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Category Archives: Long Term 2

IESO: Long-Term 2 RFP – August 20, 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-Term 2 RFP – June 16, 2026

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: Long-Term 2 RFP Feedback – April 21, 2026

The IESO’s Hybrid Resource Portfolio Equivalency Assessment (August 2025) demonstrated that portfolios built from wind, solar, and battery storage can meet Ontario’s electricity needs with reliability approaching 99.9 percent load served in modelled scenarios, all the way out to 2050.

That finding should have clarified Ontario’s path forward. Instead, the Minister of Energy rejected that direction and directed the IESO to advance new hydropower procurement, stating that these competing technologies “are deemed not well-suited to competing against resources with shorter development timelines and lifespans… but are able to offer unique benefits to Ontario’s electricity system through resource diversification.” Unfortunately, the Minister did not identify or quantify these ‘unique benefits,’ nor demonstrate that they outweigh the higher cost, longer timelines, and increased risk associated with hydropower.

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IESO: Long Term 2-Request for Proposals – February 24, 2026

Photo by Alan Oman

This position is grounded in climate science. Hydropower is not fuel-free: its fuel is freshwater. The 2023 Ontario Provincial Climate Change Impact Assessment (OPCCIA), issued by the Ministry of the Environment, Conservation and Parks (MECP), documents clearly that Ontario’s freshwater systems face increasing hydrologic volatility, reduced reliability of seasonal flows, and growing constraints on water availability—particularly during summer peak-demand periods.[i] These are the precise conditions that determine whether a hydropower facility can fulfil the output obligations of a long-term contract.

[i] Climate Risk Institute. (2023). Ontario Provincial Climate Change Impact Assessment Technical Report. Report prepared by the Climate Risk Institute, Dillon Consulting, ESSA Technologies Ltd., Kennedy Consulting and Seton Stiebert for the Ontario Ministry of Environment, Conservation and Parks. Online: https://www.ontario.ca/page/ontario-provincial-climate-change-impact-assessment

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IESO: Repowering Existing Hydroelectric Facilities – October 20, 2025

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

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).

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ORA Feedback on IESO Long-Term 2 RFP – April 24, 2025

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

For over a century, hydropower has been greenwashed as a clean, renewable, and non-emitting energy source. In reality, hydro dams and their reservoirs are major drivers of climate change–emitting methane, carbon and nitrous oxide throughout their entire lifespan. Beyond greenhouse gases, their operations can reduce water quantity for long durations of time, degrade water quality, result in erosion, sedimentation, methylmercury contamination in fish, disrupt ecosystems, and threaten biodiversity. Far from being a clean and sustainable solution, hydropower poses serious environmental risks as long as the dam remains standing.

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IESO Long-Term 2 RFP Engagement – September 12, 2024

Wabagishik Rapids, Vermilion River

The Ontario Rivers Alliance supports the requirement for Municipal and Indigenous support resolutions; however, there is much more to learn about the project before its final approval by the Minister of Environment. There must also be a process for a Municipality or Indigenous community to withdraw support if a proponent is not forthcoming with truthful and transparent information about the potential impacts that could result from the proposed project.

Our experience throughout the last surge of new hydroelectric proposals, from 2010 to 2016, was that in order to gain approval, proponents communicating with municipalities and the public tend to skip and ignore the potential negative impacts of hydroelectric projects with the sole focus on its benefits.  The benefits and the negative impacts are very well understood, but often ignored by the proponents.

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

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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Feedback on IESO Resource Adequacy and Long-Term 2 RFP Feedback on Engagement

Abitibi River – Twin Falls GS

The ORA is providing feedback on the 22 February 2024 Independent Electricity System Operator (IESO) webinar. ORA strongly objects to agricultural land being used for energy projects, as it is just another land-grab opportunity. Agricultural land is Ontario’s vitally important breadbasket, and it must be protected.

ORA also strongly objects to new hydroelectric being included as a “non-emitting” resource, eligible for the Long-Term 2 Request For Proposals (LT2-RFP). It was clearly stated in the engagement workshop and in the slide presentation that “the IESO has been asked by the Ministry of Energy to review the role of existing assets and new non-emitting electricity resources that can be in-service by 2029 including wind, solar, hydroelectric, storage and bioenergy”.

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