Bill 27 recasts Ontario’s Forest Fires Prevention Act as the Wildland Fire Management Act, broadens definitions to cover a wider range of outdoor fires and wildland areas, creates new categories of officers with expanded entry, inspection and enforcement powers, requires municipal and prescribed entities to prepare wildland fire management plans, and authorizes remediation orders and administrative penalties.
The bill also enacts the Geologic Carbon Storage Act, 2025, which establishes a licence/permit regime for research, evaluation and long‑term underground carbon storage, sets out rules for pore space ownership and the Crown’s ability to vest and authorize public pore space, provides routes for unitization and tribunal oversight, creates a Carbon Storage Stewardship Fund, and defines mechanisms for closure certificates that can transfer rights and liabilities to the Crown. Together these changes create new operational, regulatory and financial obligations for municipalities, resource operators, landowners and Indigenous communities.
At a Glance
What It Does
The Act (Schedule 1) renames and modernizes the wildfire statute: it defines 'wildland area' and 'wildland fire', creates four officer classes with specified inspection, entry and enforcement powers, makes fire permits and restricted fire zones central tools, and introduces remediation orders and administrative penalties. Schedule 2 establishes a stand‑alone Geologic Carbon Storage Act that prohibits carbon‑storage activities without licences or permits, sets out pore‑space ownership rules and Crown vesting, authorizes tribunal and Ontario Energy Board referrals, and provides for closure certificates and a stewardship fund.
Who It Affects
Municipalities and any prescribed entities operating in fire regions must prepare and update wildland fire management plans and may face remediation or administrative penalties. Energy companies, storage project proponents, owners of surface rights (including landholders above pore space), the Ontario Land Tribunal, the Ontario Energy Board and the Ministry of Natural Resources are directly affected by the carbon storage regime. Surveyors and conservation/police officers gain new roles and authorities under the amended Acts.
Why It Matters
The package enables province‑level decision‑making for both emergency wildland fire responses and the deployment of geologic carbon storage at scale. It centralizes permitting and enforcement, creates a mechanism for taking and authorizing use of pore space, and builds a financial backstop for post‑closure liabilities — all of which materially change how land rights, risk allocation and regulatory oversight operate for developers, affected landowners and the Crown.
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What This Bill Actually Does
Schedule 1 renames the old Forest Fires Prevention Act to the Wildland Fire Management Act and substantially rewrites it. The definitions now capture a broad set of outdoor fires and habitats, and the Minister can appoint or designate four types of officers (wildland fire officer, compliance officer, investigator and enforcement officer).
Those officers receive explicit entry and inspection powers (including access to and limited seizure of computers and records), authority to stop conveyances, to temporarily close sites for investigation, to summon assistance and privately‑owned equipment in emergencies, and to obtain warrants for dwelling entries. The Act also clarifies ministerial orders such as declaring fire seasons, designating restricted fire zones and declaring wildland fire emergency areas, and allows permits both for outdoor fires and for activities that would otherwise be prohibited in emergency areas.
The wildfire regime adds compliance mechanisms that go beyond criminal charges. The Minister and prescribed officials may issue remediation orders requiring specific remedial activity and timelines; recipients have 30 days to request a review and the review stays enforcement.
The Act also introduces administrative penalties that can be imposed in writing, are payable within 30 days unless stayed by a review, and can be filed in the Superior Court if unpaid. Courts keep broad remedial powers on conviction, including orders to remedy harm, pay Crown costs and bar future permits.
The Act also disclaims a private‑law duty of care by the Minister in respect of certain orders and agreements, shifting litigation risks away from the Crown for many operational decisions.Schedule 2 establishes the Geologic Carbon Storage Act, a comprehensive regime for research, testing and permanent underground storage of CO2. The framework defines research and evaluation activities versus carbon storage activities; both are prohibited unless performed in prescribed areas and under a research/ storage permit or licence.
The Act treats pore space as part of the surface rights estate by default but gives the Lieutenant Governor in Council the power, via regulation, to take and vest specified pore‑space rights in the Crown and to require authorization holders to pay compensation as prescribed. The Minister issues licences for Crown lands and permits for operational activities, subject to completeness, consultation (including with Indigenous communities where rights may be affected), municipal endorsement requirements for storage permits and mandatory or discretionary referrals to the Ontario Energy Board and the Ontario Land Tribunal for technical or contested matters.Operationally, the Act builds a lifecycle for carbon storage sites: permit and licence issuance; unitization orders (Tribunal can join pore rights and apportion costs/benefits); ongoing monitoring, insurance and recordkeeping obligations; inspector and enforcement officer powers to order remediation, decommission wells, affix tags and require deactivation; and closure procedures culminating in a closure certificate.
A closure certificate, once issued, can transfer specific rights, duties and obligations and ownership of wells and ancillary works to the Crown (subject to regulations and exceptions); the Crown may assume such responsibilities earlier in prescribed circumstances (e.g., permit holder incapacity). The Carbon Storage Stewardship Fund requires payments from authorization holders and may be used to fund Crown expenses or liabilities arising from assumed closure obligations.
The Act contains broad regulation‑making authority and transitional provisions and amends the Oil, Gas and Salt Resources Act and other statutes to ensure consistency.
The Five Things You Need to Know
The Wildland Fire Management Act lets wildland fire officers and compliance officers enter private land for fire management and empowers compliance officers to remove computer hardware or data storage (with receipt) if readable records cannot otherwise be produced, though entry to dwellings generally requires a warrant.
The wildfire regime creates written remediation orders and administrative penalty orders; recipients have 30 days to request ministerial review and a review stays enforcement until final disposition.
Under the Geologic Carbon Storage Act, the Lieutenant Governor in Council may, by regulation, take specified pore‑space rights and vest them in the Crown, with compensation only if prescribed by regulation.
A closure certificate for a carbon storage site transfers, subject to regulations, specified rights, duties and ownership of wells and ancillary works to the Crown; the Minister can revoke a certificate for material nondisclosure and, in certain circumstances, assume those duties before a certificate is issued.
Criminal and regulatory penalties for carbon storage offences carry a maximum fine of $500,000 or up to one year imprisonment (or both), and courts may increase fines by the amount of monetary benefit gained and order remediation and Crown cost recovery.
Section-by-Section Breakdown
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New officer classes and inspection powers
The bill replaces the old 'officer' concept with four distinct roles and expressly deems certain provincial, park and police officers to be wildland fire enforcement officers by virtue of office. Compliance and enforcement officers receive wide inspection powers: production of documents, operation or use of equipment, computer access and removal of hardware where necessary, taking samples, photographs and measurements, and stopping conveyances. The statute narrows dwelling exceptions (warrant required) and sets out procedures for warrants, production orders and warrants to conduct tests, creating a layered set of warrant and warrantless authorities tied to exigent circumstances.
Fire permits, restricted fire zones and mandatory plans
The Act requires fire permits to have outdoor fires during declared fire seasons and allows the Minister to declare restricted fire zones and extended fire seasons. Importantly, every municipality and prescribed classes of entities must prepare and annually review wildland fire management plans that meet prescribed standards; the Minister can order creation or revision where plans are missing or insufficient. Those orders are enforceable and form the backbone of preventative responsibilities for local governments and specified operators.
Emergency orders, remediation and administrative penalties
The Minister can declare wildland fire emergency areas and issue implementation orders, and may issue permits authorizing otherwise prohibited activity in emergency areas if certain public‑safety and resource‑protection criteria are met. The Act creates remediation orders (compulsory remedial activity with a 30‑day review right) and administrative penalties with formal written orders, review rights, stays during review and enforcement through Superior Court filing if unpaid. Courts retain broad remedial tools on conviction, including cost recovery and cancelling permit privileges.
Scope, prohibitions and pore‑space ownership
The Geologic Carbon Storage Act defines research/evaluation versus carbon storage activities and prohibits both unless carried out in prescribed areas and under authorizations. It confirms that pore space ordinarily forms part of surface rights but grants the Lieutenant Governor in Council the power to identify lands where pore‑space rights are taken and vested in the Crown; those Crown rights can then be authorized by permit. The regulation power includes prescribing compensation regimes, but the Act also states that taking under the statute is not an expropriation except where regulations provide compensation.
Permits, licences, referrals and Tribunal/OEB roles
Authorizations are split between licences for use of Crown lands/public pore space and permits for operational activities. Storage permits require consultation, municipal endorsement (as regulated) and satisfy technical completeness rules. The Minister must refer certain applications to the Ontario Energy Board where gas‑storage interactions exist and may refer contested applications or expansions to the Ontario Land Tribunal; Tribunal orders can unitize pore‑space rights and direct the Minister to issue, amend or refuse permits in specific circumstances, creating a formal adjudicative backstop for major or disputed projects.
Operation, closure, enforcement and stewardship fund
The Act imposes general duty‑of‑care obligations on authorization holders (precautions, reporting, insurance, records), empowers inspectors and enforcement officers to order remedial measures, decommission wells and affix tags, and contains arrest, seizure and production powers. Closure is regulated: permit holders must obtain ministerial approval and meet prescribed decommissioning and remediation obligations; once a closure certificate is issued and conditions met, the Crown assumes specified rights, duties and ownership; the Carbon Storage Stewardship Fund collects payments from authorization holders to finance Crown liabilities and closure‑related costs.
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Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Municipalities — The requirement to prepare and annually review wildland fire management plans standardizes expectations, potentially improving access to provincial support and clarifying municipal responsibilities for prevention and response.
- Carbon storage proponents and large industrial emitters — The Geologic Carbon Storage Act creates a clear regulatory path (licences/permits, unitization, tribunal and OEB processes) to pursue pilot and commercial storage projects and offers a framework for exclusive Crown‑authorized use of public pore space.
- The Crown (provincial government) — The statute centralizes decision‑making, creates a stewardship fund to manage long‑term liabilities and gives the Crown tools to take, authorize and, in prescribed circumstances, assume post‑closure obligations, improving the Province’s ability to coordinate large‑scale projects and emergency responses.
- Specialized service providers and surveyors — New work for inspectors, remediation contractors, monitoring and long‑term stewardship services, and amendments to the Surveyors Act open pathways for limited or temporary licences and broaden the regulatory work for cadastral surveying.
Who Bears the Cost
- Authorization holders and project proponents — They must meet stringent permit conditions, hold prescribed insurance, fund the Carbon Storage Stewardship Fund, pay for third‑party compliance reviews when ordered, and face remediation and administrative penalty liabilities.
- Municipalities and prescribed entities — Preparing, updating and implementing wildland fire management plans and complying with ministerial orders will demand staff time, planning resources and potentially expenditures to meet prescribed standards.
- Surface rights owners above vested pore space — Where the Crown takes pore‑space rights by regulation, affected owners may lose control over subsurface use and must rely on compensation regimes established by regulation rather than general expropriation law.
- The Ministry and adjudicative bodies — The Ontario Land Tribunal, Ontario Energy Board and Ministry staff will face increased caseloads for referrals, unitization applications, reviews and enforcement actions and will need technical capacity and funding to manage complex hearings and regulatory processes.
Key Issues
The Core Tension
The central dilemma is between enabling fast, centralized public action — to extinguish fires, deploy large carbon storage projects and manage post‑closure risk — and protecting private rights and procedural safeguards: the bill accelerates project and emergency responses by concentrating authority and allowing Crown vesting of subsurface rights while simultaneously narrowing private litigation avenues and leaving compensation and many key standards to future regulations.
The bill centralizes a great deal of discretion in the Minister and in regulation‑making. The Geologic Carbon Storage Act leaves many key design elements to regulations — permitted areas, minimum storage/ emitter thresholds for exclusive permits, compensation rules when pore space is taken, insurance and financial assurance standards, and the details of the stewardship fund.
That creates implementation flexibility but also regulatory uncertainty for investors, landowners and communities until regulations are published.
The Crown’s ability to take pore space and the scheme for closure certificates create a structural tradeoff: speeding project deployment and providing a mechanism for long‑term liability management, but concentrating property‑and‑risk shifts in favour of the Crown. Compensation for taken pore space is only payable if regulations provide for it, and the Act expressly disclaims expropriation outside of that regulated compensation.
Procedurally, remediation orders and administrative penalties may be issued without a prior hearing (though reviews and stays are available), which raises questions about procedural fairness in urgent compliance scenarios. Finally, multiple referral pathways (Tribunal, OEB) and overlapping inspection/enforcement powers across Crown actors introduce coordination needs and potential jurisdictional friction between technical regulators, tribunals and Indigenous consultation obligations.
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