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-026-0300: 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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ERO-026-0315 — Consultation on Upper-Tier Official Plans, Secondary Plans, and Site- and Area-Specific Policies (Bill 98)

By Linda Heron on Friday, April 24th, 2026

Posted in ORA Submissions, Aquatic Life, Environmental Registry, Regulatory, Climate Change, River Concerns, Dams, Rivers at Risk, Species at Risk, Water Quality, Planning Act, Policy & Process, Provincial Policy Statement, Public Lands Act

A Vermilion River Otter, By Al Oman

ERO-026-0315 is the latest in a series of rapid, interconnected changes to Ontario’s planning framework. Since 2018, successive amendments to the Planning Act have progressively weakened environmental protections, reduced public participation requirements, and concentrated approval authority in the Minister of Municipal Affairs and Housing.¹ ERO-026-0315 continues this trajectory.

This erosion of planning oversight is compounded by the concurrent restructuring of Conservation Authorities. Ontario’s 36 watershed-based Conservation Authorities, each delineated according to the natural boundaries of local watershed systems, are being amalgamated into 9 regional bodies with vastly larger geographic territories.

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Success: Delegation to Sudbury Planning Committee to exclude hydroelectric in its Official Plan

By Linda Heron on Monday, February 9th, 2026

Posted in Biodiversity, Hydroelectric, Aquatic Life, Regulatory, Climate Change, River Concerns, Dams, Energy, Rivers at Risk, Joint, GHG Emissions, Water Quality, Planning Act, Provincial Policy Statement, Renewable Energy on Crown Land, Vermilion River

Scanning Wabagishik for mussels.

The City Planning Committee passed a resolution to exclude hydro from the City of Sudbury Official Plan, which now states:

“Renewable energy generation shall be permitted in accordance with all federal and provincial requirements, excepting hydroelectric technologies.”

Vermilion River Stewardship Recommendation:

That Sudbury’s Official Plan explicitly exclude new hydropower development. This provides staff with clear direction, reduces ad hoc approvals, aligns with our climate commitments, and protects the City from long-term environmental and financial risk. Council would still retain discretion to consider exceptional proposals through a public process.

In the News:

City council says no to hydroelectric power, by Tyler Clarke, Sudbury.com, 11 February 2026.

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Section 16 Order Request: Allan’s Dam, Spillway and Sluiceway, City of Guelph, Speed River

By Linda Heron on Friday, November 28th, 2025

Posted in Allan's Dam, MCEA, Dam Removals, ORA Submissions, Aquatic Life, Dam Removal, Climate Change, River Concerns, Dams, Removal, Rivers at Risk, Studies & Reports, Speed River, Planning Act

Infrasture stacked on top of and surrounding Allans Dam and Spillway.

The handling and outcome of the Macdonell and Allan’s Structures MCEA constitute a serious procedural failure that infringes on the constitutionally protected Aboriginal and treaty rights of the Six Nations of the Grand River, the Mississaugas of the Credit First Nation, and the Haudenosaunee Confederacy. Throughout the five-year MCEA process, the City withheld essential information—including the dam’s true age (155 years), the absence of any structural or subsurface assessment, the deteriorated condition of the spillway, and the 2018 OSIM recommendation for a LRIA-compliant Dam Safety Review. None of this was disclosed to Indigenous rights holders, despite the project’s direct implications for the Speed River, its fish, habitat, water quality, and flood risk.

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ERO-025-1097 – Proposed Changes to the Planning Act

By Linda Heron on Thursday, November 20th, 2025

Posted in Sustainability, Environmental Registry, Regulatory, River Concerns, Energy, Rivers at Risk, Land Use, Urban Development, Municipal, Planning Act, Provincial Policy Statement

Photo by Steven Noakes

The ORA is strongly opposed to the proposed amendments to the Planning Act in Schedule 10 of Bill 60, Fighting Delays, Building Faster Act, 2025. These changes further erode Ontario’s already weakened land-use planning system, remove core environmental and climate safeguards, undermine public and Indigenous rights, and consolidate extraordinary discretionary powers in the hands of the Minister.

These proposals follow a multi-year trend of dismantling core environmental protections, accelerating sprawl, and sidelining evidence-based planning in favour of political expediency. Schedule 10 is not a “streamlining” measure—it is a structural restructuring of Ontario’s planning regime at the direct expense of watershed health, climate resilience, and public accountability.

ORA urges the Province to withdraw Schedule 10 in its entirety.

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