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.

The post ERO-026-0414: Streamlining Requirements for Waste Disposal Site Service Area and Fill Rate Changes appeared first on Ontario Rivers Alliance.

ORA is particularly concerned that the proposal is being presented as a minor administrative amendment despite fundamentally altering the scale at which forest management planning may occur across Ontario. The proposed changes would permit multiple management units and multiple Sustainable Forest License holders to operate under a single forest management plan, effectively restructuring a planning framework that has historically relied on management units as the foundation for planning, reporting, auditing, consultation, and accountability. Such a significant change warrants a far more comprehensive review than has been provided through the current Environmental Registry posting.

The Environmental Bill of Rights exists to ensure informed public participation in environmental decision-making. Meaningful public participation depends upon the public being provided with sufficient information to understand a proposal, evaluate its implications, and provide informed comment. In the case of ERO 026-0109, the Ministry has proposed a significant structural change to Ontario’s forest management planning framework while providing only a brief Environmental Registry notice, a short planning manual addendum, and a one-page Forest Information Manual change table. In ORA’s view, this information is insufficient to support informed public review.

The post ERO 026-0109: Revisions to the Forest Manuals Regulated under the Crown Forest Sustainability Act appeared first on Ontario Rivers Alliance.

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).

The post Federal: Getting Major Projects Built in Canada: Discussion Paper on Regulatory Reform appeared first on Ontario Rivers Alliance.

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.

The post IAAC: Great Bear Gold Project – Impact Statement Summary, Registry No. 85832 appeared first on Ontario Rivers Alliance.

The IESO’s own planning documents are the appropriate starting point. The May 20, 2026, presentation states on slide 24: “A large share of supply resources in the area is hydroelectric, which is energy-limited and cannot be relied on at full output in all hours.”¹ Slide 30 states: “Hydroelectric supply resources are energy-limited and cannot be relied on to meet demand in all hours or conditions.” The planning engineer presenting the NOS plan confirmed verbally at the May 20 webinar that “These hydro facilities are largely river-based, so they have limited storage, meaning their output depends on water availability, so they cannot be relied on at all times.”

Against that backdrop, the Province’s April 9, 2025, media release describes the proposed Nine Mile Rapids and Grand Rapids generating stations, together up to 430 MW, as providing “affordable, reliable, and clean electricity” and “24/7 power for families and businesses,” and characterizes hydroelectricity as “a reliable source of emissions-free power.” ORA places both sets of statements on the formal planning and procurement record. The contradiction between what the IESO’s own planning staff have documented and what the Province and industry have announced to the public is not a minor discrepancy. It goes to the core of whether the plan’s generation assumptions are honest and forthright, and whether the long-term ratepayer commitments contemplated here rest on an accurate foundation.

The post IESO: North of Sudbury Bulk Planning Update appeared first on Ontario Rivers Alliance.

Within those parameters, the IESO’s conclusion was nonetheless unambiguous: “a non-emitting, hybrid resource portfolio, in theory, shows significant promise. It can provide both baseload and peak power with reasonably high, albeit imperfect, reliability, and potentially at costs that are competitive with gas and nuclear generation.” The hybrid resource portfolio option of wind, solar and battery storage is estimated to cost between $44 billion and $53 billion, with a build-out of 13,500 MW to 16,800 MW achieving 99.5 percent to 99.98 percent of the peak load served.

The post IESO: South and Central Bulk Planning Update Webinar-April 30, 2016 appeared first on Ontario Rivers Alliance.

ORA urges the Ministry to withdraw these proposed amendments. The three changes set out in Schedule 2 of Bill 105 would eliminate the mandatory Ministry Review of the proponent’s environmental assessment (EA) document; the right of any person to request an independent hearing before the Ontario Land Tribunal (OLT); and the requirement for Lieutenant Governor in Council approval of the Minister’s EA decisions. Taken together, these amendments would concentrate final environmental approval authority in a single political office, remove every public mechanism for seeking independent adjudication of EA decisions, and eliminate the only independent expert analytical check in the entire Comprehensive EA process.

The post ERO-026-0415: Proposed Amendments to the Environmental Assessment Act (Comprehensive Environmental Assessment Process), as proposed by Bill 105, Provincial Opportunity and Worker Empowerment Rights Act, 2026 appeared first on Ontario Rivers Alliance.

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.

The post 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) appeared first on Ontario Rivers Alliance.

These two positions are irreconcilable. ERO-026-0301 says water infrastructure must remain publicly owned. ERO-026-0302 states that municipalities must approve non-municipal water infrastructure, potentially privately owned and operated, on demand once prescribed criteria are met. A government that prohibits private ownership in one part of its water policy framework while mandating municipal approval of private systems in another is not following a coherent policy direction. It is advancing the incremental privatization of water and wastewater service delivery, one subdivision at a time, under a framework designed to make each individual approval appear routine.

ORA submits this letter to both contact addresses, the Intergovernmental Relations and Partnerships Branch for ERO-026-0302 and the Local Government Policy Branch for ERO-026-0301, precisely because the government’s fragmented consultation structure has ensured that neither branch is required to evaluate what the other has posted. These two offices are on the same floor of the same building in the same Ministry. The contradiction between their respective proposals is invisible to the process that is supposed to catch it. ORA is placing it before both branches simultaneously so that it cannot be evaluated in the absence of the other half of the picture.

The post ERO-026-0301 and ERO-026-0302: Proposed Amendments to the Municipal Act, 2001 and the Safe Drinking Water Act, 2002 Respecting Communal Drinking Water and Wastewater System Municipal Consent Requirements (Schedule 4 of Bill 98, the Building Homes and Improving Transportation Infrastructure Act, 2026) appeared first on Ontario Rivers Alliance.

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.

The post ERO-026-0304: Draft Projection Methodology Guideline (PMG), 2026 to Support Implementation of the Provincial Planning Statement, 2024 (Bill 98) appeared first on Ontario Rivers Alliance.