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 submits the following comments in response to ERO-025-1078, which proposes amendments to regulations under the Public Lands Act to exempt a range of pre-development activities from written, site-specific authorization requirements. While presented as a narrow, administrative streamlining exercise, this proposal represents a significant weakening of oversight for activities occurring on Crown lands and shore lands, including riverbeds and seasonally inundated areas that are among Ontario’s most ecologically sensitive environments.
ORA is particularly concerned that this regulation must be read in direct conjunction with ERO-025-1145. Together, these postings establish a two-step framework in which Crown lands are first prioritized for energy development through policy and then rendered procedurally accessible through regulatory exemptions that bypass early scrutiny. This proposal, therefore, cannot be assessed in isolation, despite the Ministry’s attempt to separate the postings administratively.
2. Erosion of Site-Specific Oversight on Crown Lands:
The proposal would allow a wide range of activities—including mobile wind testing equipment, geotechnical and hydrogeological investigations, environmental monitoring equipment, and short-term bridges—to occur on public lands without written, site-specific authorization, provided that regulatory conditions and location registration are met.
These activities are characterized as “low-risk” and “short-term,” yet in practice, they represent the first physical footprint of industrial development on Crown lands, including river corridors and shorelands.
Removing the requirement for site-specific authorization at this stage undermines the precautionary principle. Early investigations frequently determine project viability, alignment, access routes, and river crossing locations. Once these activities occur, ecological disturbance is no longer hypothetical; it is real, cumulative, and often irreversible, particularly in wetlands, riparian zones, and coldwater river systems.
3. Redefinition of “Shore Lands” and Loss of Riparian Protection:
ORA is deeply concerned by the proposed narrowing of the definition of “shore lands,” which would exclude areas inundated during spring freshet or extreme flooding events
This change is fundamentally incompatible with climate science and Ontario’s own Climate Change Impact Assessment, which documents increasing frequency and severity of extreme precipitation and flooding events.
Environment and Climate Change Canada’s Synthesis of Freshwater Science in Canada identifies climate change as a force multiplier that intensifies the ecological consequences of land-use disturbance, particularly in riparian zones and flood-affected areas. The synthesis stresses that floodplains, seasonally inundated shorelands, and river margins play a critical role in regulating temperature, sediment transport, nutrient cycling, and habitat connectivity, and that weakening protections in these areas increases long-term risks to water quality and aquatic biodiversity. Excluding flood-affected shorelands from regulatory oversight is therefore directly at odds with federal freshwater science and climate-adaptation best practice.
By excluding these areas from regulatory protection, the proposal effectively withdraws oversight from precisely those zones that are most dynamic, most climate-vulnerable, and most critical for fish habitat, nutrient cycling, and flood attenuation. In river systems, areas affected by freshet and flooding are not anomalous—they are integral to ecological function. Redefining them out of scope is a regulatory fiction that invites damage under the guise of administrative clarity.
See the full submission in the attached PDF.