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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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: Long Lead-Time RFP: Questions and Comments

By Linda Heron on Friday, July 10th, 2026

Posted in Long Lead-Time, IESO, ORA Submissions, Hydroelectric, Aquatic Life, Climate Change, River Concerns, Dams, Energy, Rivers at Risk, Industry, Class EA for Waterpower, GHG Emissions, Water Quality, Watershed Planning

The hydro-only energy stream is not reconciled with the IESO’s own August 2025 modelling.

The LLT energy stream is restricted to new hydroelectric resources, yet the IESO’s own August 2025 Hybrid Resource Portfolio Equivalency Assessment found that wind/solar/BESS portfolios served 99.5%–99.98% of the peaky-need scenario and 99.7%–99.9% of the baseload-need scenario, and that a gas + wind/solar/BESS portfolio served 100% of load at a lower net present value than the gas-only option in seven of ten weather years. The IESO has not publicly reconciled that modelling with a decision to create an exclusive 40-year procurement lane for new hydro, together with the new transmission required to connect those projects to the grid. Citing the Directive does not discharge the IESO’s public-interest obligation to show that new hydro is necessary, least-cost and superior to lower-risk alternatives.

Nor has the IESO published any comparable analysis testing new hydro against wind, solar and BESS portfolios; the reconciliation gap is therefore wider, not narrower.

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IESO: Regional Electricity Planning in the Northwest Region – June 11, 2026

By Linda Heron on Wednesday, July 1st, 2026

Posted in Transmission, IESO, IRRP, Alternatives, ORA Submissions, Hydroelectric, Climate Change, River Concerns, Dams, Energy, Rivers at Risk, GHG Emissions

The IRRP is the planning vehicle that is meant to consider a broad range of options, including non-wires alternatives. ORA asks the IESO to hold to that purpose in the Northwest. Several large transmission builds are already underway or contemplated for the region: the $1.2 billion dollar Waasigan line, in service between 2026 and 2027,² the Red Lake line north of Dryden, a 230 kV double-circuit build that nearly quadruples the area’s capacity, roughly 400 MW, and is expected in the early 2030s, a planned 230 kV line toward the Greenstone area, and the recently completed East-West Tie at about $777 million. The IESO has not published a cost estimate for the Red Lake line, though it almost certainly holds one; CBC reports it at $830 million. For scale, the province’s new Barrie-to-Sudbury bulk line is estimated at $1.4 to $1.6 billion. These are multi-billion-dollar commitments. A wind, solar, and battery storage package sized to a remote community’s need costs a fraction of a long transmission build and can be deployed far sooner, so communities are not left waiting years for power that a local resource could deliver.

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ERO 026-0427, Fortifying Ontario’s Economy: A vision for protecting Ontario, strengthening economic sovereignty, and securing global leadership in critical minerals.

By Linda Heron on Tuesday, June 16th, 2026

A Vermilion River Otter, By Al Oman

A strategy that halves review time, proposes permit-by-rule, ignores its own climate science, weakens species law, short-changes public and Indigenous consultation, commits to century-long methane-emitting reservoir infrastructure over its own innovative and green alternatives, and treats Indigenous consent as an equity transaction, is not protecting Ontario’s economy. It is mortgaging Ontario’s watersheds, its climate resilience, and its relationships with First Nations against a demand the public was never asked to approve. It does all of this to fast-track projects, while the courts are still being asked whether the very laws that enable it are constitutional.

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North Shore Link Project (Mississagi TS to Third Line TS) Draft Environmental Study Report

By Linda Heron on Thursday, June 11th, 2026

Posted in Electricity Act, Ontario Energy Board Act, Transmission, IESO, Bulk Planning, ORA Submissions, Climate Change, River Concerns, Energy, Rivers at Risk, Government, Fisheries, Environmental Assessment Act, Mining, Species at Risk

The Project is being advanced as a designated “priority project”, and that designation matters. Under the Ontario Energy Board Act, 1998, the Ontario Energy Board (OEB) grants leave to construct a transmission line only if the work is in the public interest, but the OEB may, by law, consider only a narrow public interest: the interests of consumers with respect to the price, reliability, and quality of electricity service. The OEB does not weigh environmental effects, which are left to the Class Environmental Assessment for Transmission Facilities (2024) (Class EA), and because the provincial government has declared this Project a “priority project”, the OEB must accept that the Project is needed; it does not test need at all. The Class EA gives the public no ability to request that the decision be elevated to a Comprehensive Environmental Assessment, and the comments received during this 30-day window are reviewed and resolved by the proponent, Hydro One Networks Inc. The result is that no independent body weighs whether this line, on this route, at this cost, and with these environmental effects, is the right choice for the public, while ratepayers and taxpayers carry the full and long-term cost.

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IAAC: Crawford Nickel Project, Draft Impact Assessment Report, IAAC Registry No. 83857

By Linda Heron on Wednesday, June 10th, 2026

Posted in Carbon Capture, ORA Submissions, Heavy Metal Contamination, Lake Sturgeon, Climate Change, River Concerns, Rivers at Risk, Government, Fisheries, GHG Emissions, Mining, Species at Risk, Water Quality, Impact Assessment Act

Photo by Dennis Jarvis.

The Crawford Nickel Project is one of the largest proposed mines in Canadian history. Its receiving waters, the North Driftwood, the West Buskegau, and the Jocko Rivers, are not industrial corridors. They are living rivers in Treaty 9 territory, supporting fish, birds, boreal caribou, and the harvesting rights, food security, and cultural continuity of nations that have depended on them since time before memory. The federal government’s own analysis values Canada’s ecosystem services at $3.6 trillion. A “low to moderate” economic contribution from a project with admitted significant adverse effects on fish, birds, and Indigenous rights, whose climate contribution is undemonstrated and whose consultation record is incomplete, does not clear that bar.

ORA calls on the Minister to withhold approval until the consultation record is complete, FPIC from AAN has been obtained or the legal consequences of its absence fully adjudicated, the fish habitat offsetting plan is finalized and publicly reviewed, the mercury methylation risk and the predicted seepage-face exceedances are resolved by precautionary conditions and best available treatment to background rather than post-hoc monitoring, tailings dam safety is brought to the Global Industry Standard on Tailings Management, climate change is incorporated into the cumulative effects analysis, and the ecosystem services value of what will be destroyed is honestly weighed against the economic value of what will be gained.

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Federal: Getting Major Projects Built in Canada: Discussion Paper on Regulatory Reform

By Linda Heron on Thursday, June 4th, 2026

Posted in Sustainability, ORA Submissions, Hydroelectric, Aquatic Life, Regulatory, Climate Change, River Concerns, Energy, Rivers at Risk, Government, Regulatory Submissions, Species at Risk, First Nations Treaty Rights, Water Quality, Impact Assessment Act, Mercury

Abitibi River – Twin Falls GS

The Discussion Paper frames delays as a process problem caused by excessive oversight and public consultation considerations that delay projects by more than five years before federal decisions are made and construction begins. The evidence from ORA’s direct experience tells a different story: current delays are driven primarily by proponents who extend their own timelines while development activity proceeds on the ground, and by assessments that defer rather than decide on the most difficult questions. Reducing or eliminating public consultation will not fix these structural failures. It will make them worse, and the costs will be borne by communities, by First Nations, and ultimately by the federal government in litigation.

ORA supports a well-resourced, efficient, and credible impact assessment system, and supports reforms that fix the real bottlenecks: underfunded review staff, incomplete Crown consultation, and weak post-approval enforcement. ORA opposes the proposals that would cut public and Indigenous participation, exempt whole categories of projects from independent review, or allow construction to begin before a decision is made.

The Prime Minister promised, in the 2025 Speech from the Throne, that decisions on major projects would be made within two years. The Discussion Paper now proposes one. ORA asks the Government to hold the Prime Minister to that two-year commitment, and to withdraw the following proposals outright: early construction before a decision (Proposal 6.5); the Cabinet power to exempt projects from the species-at-risk jeopardy test (Proposal 6.8); Federal Economic Zones (Proposal 5); the removal of independent impact assessment for pipelines and transmission lines (Proposal 4); the transfer of nuclear and uranium assessments to the industry’s own regulator (Proposal 4); and the new ministerial powers to weaken environmental conditions after approval (Proposals 6.6 and 6.7).

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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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