ERO-026-0696: Changes to Streamline Natural Resource Permits: Removal of Forest Resources (Trees) for Non-Forestry Activities Proposed addition of the Environmental Protection Act, 1990 to the listed Acts

By Linda Heron on Friday, September 25th, 2026

Vermilion River – Our grandchildren’s future with water!

ORA is deeply concerned about where these changes lead when they are taken together. The streamlining of environmental assessment, the spread of permit-by-rule, and the government’s direction to move MNR away from its strengths in protecting public land would leave Ontario’s forests and rivers, and the rich social and economic values they hold, to be decided project by project by proponents whose bottom line is profit. Together, these changes would roll back more than a century of public stewardship and place the health and safety of communities at dire risk.

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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ORA has made it clear that we are strongly opposed to this proposal and that it should be withdrawn.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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Speed River: Macdonell and Allan’s Structures Municipal Class Environmental Assessment

By Linda Heron on Tuesday, October 28th, 2025

Posted in Allan's Dam, MCEA, Dam Removals, ORA Submissions, Dam Removal, Speed River, Lakes & Rivers Improvement Act, Municipal

Allan’s Dam & Allan’s Dam Bridge, Guelph, Speed River.

Our own research revealed that Allan’s Dam is a legacy mill dam, originally constructed in the 1830s to power Allan’s Mill—one of Guelph’s founding industrial sites. Sometime later, the structure was adapted for hydroelectric generation, likely in the early to mid-20th century. It is our understanding that this facility has not generated electricity for several decades and now functions only as an aging dam, concrete spillway and sluiceway, impounding a shallow headpond on the Speed River. It appears that this infrastructure no longer serves any useful purpose while continuing to fragment habitat, degrade water quality, and emit copious amounts of carbon, methane, and nitrous oxide into the atmosphere.

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ERO-019-4300 – Exempting 5 LRIA Orders from EBR Stakeholder Consultation Requirements

By Linda Heron on Friday, April 19th, 2024

Posted in Dam Removals, Environmental Registry, Regulatory, River Concerns, Dams, Removal, Lakes & Rivers Improvement Act

The ORA is in strong support of ensuring that MNRF is more efficient in issuing permits to remove old and unsafe dams; however, we are strongly opposed to exempting these five LRIA orders from the requirements to consult the public under Part II of the EBR. This would mean that stakeholders, the public and Indigenous communities would have no opportunity to be consulted and provide input on projects that could heavily impact their property values, quality of life, and other important landowner interests!

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Exempting dams from requiring a Permit to Take Water – ERO-019-2517

By Linda Heron on Friday, November 20th, 2020

Posted in ORA Submissions, Permit to Take Water, Dam Agreements, Impacts, Environmental Registry, Regulatory, River Concerns, Dams, Rivers at Risk, Industry, Safety, Fisheries, Regulatory Submissions, Species at Risk, Water Quality, Lakes & Rivers Improvement Act, Ontario Water Resources Act

Melville Dam, Credit River, breached on 26 June 2017

ORA submits that the MECP’s priority must be the pursuit of its Statement of Environmental Values (SEV), and its vision and mandate of “an Ontario with clean and safe air, land and water that contributes to healthy communities, ecological protection, and environmentally sustainable development for present and future generations”[i]. There is nothing in the MECP’s SEV that promises to “remove the regulatory burden” from industry or “provide some cost savings for dam owners and operators”. It is not the MECP’s duty to save dam owners and operators money or ease their regulatory burden. Its duty is to fulfill its Mandate to protect the environment and to follow its promise of environmentally sustainable development for our present and future generations. Certainly, MECP’s priority should not be to cut regulatory burden at the expense of our air, land and water. It is a tragedy that today’s cost savings for dam owners and operators will be borne on the backs of our children and grandchildren.

[i] Statement of Environmental Values: Ministry of the Environment and Climate Change

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Monitoring of Mercury Near Dams – LRIA, Ontario Regulation 102/20

By Linda Heron on Tuesday, May 19th, 2020

Posted in ORA Submissions, Water Management Plan, Permit to Take Water, Bills, Environmental Registry, Regulatory, Government, Bill 132, Industry, Joint, Support, Lakes & Rivers Improvement Act, Ontario Water Resources Act

ORA is very concerned about the extreme deregulation that occurred with the recent waterpower exemption to the Permit to Take Water, and in this new Mercury Regulation where new and significantly redeveloped electricity producing dams have not been addressed. These important legislative requirements were designed to ensure hydroelectric facilities are held accountable for environmental and socio-economic impacts and risks to communities and riverine ecosystems.

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ERO-019-1060 – Proposal to amend Ontario Regulation 454/96 (Construction) to provide alternative regulatory approval requirements for repairs to existing low hazard wetland dams

By Linda Heron on Monday, February 3rd, 2020

Posted in Dam Removals, ORA Submissions, Dam Removal, Environmental Registry, Regulatory, Regulatory Submissions, West Credit River, Lakes & Rivers Improvement Act

The Rudd Dam’s headpond had essentially turned into a large wetland created by over 100 years of sediment accumulating behind the dam, and the shallow pond’s water temperature was no longer viable brook trout habitat. After the removal of the Rudd Dam the water temperature was reduced and brook trout habitat was made more resilient to a warming climate. It was also an earthen dam that had already failed once, and the dam owner’s objective was to reduce his risk and liability.

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ORA Speaks to the Legislature, Re: Omnibus Bill 132

By Linda Heron on Monday, November 25th, 2019

Posted in ORA Submissions, Permit to Take Water, Bills, Environmental Registry, Regulatory, Presentations, River Concerns, Government, Bill 132, Industry, Regulatory Submissions, Lakes & Rivers Improvement Act, Ontario Water Resources Act

With the warming temperatures and extreme rain and drought events that climate change is predicted to bring with increasing frequency and intensity as time passes, decision makers and legislators bear a responsibility to strengthen freshwater protection and resiliency – not weaken it. If this proposal moves forward it will be a precipitous turning point for our future with freshwater in Ontario and beyond.

You will find ORA’s submissions regarding Bill 132 here.

Check out ORA’s speech to the Standing Committee on General Government: Continue reading →

Hillsburgh Dam and Bridge Class EA – Part II Order Request

By Linda Heron on Wednesday, February 1st, 2017

Posted in Rehabilitation, Hillsburgh Dam, Part II Order requests, River Concerns, Dams, Removal, Rivers at Risk, Government, Fisheries, West Credit River, Lakes & Rivers Improvement Act

It is imperative that the Town of Erin examines every means possible to make its community more resilient to climate change, and most importantly, to protect its finite freshwater resources and its fishery. In fact, consideration of climate change was not even mentioned within the EA documentation, and ORA sees this as a major flaw, when it should have been included as a key consideration in the Scoring Matrix.

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Decision Notice: Alterations, Improvements & Repairs to Existing Dams, LRIA

By Linda Heron on Friday, April 1st, 2016

Posted in Technical Bulletins, ORA Submissions, E-Newsletter, ORA Reports, Dam Removal, Regulatory, River Concerns, Dams, Removal, Rivers at Risk, Government, Repair/Replacement, Regulatory Submissions, Lakes & Rivers Improvement Act

Misner Dam, Port Dover

In November of 2015, Ontario Rivers Alliance (ORA) commented on EBR 012-5093, regarding a Technical Bulletin for the Alterations, Improvements and Repairs of Existing Dams. You can find our submission on our Blog here. On March 24, 2016, ORA received a Decision Notice, as well as the approved Technical Bulletin. Continue reading →