk, Government, Class EA for Waterpower, GHG Emissions, Regulatory Submissions, Water Quality, Green Energy Act

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

Unfortunately, the hydropower industry, as well as all levels of government, have ignored the extensive body of evidence compiled over the last few decades, indicating that hydroelectric reservoirs contribute approximately 5 to 7% of global GHG emissions that, individually, can rise to the level of a gas-fired facility. Instead, the industry and this government greenwash it with disinformation by labelling it as non-emitting, low-emitting, clean or renewable to mislead the public into believing it will cut GHG emissions when, in fact, it will be adding significantly to global emissions until the dam is removed.

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Hydroelectric Program Development and Assessment – IESO Small Hydro Program

By Linda Heron on Friday, May 13th, 2022

Posted in IESO, Small Hydro, ORA Submissions, Hydroelectric, Heavy Metal Contamination, Pollution, River Concerns, Energy, Rivers at Risk, Industry, Class EA for Waterpower, Regulatory Submissions, Species at Risk, Water Quality, Ontario Water Resources Act

Lake Sturgeon stranded in a hydroelectric facility’s overflow channel.

First, it was enlightening to be provided with a clear definition of small and large hydro facilities in the Hydroelectric Program Development and Assessment webinar, as well as a total amount of power generated by these categories. You informed that the definition of small hydro would have a scope of installed capacity of 10 MW and under, with 30 companies representing 50 facilities generating a total of 120 to 150 MW, and large hydro having a scope of installed capacity of over 10 MW, with 3 companies representing 22 facilities producing a total of 1,000 MW.

The increased number of small hydro facilities making such a small contribution to our electricity grid impacts on multiple Ontario riverine ecosystems, whereas the 22 facilities producing 1,000 MW of power on presumably fewer rivers has a much lower trade-off value. Additionally, larger rivers have a greater capacity to buffer some of the worse effects of hydroelectric.

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