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 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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IESO: Changes to the Establishment and Publication of Market Parameters – June 18, 2026

By Linda Heron on Tuesday, June 30th, 2026

Posted in Sustainability, IESO, Alternatives, ORA Submissions, Hydroelectric, River Concerns, Energy, Rivers at Risk, Industry, Fisheries, GHG Emissions, Water Quality

ORA’s concern is heightened by the growing influence of directives from the Minister of Energy and Mines over IESO preferences that are backed by data or studies. The April 16, 2026, Ministerial Directive instructed the IESO to procure new long lead-time hydroelectric generation, even as the Directive acknowledged that these resources are “deemed not well-suited to competing against resources with shorter development timelines and lifespans (e.g., wind, solar and inverter-based battery energy storage systems).” That instruction overrode the IESO’s own August 2025 Hybrid Resource Equivalency Assessment, which found that wind, solar, and battery energy storage systems (BESS) could serve 99.5 to 99.98 percent of load in the Peaky Need Scenario. When political direction can displace the IESO’s own expert analysis, on-the-record, Board-governed control of market parameters is not a formality. It is the safeguard that keeps ratepayer-facing decisions independent, accountable, and aligned with the public interest rather than a shifting political agenda.

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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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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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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-026-0313: 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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