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

By Linda Heron on Monday, August 31st, 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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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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IESO: Regional Electricity Planning in the Northwest Region – June 11, 2026

By Linda Heron on Wednesday, July 1st, 2026

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

During the June 11 webinar, ORA asked why wind, solar, and battery energy storage systems (BESS) could not supply some remote communities directly, rather than waiting on long transmission builds, when those resources are cheaper, cleaner, and faster to deploy. The IESO answered that this is “exactly the kind of options and considerations this planning process is meant to consider,” and confirmed that such supply resources “can certainly be done in a shorter timeframe” and “are a key aspect to helping address some of those more near-term needs” for remote communities.¹ ORA welcomes that answer and writes to ensure it is carried into the demand forecast, the scenarios, and the plan that follows.

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ERO-026-0364: Proposed Amendment to Ontario Regulation 316/07 to Remove Selected Lands from Beekahncheekahmeeng Deebahncheekayweehn Eenahohnahnuhn in Support of Pikangikum First Nation

By Linda Heron on Thursday, May 14th, 2026

Posted in Crown Land Use Policy, ORA Submissions, Environmental Registry, First Nations Treaty Rights, Public Lands Act

ORA’s support is grounded in two considerations. First, this proposal fulfills a provincial commitment made in 1968, more than fifty years ago, to increase the size of Pikangikum First Nation’s reserve. Pikangikum First Nation requested this addition by Band Council Resolution to address the community’s immediate housing and infrastructure needs. With a current on-reserve population of over 3,800 people, projected to reach up to 6,000 by 2038, and over 95% of the membership living on reserve, the need for additional land is both legitimate and urgent. Honouring this longstanding commitment is a matter of basic fairness and substantive reconciliation.

Second, ORA notes that Pikangikum First Nation has identified the 17-hectare parcel as a cultural waterway. ORA’s mission centers on the protection of river and waterway ecosystems as public trust assets sustaining ecological, cultural, and community well-being. The cultural waterway designation signals that these lands carry significance beyond their small geographic footprint within the broader 96,085-hectare park. ORA encourages Ontario and Canada to ensure that stewardship of these lands, once transferred, is guided by Pikangikum’s own knowledge of their cultural and ecological values, consistent with Pikangikum’s longstanding role as co-stewards of the “Keeping the Land” (Community-Based Land Use Plan), developed and approved jointly by Pikangikum and Ontario in 2006.

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IESO: ORA Comments on Long Lead-Time RFP Engagement on April 23, 2026

By Linda Heron on Thursday, April 30th, 2026

The LLT RFP, as currently structured, does not protect Ontario rivers, ratepayers or taxpayers, and is not in the public interest. It creates a hydro-only energy stream, offers 40-year revenue certainty to proponents, advances long-lead water-dependent infrastructure with a 100-year lifespan, without visible integration of Ontario’s own climate science, and responds to industry pressure for greater investor protection while leaving the public to bear long-term environmental and financial risk.

Ontario does not need to sacrifice rivers to meet electricity needs. IESO’s own modelling shows that wind, solar and battery storage portfolios can meet future needs with very high reliability. The responsible course is to prioritize lower-impact, faster-deploying, scalable resources, protect existing rivers, and ensure that any long-term procurement is grounded in climate science, cumulative effects assessment, and transparent ratepayer accountability.

Ontario should not lock households, businesses, and future generations into decades of avoidable financial and environmental liability for a climate-vulnerable energy source when lower-impact, scalable, increasingly cost-effective, and climate-resilient alternatives already exist.

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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

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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.

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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.

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ERO-025-1367: Amending the Renewable Energy Approval regulation to remove certain project types from the process and streamline the review of Natural Heritage Assessments

By Linda Heron on Sunday, January 18th, 2026

Posted in Renewable Energy Approvals, Hydroelectric, Regulatory, Climate Change, River Concerns, Dams, Energy, Regulatory Submissions, Environmental Protection Act, Renewable Energy on Crown Land

Photo by Ken Bennison – Vermilion River

ORA submits that this posting cannot be assessed in isolation. It is part of a coordinated deregulatory package advanced through multiple ERO postings under the Natural Resources Regulatory and Permit Reform Initiative, designed to accelerate renewable energy approvals while dismantling independent Crown oversight. In particular, ERO-025-1367 proposes to amend Ontario Regulation 359/09 to remove Ministry of Natural Resources review/confirmation of Natural Heritage Assessments and Bird/Bat monitoring plans and replace it with proponent attestation by “qualified persons.” This model, combined with the related technical guidance changes proposed under ERO-025-1146, represents a structural shift in environmental governance: Ontario is replacing independent verification with proponent-paid assurances.

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ERO-025-1145: Natural Resources Regulatory and Permit Reform Initiative: Proposing changes to the Renewable Energy on Crown Land policy

By Linda Heron on Sunday, December 21st, 2025

Posted in Competition Act - Greenwashing, Crown Land Use Policy, ORA Submissions, Hydroelectric, Heavy Metal Contamination, Environmental Registry, Regulatory, Climate Change, River Concerns, Dams, Rivers at Risk, Fisheries, Environmental Assessment Act, Water Quality, Public Lands Act, Renewable Energy on Crown Land

ERO-025-1145 does not represent prudent regulatory reform. It represents a deliberate policy choice to subordinate Ontario’s rivers, climate commitments, and public-interest safeguards to an unmandated “energy superpower” agenda built on outdated assumptions about hydropower. By ignoring Ontario’s own Climate Change Impact Assessment, greenwashing hydropower, downplaying methane emissions, dismissing cumulative effects, and failing to require decommissioning, fish passage, and financial security, the proposed amendments expose the Province to long-term ecological, legal, and financial risk.

Free-flowing rivers are among Ontario’s most valuable and climate-resilience assets. Once fragmented, flooded, or abandoned, they cannot be easily or cheaply restored. ORA urges the Ministry to withdraw these amendments, re-ground Crown land policy in contemporary science and Indigenous rights and reject the false premise that new hydropower—particularly under the 10-MW scale—is compatible with climate responsibility or watershed protection.

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