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ORA has made it clear that we are strongly opposed to this proposal and that it should be withdrawn.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 026-0427, 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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ERO-026-0414: Streamlining Requirements for Waste Disposal Site Service Area and Fill Rate Changes

By Linda Heron on Monday, June 8th, 2026

Posted in Sustainability, Drinking Water, ORA Submissions, Aquatic Life, Environmental Registry, Regulatory, River Concerns, Rivers at Risk, Government, Fisheries, Flooding, Land Use, Environmental Assessment Act, Species at Risk, Urban Development, Water Quality

ORA urges the Ministry to withdraw this proposal. ERO-026-0414 is not a red-tape reduction measure. It is the elimination of the only independent environmental assessment for a class of waste disposal decisions that can directly affect groundwater, contaminate rivers, damage aquatic ecosystems, and undermine the health and food security of rural and municipal communities, Indigenous peoples, and all communities living near waste-disposal sites. Posted as a companion to Bill 105’s simultaneous assault on the Comprehensive EA process (ERO-026-0415), it is part of a coordinated and accelerating dismantling of Ontario’s environmental protection framework, a withdrawal by the Province from its constitutional and moral obligation to hold Ontario’s natural environment in public trust for present and future generations.

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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-026-0312: 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-025-1334: A Renewed Ontario Invasive Species Strategic Plan

By Linda Heron on Saturday, February 21st, 2026

Posted in ORA Submissions, Environmental Registry, Climate Change, River Concerns, Fisheries, Invasive Species, Land Use, Species at Risk

Eurasian Milfoil

ORA appreciates the opportunity to comment on the Ministry of Natural Resources’ proposed renewed Ontario Invasive Species Strategic Plan (OISSP). ORA supports the objective of protecting Ontario’s biodiversity, fisheries, wetlands, and freshwater systems from invasive species. However, as drafted, the renewed plan risks weakening Ontario’s invasive species protection framework at a time when invasive risk is increasing due to climate change, expanding northern access corridors, and accelerated industrial development—not through explicit rollbacks, but through a structural shift away from enforceable prevention and rapid response measures and toward “shared responsibility,” knowledge-sharing, and resilience language without binding commitments, implementation timelines, or resourcing.[i]

[i] Draft Renewed Ontario Invasive Species Strategic Plan (OISSP), October 2025 (Discussion Paper and Draft Plan).

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ERO-025-1078: Natural Resources Regulatory and Permit Reform Initiative: Proposing changes to streamline certain approvals under the Public Lands Act

By Linda Heron on Sunday, December 21st, 2025

Posted in Crown Land Use Policy, ORA Submissions, Hydroelectric, Environmental Registry, Regulatory, Climate Change, River Concerns, Dams, Energy, Rivers at Risk, GHG Emissions, Land Use, Public Lands Act, Renewable Energy on Crown Land

Photo by Mark Clement

This two-step approach shifts risk away from proponents and onto Ontario’s rivers, Indigenous Nations, and the public interest—at precisely the moment when climate change, flooding, and freshwater ecosystem decline demand stronger, not weaker, precaution. By exempting early disturbances, narrowing shore-land protections, and relying on registration rather than site-specific authorization, the Province is effectively pre-approving development pathways before their ecological and social consequences are understood.

Ontario’s rivers and Crown lands are not expendable staging grounds for an unexamined “energy superpower” agenda. They are public trust resources and critical climate-resilience infrastructure. ORA therefore urges the Ministry to withdraw ERO-025-1078, reassess it jointly with ERO-025-1145, and re-establish a regulatory framework grounded in contemporary freshwater science, Indigenous rights, and the precautionary principle.

Subsequent Ministry correspondence dated November 6, 2025, confirms that ERO-025-1145 and ERO-025-1078 form part of a single, coordinated initiative to streamline Crown land and in-water approvals, reinforcing ORA’s concern that these proposals must be assessed together for their cumulative ecological and governance impacts.

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ERO-025-1134: Natural Resources Regulatory and Permit Reform Initiative: Improving forest legislation, regulations, processes and forest management policy

By Linda Heron on Sunday, December 21st, 2025

Posted in Sustainability, Crown Land Use Policy, ORA Submissions, Hydroelectric, Environmental Registry, Regulatory, Climate Change, River Concerns, Dams, Rivers at Risk, Fisheries, Forestry, GHG Emissions, Land Use, Water Quality, Public Lands Act, Renewable Energy on Crown Land

ERO-025-1134 does not represent neutral modernization of forest policy. When combined with concurrent Crown land, Public Lands Act, and economic reforms, it forms part of a coordinated deregulation agenda that will predictably intensify pressure on Ontario’s rivers through expanded hydropower and associated infrastructure. Weakening forest oversight at a time of accelerating climate change, cumulative watershed stress, and public-safety risk is neither precautionary nor responsible. ORA urges the Province to halt this trajectory and restore a science-based, integrated approach to forest, land, and river stewardship that protects Ontario’s natural heritage for present and future generations.

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ERO-025-0872 – Streamlining environmental permissions for sewage works servicing on-farm worker housing

By Linda Heron on Sunday, December 7th, 2025

Posted in Sustainability, ORA Submissions, Septic Systems, Environmental Registry, Regulatory, River Concerns, Clean Water Act, Land Use, Environmental Compliance Approval, Urban Development, Sewage

The magnitude of these systems alone makes this proposal indefensible. Both documents confirm that sewage works with a total capacity of up to 50,000 litres per day and individual systems with a capacity up to 25,000 litres per day may be installed and operated without an Environmental Compliance Approval.^1,2 These volumes are not small or low-risk; they are equivalent to communal wastewater treatment systems serving dozens of households. Systems of this scale require careful plume modelling, nitrate-loading calculations, groundwater mounding analysis, assessment of down-gradient receptors, and long-term effluent criteria development—work that must be independently scrutinized to ensure protection of human health and drinking water sources. Allowing these systems to operate without MECP review creates an unacceptable risk of contaminant migration into shallow aquifers, private wells, and baseflow that sustains rivers and coldwater ecosystems.

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