Ontario’s latest energy RFP acknowledges Indigenous inclusion but stops short of sharing power
Ontario’s latest long-term electricity procurement plan, LT2 (e-1) Request for Proposals, marks another step in the province’s effort to secure energy supply from new generation projects.
It arrives in a moment when governments and industry regularly invoke reconciliation and Indigenous partnership in the language of infrastructure. But for those looking closely at the mechanics of these energy processes, important questions remain about who actually holds decision-making power, and whether Indigenous inclusion is a goal or a checkbox.
A review of the LT2 RFP from an Indigenous policy perspective raises several concerns. While the document makes space for Indigenous participation, it does not embed Indigenous governance, legal rights, or land stewardship principles into the structure of the process itself. The result is a framework that reflects modest inclusion within a Western energy paradigm—not co-development on Indigenous terms.
Inclusion Without Authority
The RFP encourages early engagement with Indigenous communities and requires documentation of support when projects intersect with Indigenous land or treaty territory. These are standard features in many current procurement documents. However, Indigenous governments are not involved in project selection, contract awarding, or any part of the oversight process. There is no co-governance body, no advisory council, and no structural commitment to nation-to-nation collaboration.
Environmental Considerations Fall Short
The document contains basic environmental constraints, such as avoiding specialty crop lands. But it does not reflect Indigenous land values. There is no mention of traditional ecological knowledge, cumulative impacts, or cultural site protection. Environmental review is described in terms of permitting and municipal requirements. This is a technical approach, not one informed by Indigenous knowledge systems or obligations to future generations.
Economic Participation is Transactional
The RFP awards points for Indigenous equity participation. It also includes a clause voiding contracts if that ownership falls below a threshold in the first five years. These provisions are stronger than some past practices. However, they are still limited in duration and intent. The structure does not prioritize Indigenous-led projects. Instead, it encourages Indigenous communities to act as junior partners in externally driven developments. There is no long-term pathway to ownership, control, or self-determined energy planning.
Consent and Rights Are Not Central
The RFP does not include any reference to Free, Prior and Informed Consent (FPIC), despite Canada’s commitment to the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP). Engagement is directed by proponents, not communities. The framework assumes the legitimacy of project development, rather than building consent through mutual agreement. There is also no mention of outstanding land claims, treaty enforcement, or Indigenous legal orders. Treaties are acknowledged only in passing and only when proponents choose to reference them for scoring purposes.
A Missed Opportunity
The LT2 RFP shows that Indigenous participation is increasingly expected—but it remains conditional, limited, and non-binding. The opportunity exists to design procurement processes that reflect Indigenous governance, protect lands and waters beyond regulatory minimums, and require full consent from affected Nations. This RFP does not meet that standard.
If Ontario is serious about Indigenous leadership in energy, it must move beyond incentives and consultations. It must embed Indigenous law, land stewardship, and governance into the rules that shape how energy is planned, built, and owned in this province.