Photo by Ken Bennison – Vermilion River
ORA submits that this posting cannot be assessed in isolation. It is part of a coordinated deregulatory package advanced through multiple ERO postings under the Natural Resources Regulatory and Permit Reform Initiative, designed to accelerate renewable energy approvals while dismantling independent Crown oversight. In particular, ERO-025-1367 proposes to amend Ontario Regulation 359/09 to remove Ministry of Natural Resources review/confirmation of Natural Heritage Assessments and Bird/Bat monitoring plans and replace it with proponent attestation by “qualified persons.” This model, combined with the related technical guidance changes proposed under ERO-025-1146, represents a structural shift in environmental governance: Ontario is replacing independent verification with proponent-paid assurances.