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Category Archives: Policy & Process

ERO 026-0419: Invitation to Municipalities to Register Potential Interest in Implementing a Water and Wastewater Public Corporation Model

By Linda Heron on Tuesday, August 11th, 2026
Posted in Sustainability, Drinking Water, Statement of Env. Values, Environmental Registry, River Concerns, Waste Water Treatment Facilities, Government, Environmental Compliance Approval, Sewage, Urban Development, Water Quality, Policy & Process, Safe Water Act, Sewage

The notice asks municipalities why they are interested in the model and how they anticipate it “will improve” their services; what their fiscal circumstances are; what steps they are taking on infrastructure; how independent governance “would benefit” their systems; how their proposal “improve[s] efficiency and generate[s] economies of scale”; and whether they are “willing to merge your water and wastewater systems into a public utility with surrounding systems.”1

Not one question asks about risk. Not one asks about drinking water sources, receiving waters, watersheds, climate resilience, affordability for low-income households, First Nations, or the Crown’s duty to consult. Not one asks what happens if the model does not work. The questions are written so that only a municipality already inclined toward the model can answer them, and only in its favour.

The sixth question is the one that reveals the destination. Merging systems “with surrounding systems” is regional consolidation of municipal water and wastewater utilities. That is a far larger proposal than the notice describes, and it has not been consulted on.

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ERO 019-2487, Supporting Guide to Calculate the Design Sewage Flow for Subsurface Sewage Works Subject to Section 53 of the Ontario Water Resources Act, and ERO 026-0643: Replacing Table 5-3 in the Design Guidelines for Sewage Works (2008)

By Linda Heron on Tuesday, August 11th, 2026
Posted in Environmental Registry, Regulatory, River Concerns, Rivers at Risk, Waste Water Treatment Facilities, Fisheries, Environmental Compliance Approval, Sewage, Environmental Protection Act, Urban Development, Water Quality, Ontario Water Resources Act, Policy & Process

ORA submits this letter in response to both postings together, because they are one instrument. ERO 019-2487 proposes the draft Design Sewage Flow Guide (the Guide), and ERO 026-0643 proposes to revoke Table 5-3 of the Design Guidelines for Sewage Works, 2008, and replace it with Table 1 of that same Guide.1,2 Neither can be assessed without the other.

ORA supports a clear, modern, well-evidenced guide for large subsurface sewage disposal systems. Applicants deserve certainty, and the Ministry of the Environment, Conservation and Parks (the Ministry) deserves complete applications. Much of the draft Guide does useful work, particularly the design options for modular systems, flow balancing, alternating drainfields and reserve areas.

ORA does not support the proposal as drafted, for one central reason. The numbers that come down are prescriptive. The protections that would make lower numbers safe are advisory. A subsurface sewage system that is undersized does not fail quietly. It surfaces, and it reaches ditches, streams and rivers. The recommendations below are offered to correct that imbalance, and none of them should be read as support for the reduced values in Table 1.

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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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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 Thursday, May 14th, 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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ERO-026-0315: Upper Tier Official Plans, Secondary Plans, Upper Tier & Secondary Plans & Site- and Area-Specific Policies

By Linda Heron on Friday, April 24th, 2026
Posted in ORA Submissions, Environmental Registry, Regulatory Submissions, Municipal, Planning Act, Policy & Process, Provincial Policy Statement

“Consider This” by Storm Crypt is licensed under CC BY-NC-ND 2.0.

ORA’s interest in this consultation is direct. Official plans, secondary plans, and SASPs are the primary legal instruments through which municipalities protect river corridors, riparian buffers, floodplains, wetlands, and natural heritage systems from incompatible development. Changes to how those instruments are structured, what they may contain, and who approves them carry significant consequences for Ontario rivers and the communities that depend on them.

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ERO-019-9285 – Integrated Energy Resource Plan Consultation

By Linda Heron on Friday, December 13th, 2024
Posted in Competition Act - Greenwashing, ORA Submissions, Hydroelectric, Environmental Registry, Regulatory, River Concerns, Energy, Rivers at Risk, Clean Energy Credits, GHG Emissions, Invasive Species, Species at Risk, Water Quality, Policy & Process

The ORA is responding to the Ministry of Energy’s stakeholder outreach, seeking feedback to help inform Ontario’s first integrated energy resource plan. This government talks about the previous government’s hydro mess, but this is pure gaslighting because when it came into power, it cancelled approximately 750 “clean” energy projects, involving incalculable hours of government staff support and taxpayers’ dollars, and is now proposing to procure new “clean” energy projects to become an “energy superpower”.

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

By Linda Heron on Friday, September 27th, 2024
Posted in Long Term 2, IESO, ORA Submissions, Hydroelectric, Regulatory, River Concerns, Dams, Energy, Rivers at Risk, Regulatory Submissions, Policy & Process

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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