ERO 026-0670: Proposal to Update the Statement of Environmental Values for the Ministry of Energy and Mines

By Linda Heron on Thursday, August 6th, 2026

Posted in Sustainability, Biodiversity, Statement of Env. Values, Aquatic Life, Environmental Registry, Climate Change, River Concerns, Dams, Energy, Rivers at Risk, Government, Fisheries, Species at Risk, Water Quality

Vermilion River – Our grandchildren’s future with water!

ORA has reviewed the draft Statement of Environmental Values (SEV) for the Ministry of Energy and Mines (MEM) and the two statements it would replace. The Environmental Registry notice says the climate change content of the former statements has merged into the new document.¹ It has not merged. It has been cut. The draft removed the commitment to sustainable development, the commitment to reduce greenhouse gas emissions, the commitment to help Ontarians prepare for the impacts of climate change, and the commitment to engage with communities in their preferred language. It replaces the word evaluate with the word consider. And it never once mentions water.

This matters now more than at any point in the past thirty or more years. One ministry now sets Ontario’s energy priorities, directs what the province procures to meet them, and decides which mineral projects proceed. Both sides of that mandate run on water. Both change rivers. ORA’s position is that the largest single long-term risk to ratepayers, taxpayers, the climate and Ontario rivers is more hydroelectric development, followed closely by the mine waste that will be left behind. An SEV that does not mention water, rivers, fish or cumulative effects cannot manage either risk.

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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-026-0300: 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-026-0304: 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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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 – 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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IESO: Northern Hydro Program

By Linda Heron on Friday, February 6th, 2026

Posted in Sustainability, Biodiversity, IESO, Northern Hydro, ORA Submissions, Hydroelectric, Climate Change, River Concerns, Dams, Energy, Rivers at Risk, Fisheries, GHG Emissions, Regulatory Submissions, Species at Risk, Water Quality

Ontario ratepayers are already absorbing escalating costs from multiple electricity procurement programs. Locking in additional long-term hydro contracts without climate stress-testing will compound that burden and undermine public confidence in the electricity system.

The Northern Hydro Program is being advanced as a routine contract extension. In reality, it locks ratepayers into decades-long payment obligations for climate-vulnerable infrastructure, without contractual safeguards if freshwater availability declines and facilities cannot perform as assumed. At the same time, long-term demand forecasts have been significantly revised upward in a short period, and those inflated assumptions are now being used to justify cascading commitments across hydropower, nuclear, SMRs, and major transmission projects.

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IESO: East Lake Superior Regional Electricity Planning-11 December 2025

By Linda Heron on Wednesday, January 28th, 2026

Posted in Sustainability, Biodiversity, IESO, Regional EP, ORA Submissions, Hydroelectric, Aquatic Life, Regulatory, Climate Change, River Concerns, Dams, Energy, Rivers at Risk, Fisheries, Flooding, Regulatory Submissions, Species at Risk

Most critically, the options analysis remains disconnected from Ontario’s most authoritative climate risk evidence. The IESO relies on generalized “extreme weather methodology” references rather than the Ontario Climate Change Impact Assessment (OCCIA)[i], which provides region-specific projections for drought frequency, extreme precipitation, temperature volatility, and hydrological change — all of which directly affect transmission reliability and hydroelectric performance. This omission materially undermines confidence in both wire and non-wire option selection.

[i] Ontario Provincial Climate Change Impact Assessment, Technical Report, January 2023. Online: https://www.ontario.ca/files/2023-11/mecp-ontario-provincial-climate-change-impact-assessment-en-2023-11-21.pdf

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