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.

Continue reading →

IESO: Long Lead-Time RFP – March 26, 2026

By Linda Heron on Wednesday, April 15th, 2026

Posted in Long Lead-Time, Crown Land Use Policy, ORA Submissions, Hydroelectric, Climate Change, River Concerns, Dams, Energy, Rivers at Risk, Government, GHG Emissions, Regulatory Submissions, Water Quality

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

This is a fundamental failure of open and transparent dialogue before municipal and Indigenous consent is awarded. For any hydroelectric development, the full hydraulic footprint, including the headpond, inundation zone, drawdown range, and affected upstream and downstream wetland and river reaches, constitutes the project’s actual physical and ecological footprint. Limiting the project site definition to the dam structure and immediate generating works conceals the true scope of the project from the municipality, Indigenous communities, and the public before the Municipal Support Resolution or Evidence of Indigenous Support is received.

ORA’s position, consistent with our March 2026 submission, is that proponents must fully disclose the complete hydraulic footprint to the municipality and Indigenous communities. This information is required for:

Meaningful environmental considerations and impact assessment

Number and extent of all project sites required

Free, prior, and informed consent processes with affected First Nations and Métis communities

Accurate assessment of land tenure, Crown resource conflicts, and access rights

Informed public participation

Continue reading →

IAAC: Ontario Pumped Storage Hydropower Project – Project Reference: 89803

By Linda Heron on Monday, April 6th, 2026

Posted in Long Lead-Time, IAAC, Pumped Storage, IESO, ORA Submissions, Hydroelectric, Lake Sturgeon, Climate Change, River Concerns, Energy, Fisheries, GHG Emissions, Species at Risk, Water Quality

The Ontario Pumped Storage Project Initial Project Description – Plain Language Summary presents an incomplete, proponent-favourable characterization of a project with potentially severe, long-duration, and in some cases irreversible environmental consequences. The most critical gaps are the absence of a cumulative effects assessment, the inadequate treatment of fish entrainment and contaminant mobilization risks, the incomplete Species at Risk inventory, the absence of OCCIA 2023 considerations, and the lack of a genuine alternatives analysis.

Continue reading →

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.

Continue reading →

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.

Continue reading →

IESO: Long Lead-Time Request for Procurement – 18 December 2025

By Linda Heron on Thursday, January 15th, 2026

Posted in Long Lead-Time, ORA Submissions, Hydroelectric, Regulatory, Climate Change, River Concerns, Energy, Rivers at Risk, GHG Emissions, Regulatory Submissions, Water Quality

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.

Small hydro is often promoted as “clean”, “non-emitting”, and “low impact”, implying it causes little environmental harm and does not emit greenhouse gases. In practice, that claim is indefensible. Even so-called run-of-river projects still fragment river systems, create an impounded reach, and trap sediments and organic matter, producing and releasing greenhouse gases—particularly methane—from the impounded reach, and at downstream discharge points (turbine, intake, spillway, and downstream of the dam).

This is not theoretical: peer-reviewed research has documented methane release “hot spots” associated with small dams in a temperate European river system, where sedimentation behind six small dams significantly increased freshwater methane flux and methane bubbling (“ebullition”). This mechanism is straightforward and directly relevant to Ontario because it is driven by conditions commonly created by small hydro and run-of-river impoundments: shallow water that warms easily, sediment and organic matter accumulation, and nutrient enrichment.

Importantly, methane generation occurs largely at the sediment–water interface, meaning shallower impoundments can emit more methane per unit area than deeper reservoirs. Where rivers receive elevated nutrient inputs and organic loading—including from wastewater effluent and agricultural runoff—impoundments become biogeochemical “reactors” that intensify anaerobic decomposition and methane formation. In other words, methane risk is not only a “reservoir size” issue but is also strongly driven by site conditions, sedimentation, operating strategies, temperature, and upstream nutrient loading.

Continue reading →

IESO: Long Lead-Time Request for Proposals – November 19, 2025

By Linda Heron on Wednesday, December 3rd, 2025

Posted in Long Lead-Time, Sustainability, Biodiversity, ORA Submissions, Hydroelectric, Micro-hydro, Regulatory, River Concerns, Dams, Energy, Rivers at Risk, Government, GHG Emissions, Regulatory Submissions

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

The proposed eligibility requirements for hydroelectric resources are fundamentally misaligned with Ontario’s climate realities, freshwater vulnerabilities, and the scientific evidence on reservoir emissions. Climate-driven warming, drought—deluge cycles, thermal exceedances, and declining summer flows further worsen their impacts and are documented extensively in Environment and Climate Change Canada’s Synthesis of Freshwater Science in Canada. It provides federal scientific confirmation that Canadian freshwater systems are increasingly threatened by warming temperatures, altered hydrology, extreme precipitation patterns, habitat fragmentation and biodiversity declines.[i] Exactly the pressures that make new hydropower dams and reservoirs even more damaging.

In addition, the Ontario Provincial Climate Change Impact Assessment and Technical Report Appendices[ii] must be incorporated into the Minister of Energy and IESO’s decision-making regarding hydropower. It is crucial that Ontario’s electricity planning is anchored in climate reality, not supply-driven industrial aspirations and untenable dreams of becoming an “Energy Superpower”, on the backs of ratepayers and the environment, no less.

[i] Environment and Climate Change Canada. “Synthesis of Freshwater Science in Canada, An overview toward informing discussion on prioritizing of freshwater science activities”.
[ii] Ontario Provincial Climate Change Impact Assessment and Technical Report Appendices.

Continue reading →

ORA & VRS: Delegation to Sudbury Planning Committee – Including hydro in its Official Plan

By Linda Heron on Tuesday, November 4th, 2025

Wabagishik Rapids, Vermilion River

Hydropower has been aggressively greenwashed for decades, despite well-documented, significant, and ongoing adverse environmental effects from its impoundments and peaking operations.

The negative environmental effects of hydro dams, reservoirs, and operating strategies can be extensive, affecting many kilometres upstream and downstream of the dam. That series of five cascading projects, six counting Vale’s Wabagishik Generating Station, would have been strung out for over 130 km of river, impacting from Capreol, all the way out to where it joins the Spanish River. It would have dramatically changed the Vermilion on many levels, stirring up contaminated sediment and impacting local residents who rely on the River for drinking water.

Proponents often claim hydro projects will last for 100 years, but there is a dark side to that.

Over the last three decades, a growing body of independent peer-reviewed research reports that hydroelectric reservoirs can be a significant and ongoing source of GHG emissions in boreal, temperate, and tropical regions. In fact, reservoir methane emissions can rival or exceed those coming from natural gas facilities over a 20-year horizon (e.g., DelSontro et al., 2018; Beaulieu et al, 2020; Scherer & Pfister, 2016).

Continue reading →

ORA Feedback on IESO Long Lead-Time Hydroelectric – 23 April 2025

By Linda Heron on Friday, May 9th, 2025

On April 30, 2024, Parliament amended the Competition Act in Bill C-59 to explicitly address greenwashing. The Act requires that environmental claims be evidence-based as they relate to deceptive, misleading, and false marketing provisions. Claims about the future can be considered greenwashing if they represent little more than wishful thinking and are especially serious for businesses regarding internationally recognized methodologies related to common claims of achieving net-zero.

Environmental claims matter to consumers and influence their decisions, which is a primary reason for businesses making these claims in the first place. Note: Underlining is for emphasis only.

For instance, in February 2023, ORA confronted Ontario Power Generation and the Ontario Minister of Energy for promoting hydroelectric power generation as clean and non-emitting. Between 2013 and 2022, OPG sold over $5.5 million in Clean Energy Credits (CEC) in a private revenue-making scheme to offset greenhouse gas (GHG) polluters that, in effect, ended up paying OPG to fuel climate change. This is precisely the type of disinformation that would be considered greenwashing and likely considered fraudulent.

Continue reading →