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.

1. Forestry Deregulation as a Catalyst for River and Hydropower Impacts:

ERO-025-1134 cannot be assessed as a stand-alone forestry modernization exercise. It forms one component of a coordinated regulatory framework that, when combined with ERO-025-1145 (Renewable Energy on Crown Land), ERO-025-1078 (Public Lands Act streamlining), and ERO-025-1141 (economic reforms), will materially increase development pressure on Ontario’s rivers, particularly through a new tranche of hydropower proposals.

Forests are inseparable from river systems. Forest management decisions directly influence watershed hydrology, sediment transport, mercury mobilization, thermal regimes, and flood response. Weakening forest oversight, therefore, has predictable and compounding downstream consequences for river ecosystems already under stress from climate change and cumulative development.

2. Permit-by-Rule and Self-Registration Undermine Watershed Protection:
The proposal repeatedly advances permit-by-rule, registration, and extended licence frameworks as efficiency measures. From a watershed perspective, these approaches are deeply problematic. Forest operations—roads, crossings, harvest blocks, aggregate extraction, and land clearing—are among the primary drivers of cumulative effects on aquatic ecosystems. Removing site-specific approvals and reducing Crown oversight at these stages increases the likelihood that impacts to streams and rivers will be normalized, fragmented across permits, and effectively invisible to regulators until damage is entrenched.
Federal fisheries science confirms that cumulative effects, rather than individual projects, are the dominant cause of fish habitat degradation. , Project-by-project and activity-by-activity approaches are structurally incapable of managing these risks. By expanding permit-by-rule approaches in forest management, the Province is moving in the opposite direction of best available science.

3. Continuous Forest Management Planning and Loss of Precaution:
ORA is concerned that the shift toward longer, more consolidated forest management planning cycles reduces meaningful opportunities for adaptive management under rapidly changing climate conditions. Climate-driven increases in extreme rainfall, freeze-thaw cycles, drought, wildfire, and pest outbreaks fundamentally alter hydrologic response and erosion risk in forested watersheds. ,
Locking in harvest patterns, access corridors, and infrastructure assumptions while simultaneously weakening approval triggers reduces MNR professionals' ability to exercise precaution when conditions change. This is particularly concerning in watersheds targeted for renewable energy and hydropower development, where forestry disturbance compounds flow alteration, sedimentation, stream temperature and downstream risks.
See full submission in PDF attached below.