The Ontario Rivers Alliance …

The Ontario Rivers Alliance (ORA) is a not-for-profit grassroots organization with a mission to protect, conserve, and restore riverine ecosystems across the province. The ORA advocates for effective policy and legislation to ensure that development affecting Ontario rivers is environmentally responsible, socially just, and climate resilient.

ORA’s comments are informed by long experience working with Ministry of Natural Resources professionals whose mandate has been to protect, restore, and sustainably manage Ontario’s forests, rivers, and watersheds for present and future generations.

ORA recognizes that MNR staff enter the natural resources profession to apply science, exercise precaution, and prevent irreversible harm. The concerns raised in this submission are therefore directed at the policy and regulatory direction set by government—which increasingly constrains professional discretion and weakens long-standing safeguards—rather than at the expertise or intent of Ministry staff charged with implementing these changes.

ORA submits that these proposals must be assessed together as a single, coordinated deregulation package. Although posted as separate notices with different Ministry contacts, the Natural Resources Regulatory and Permit Reform Initiative is advancing an integrated framework that (1) prioritizes Crown lands and watersheds for renewable energy and waterpower development (ERO-025-1145), (2) removes early-stage Public Lands Act authorizations that currently function as precautionary gates (ERO-025-1078), (3) expands permit-by-rule/self-registration approaches and weakens forest-related safeguards that directly affect watershed hydrology, erosion, and downstream aquatic habitat (ERO-025-1134), and (4) consolidates these reforms under a broader “economic unlocking” agenda (ERO-025-1141). In combination, these measures create a foreseeable “pipeline effect” that will unleash a new tranche of hydropower and related infrastructure onto Ontario rivers by reducing oversight at the exact stages when project feasibility, routing, and impacts are determined.

1. Core Objection and Policy Context:

The ORA strongly opposes the proposed amendments to the Renewable Energy on Crown Land (RECL) policy. Despite being framed as administrative modernization, these changes represent a substantive policy shift that privileges rapid energy procurement over sustainability, ecological integrity, Indigenous rights, climate resilience, and the Crown’s public trust obligations.

The proposal embeds the Ministry of Energy’s report, Energy for Generations, into Crown land decision-making without addressing its documented analytical gaps, particularly regarding hydropower emissions, cumulative watershed impacts, and climate-driven hydrologic instability. The report engages in major misinformation, falsely portraying hydropower as a “clean” and “non-emitting” resource, even though reservoir-based hydropower is a well-documented source of methane that can rival that of a gas-fired facility. Yet, claims it will help keep Ontario’s grid among the “cleanest in the world.”

The Energy for Generations document relays harmful misinformation that perpetuates a century of river mismanagement in Ontario and actively fuels climate change. For instance, our climate is in crisis, and there are 224 hydropower facilities, likely 3 to 4 times as many associated control dams, and only two operating fishways in all of Ontario. Dams are considered to be a major factor in the extirpation of Ontario’s Atlantic Salmon stock , one of the important causes of significant anthropogenic mortalities and decline of Ontario’s American Eel , and a key threat to declining Lake Sturgeon populations. , ,

2. Ontario Wants to Be an “Energy Superpower” on the Backs of Ratepayers:

The 2025 Energy for Generations, Ontario’s Integrated Plan to Power the Strongest Economy in the G7, stated, “We will cement Ontario’s position as a national, continental and global energy superpower”. This is not a mandate the public ever endorsed. The Premier did not campaign on becoming an “energy superpower”, nor did the PC Party’s election platform seek voter approval for an energy-export agenda, new northern hydropower development, or building electricity supply beyond our own domestic needs. This framing appeared only after the election, through ministerial statements and government planning documents. Nothing in the PC Party’s public-facing platform communicated a mandate for an export-oriented energy or hydroelectric expansion strategy. Although the federal government under Prime Minister Mark Carney campaigned to position Canada as a national energy superpower, that federal mandate does not transfer to Ontario’s electricity system; the Province did not seek voter approval for a provincial energy-export agenda or for a hydropower-driven expansion strategy. Ontario cannot rely on federal political messaging to justify a provincial energy export agenda that voters were never asked to endorse and will end up paying for.

Ontario ratepayers were not consulted on this shift, yet the government is already proposing to shift early-stage hydropower planning, incentives, and consultation costs—including Indigenous consultation costs—onto ratepayers’ hydro bills, an unprecedented transfer of speculative project risk from proponents to the public. , Supporting Indigenous prosperity is essential, but it should not be leveraged as a vehicle for an “energy superpower” build-out in some of Ontario’s most vulnerable and ecologically intact northern watersheds. In a period of accelerating climate uncertainty, imposing unnecessary, speculative system-expansion costs on ratepayers is irresponsible and lacks democratic legitimacy. We are living in very uncertain times, and this is not the time to add unnecessary costs to ratepayers’ hydro bills.

The province’s Energy for Generations plan positions 3,000–4,000 MW of new northern hydro potential as a tool to enhance reliability and reinforce Ontario’s position as an ‘Energy Superpower,’ and highlights new Moose River Basin projects at Nine Mile Rapids and Grand Rapids alongside recontracting programs for small- and northern-hydro. This ERO must be read squarely in that context. However, it omits critical climate‑change considerations and risks locking Ontario into an intermittent, unreliable and high‑emissions energy pathway.

3. Northern Hydro <10 MW is an Energy-Limited and Highly Variable Resource:

Energy for Generations frames hydropower as a non-emitting, clean, dispatchable, long-term climate solution. However, its fundamental analytical failure is the complete absence of the 2023 Ontario Climate Change Impact Assessment (OCCIA), despite its direct relevance to hydropower and transmission system planning in northern Ontario. OCCIA documents severe increases in drought frequency, extreme precipitation, hydrologic instability, rising summer stream temperatures, and ecosystem stress—conditions that fundamentally undermine the performance, certainty, and safety of hydropower infrastructure. Ignoring OCCIA’s findings is a major flaw that renders the proposed changes to the Renewable Energy on Crown Land policy unsupported by science or sound planning.
The supporting documentation greenwashes northern hydropower as a dependable baseload, whereas the Independent Electricity System Operator’s (IESO) own North of Dryden Integrated Regional Resource Plan (NDIRRP) unequivocally reports that northern hydropower is an energy-limited and highly variable resource incapable of providing firm capacity at scale.
“Canada’s increasing struggle with hydropower is an ill omen representing a wider global problem. Climate change and droughts are threatening hydropower supplies everywhere, and as severe weather events become increasingly common due to climate change, the future of the world’s leading renewable energy source is vulnerable. The greatest problem is not just the severity of any drought but the persistence of drought conditions over an extended period of time. The Yale Climate Connection argues that the link between climate change and increasing drought conditions worldwide is demonstrable, and things are getting worse. Global hydropower generation dropped significantly in the first half of 2023, resulting in an overall increase in fossil-fuel power production to make up for the deficit.”

Run-of-river or hydropower under 10 MW is often not cost-effective due to high construction costs and its intermittent and unreliable nature, particularly during drought conditions. The NDIRRP reported that northern hydroelectric power generation has a firm capacity of 15 to 30% at a cost of $16 to $66 million per MW with a development duration of 5 to 10 years.

Treating such resources as foundational infrastructure exposes Ontario to escalating climate, ecological, and financial risk.
See PDF for complete submission: