Changes to Streamline Natural Resource Permits: Allow dry hydrants on public lands

As part of its plan to protect Ontario and build the most competitive economy in the G7, the Ontario government is proposing changes to modernize and streamline natural resource permits, allowing mining and infrastructure projects to move forward faster and with greater certainty. These proposals, focused on low-risk and routine activities, would reduce administrative requirements for hundreds of natural resource permits annually and shorten approval timelines, all while continuing to safeguard public health and safety and sustainably manage natural resources.

Public Lands in Ontario

The Ministry of Natural Resources (MNR) manages public lands (also called Crown lands) in Ontario under the Public Lands Act (PLA). To better support economic development, burden reduction and service delivery, we are proposing to streamline permitting and approvals processes to allow some occupations if rules are followed. 

Public Lands Act

Public lands under the administration and control of the Minister of MNR represent 77% of the total area of Ontario and include the beds of most navigable lakes and rivers. The Public Lands Act provides the Minister of MNR with broad authority to manage and dispose of public lands. The public lands managed under the Public Lands Act do not include:

• Provincial parks
• Conservation reserves
• Federally managed lands.

Currently, people need written approval from MNR to occupy public lands. This is typically provided in the form of a: 

• land use permit
• licence of occupation
• lease or; 
• easement. 

Approval to occupy public lands can also be provided through regulation. Ontario Regulation 161/17: Occupation of Public Lands under Section 21.1 of the Act (O. Reg. 161/17) sets out the types of buildings, structures or things that can be placed and used on public lands without a written site-specific authorization if the rules set out in the Act and regulation are followed.

Ontario Regulation 239/13: Activities on Public Lands and Shore Lands – Work Permits and Exemptions (O. Reg. 239/13) sets out when people need a work permit for activities on public lands or shore lands, and exemptions for certain activities if rules set out in the Act and regulation are followed. 

Proposed changes to regulations under the Public Lands Act 

Dry hydrants

Dry hydrants are non-pressurized pipes installed along a water source, such as a lake or river, to provide water for fire protection or fire suppression. We are proposing to allow dry hydrants on public lands to support activities related to infrastructure. 

In 2025 the ministry sought preliminary input on proposals to reduce approval requirements for certain activities, including dry hydrants: Natural Resources Regulatory and Permit Reform Initiative: Unlocking Ontario’s Economic Potential | Environmental Registry of Ontario. 

We are proposing to allow dry hydrants on public lands under a code of practice framework, without site-specific authorization, under O. Reg. 161/17 if the following rules are met: 

• Must be used only for fire protection or fire suppression purposes (including regular maintenance and testing of the dry hydrant). 
• Must be kept in working condition and maintained in acceptable manner to the appropriate authority. 
• Only ancillary equipment for protection of the dry hydrant, such as bollards, are permitted in conjunction with the dry hydrant. 
• Must use clean, stable, and non-erodible materials for the dry hydrant and any ancillary equipment. 
• Any dredging or placement of fill must be minimal and limited to the immediate area needed for installation. 
• Sediment and erosion control measures must be used during installation, maintained for the duration of installation and until sediment is stabilized. 
• Any disturbed shoreline must be stabilized immediately after installation  
• In-water work would be prohibited during the times of the year when fish species are vulnerable (e.g. spawning) according to the In-Water Work Timing Window Guidelines.
• Machinery must be operated from dry land, ice, a barge or vessel and equipment used for installation must be properly maintained and must not be refueled or serviced near the water.
• Any material removed during installation must be managed to prevent it from re-entering the water. 
• The location of the dry hydrant must not interfere with public access or travel, including on road allowances. 

A proponent that meets all the rules for the placement of a dry hydrant would not be required to obtain a work permit for any activities related to the placement of a dry hydrant. 

The proposal would support infrastructure development by streamlining approvals for dry hydrants while maintaining environmental protections and consistent installation requirements.

Environmental Implications

MNR is committed to preserving natural heritage features for present and future generations. Occupational authority and work permit requirements would continue to apply to higher-impact activities. The proposal only applies to certain occupations where impacts are predictable and manageable through standard conditions. Placing things on public lands and using them for these purposes would not require a written site-specific authorization. These occupations and activities would only be allowed if they meet specific conditions designed to avoid or mitigate impacts to the environment. If not allowed by the regulation, then review and written site-specific authorization from MNR would be required to proceed with the occupation or activity.

The proposed conditions to be included in regulation have been developed to mitigate or reduce potential negative impacts to the environment. Other environmental regulatory requirements or approvals at the municipal, provincial or federal level would not be impacted.

Regulatory impact analysis

In developing these proposals in a way which would continue to protect and sustainably manage natural resources, we have considered any potential risks to natural resources, public health and safety, economic values, and society. Based on these considerations, we have determined that:

• The anticipated environmental impacts and social consequences of the proposal are expected to be minimal. Allowing things to be placed on public lands if conditions are followed would continue to provide oversight for environmental impacts and social consequences of proposed occupations and activities.
• The anticipated economic consequences of the proposal are expected to be positive. The proposed changes would reduce the regulatory burden on individuals and businesses engaged in infrastructure projects and other economic development opportunities on public lands.