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Category Archives: Watershed Planning

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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IAAC: Great Bear Gold Project – Impact Statement Summary, Registry No. 85832

By Linda Heron on Friday, May 29th, 2026
Posted in IAAC, ORA Submissions, Regulatory, River Concerns, Rivers at Risk, Industry, Fisheries, GHG Emissions, Mining, Species at Risk, Water Quality, Watershed Planning, Impact Assessment Act

Great Bear Gold Project proposed site development.

ORA wishes to express its strong support and alignment with the submissions and recommendations of CELA on behalf of ANA/Grassy Narrows First Nation.

The Ontario Land Tribunal’s (OLT) engagement with this project reinforces these concerns and bears directly on the adequacy of the Crown consultation record. In 2025, the OLT granted ANA leave to appeal water-taking permits issued by the Province of Ontario to Kinross, finding that “no reasonable person” would have issued those permits in light of ANA’s documented mercury concerns. Kinross subsequently withdrew the permit application before the appeal could be heard. A new permit application was filed; on May 7, 2026, ANA filed a new application for leave to appeal the new permits, again on the grounds that sulphate discharge will drive mercury methylation in the Chukuni-English River system and produce elevated methylmercury concentrations in fish consumed by community members downstream.

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Laurentian River–A Highly Valued Aquifer at Risk in High Park, Toronto

By Linda Heron on Thursday, November 20th, 2025
Posted in ORA Submissions, River Concerns, Rivers at Risk, Government, Land Use, Urban Development, Watershed Planning, Municipal, Planning Act

The Ministry of the Environment, Conservation and Parks confirms that this location lies within a Highly Vulnerable Aquifer (HVA)—one of the most sensitive groundwater zones recognized under Ontario’s source protection framework. HVAs are explicitly protected because disturbance, dewatering, excavation, and large-scale impermeable development can alter groundwater flow, create contamination pathways, and permanently destabilize subsurface hydrology.

The developer’s own geotechnical consultants repeated multiple times that “further investigation is required” regarding groundwater conditions. When a proponent cannot establish foundational geotechnical certainty on an HVA, the City must halt the process rather than gamble with groundwater systems that sustain High Park, its creeks, wetlands, and ecological communities.

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Feedback on the IESO Resource Adequacy and Long-Term 2 RFP Engagement

By Linda Heron on Monday, January 15th, 2024
Posted in Long Term 2, IESO, ORA Submissions, Hydroelectric, Regulatory, River Concerns, Energy, Rivers at Risk, Industry, Fisheries, GHG Emissions, Species at Risk, Water Quality, Watershed Planning, Green Energy Act

The ORA is offering feedback on the 13 December 2023 Independent Electricity System Operator (IESO) webinar. ORA strongly objects to new hydroelectric being included as a “non-emitting” resource, eligible for the Long Term 2 (LT2) Request For Proposals (RFP). Participants were informed of an overall need for 5 TWH of energy emerging at the end of the decade and growing through the 2030s. The LT2 RFP has an anticipated installed capacity target of around 2,000 MW of non-emitting energy resources to be procured and operational by 2030.  ORA questions the IESO’s rationale for applying the non-emitting label to hydroelectric when there are numerous independent third-party peer-reviewed studies, as well as the Intergovernmental Panel on Climate Change (IPCC) reporting guidelines. This immense volume of studies indicate that hydropower reservoirs generate significant and ongoing greenhouse gas (GHG) emissions, especially methane, for the full life cycle of the dam. It is misleading the public to claim that hydroelectric is “non-emitting” in the LT2 RFP or in any other public arenas and could be considered fraudulent.

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ERO-019-6951, 6963, 6928 & 6853 – Proposed Streamlining to Permit-by-Rule, Waste Management, Stormwater Management and Site Dewatering Activities – ORA Support

By Linda Heron on Monday, October 30th, 2023
Posted in Regulatory, Stormwater, River Concerns, Rivers at Risk, Waste Water Treatment Facilities, Joint, Land Use, Mining, Quarries, Environmental Bill of Rights, Environmental Compliance Approval, Sewage, Species at Risk, Urban Development, Water Quality, Watershed Planning, Ontario Water Resources Act, Policy & Process, Provincial Policy Statement

Canadian Environmental Law Association (CELA) has prepared the following analysis and recommendations in response to the four above-noted Environmental Registry of Ontario (ERO) notices, which propose dramatic changes to Ontario’s permit-by-rule framework. The undersigned environmental, conservation, and civil society organizations have endorsed CELA’s submission. Collectively, it is strongly recommended that the Ministry of Environment, Conservation and Parks not move ahead with the four proposals…

We are willing to meet and discuss CELA’s submission at your convenience.

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ERO-019-6141 – Legislative & Regulatory proposals affecting Conservation Authorities

By Linda Heron on Thursday, November 24th, 2022
Posted in MZOs, Bill 23, ORA Submissions, Environmental Registry, River Concerns, Rivers at Risk, Industry, Conservation Authorities Act, Regulatory Submissions, Endangered Species Act, Species at Risk, Urban Development, Water Quality, Watershed Planning, Municipal, Ontario Water Resources Act, Planning Act, Provincial Policy Statement

“Consider This” by Storm Crypt is licensed under CC BY-NC-ND 2.0.

The Ontario government’s own 2020 report, “Protecting People and Property: Ontario’s Flooding Strategy,” which resulted from the 2019 flooding disaster, states very clearly that “Flood risk management is achieved through multiple provincial acts, regulations, policies and technical guides and a wide range of provincial programs and services. Successful implementation relies on partnerships between provincial ministries, municipalities, Indigenous communities, conservation authorities, stakeholder organizations and the federal government.” 1

Instead, this proposal seeks to do the very opposite. It proposes to exempt the CAs from their authority under ten crucial Acts and their associated regulations; it blocks the CA partnership with municipalities and stakeholders and takes the authority of CAs away from permitting so they cannot properly fulfill the recommendations of this report that was commissioned by the Ontario government only a few short years ago.  Now, where is the wisdom in that?

[1] Protecting People and Property: Ontario’s Flooding Strategy, 10 March 2020. P-7/42

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Bill 23 – ORA Comments to the Standing Committee on Heritage Infrastructure and Cultural Policy

By Linda Heron on Thursday, November 17th, 2022
Posted in MZOs, Bill 23, ORA Submissions, Pollution, Bills, Environmental Registry, Regulatory, River Concerns, Rivers at Risk, Conservation Authorities Act, Species at Risk, Water Quality, Watershed Planning, Municipal, Ontario Water Resources Act, Planning Act, Provincial Policy Statement

Vermilion River – Our grandchildren’s future with water!

The ORA is concerned that Bill 23 will have far-reaching negative effects on the environment and communities. This major streamlining of development is irresponsible and a recipe for disaster. Bill 23 works against sustainability and the watershed approach at a time when Government decision-making should be focused on protecting the environment and building climate resilience into Ontario’s communities and infrastructure.

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ERO 019-4971 – Draft Low Impact Development Stormwater Management Manual

By Linda Heron on Wednesday, April 27th, 2022
Posted in ORA Submissions, Environmental Registry, Climate Change, Stormwater, River Concerns, Rivers at Risk, Waste Water Treatment Facilities, Sewage, Environmental Protection Act, Urban Development, Water Quality, Watershed Planning, Ontario Water Resources Act, Planning Act

Blue Heron in Waterloo, Ontario, by Leslie Bamford

The ORA is in full agreement that Low Impact Development (LID) must be a priority in development planning guidance for stormwater management practices and should include innovative green infrastructure such as rain harvesting, rain gardens, green roofs, urban trees and forests, permeable surfaces, ditches, swales, stormwater catchments, and must emphasize the protection of wetlands.

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ERO-019-4967 – Municipal Wastewater and Stormwater Management in Ontario – Discussion Paper

By Linda Heron on Monday, March 28th, 2022
Posted in ORA Submissions, Environmental Registry, Stormwater, River Concerns, Rivers at Risk, Waste Water Treatment Facilities, Sewage, Watershed Planning

The province should not be streamlining reporting requirements. Wastewater and stormwater management are vitally important to the health and resilience of our freshwater resources and to the people of Ontario. There are numerous complex and site specific considerations for each and every outfall of sewage effluent that is unique to the area and the water body. We cannot continue to release partially treated or untreated sewage into our lakes and rivers. We must stop thinking about how we can make it easier and start thinking about how we can make wastewater treatment more efficient and effective so we can build resilience into our lakes and rivers to help prepare for a warming climate. 

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