Photo by Mark Clement
This two-step approach shifts risk away from proponents and onto Ontario’s rivers, Indigenous Nations, and the public interest—at precisely the moment when climate change, flooding, and freshwater ecosystem decline demand stronger, not weaker, precaution. By exempting early disturbances, narrowing shore-land protections, and relying on registration rather than site-specific authorization, the Province is effectively pre-approving development pathways before their ecological and social consequences are understood.
Ontario’s rivers and Crown lands are not expendable staging grounds for an unexamined “energy superpower” agenda. They are public trust resources and critical climate-resilience infrastructure. ORA therefore urges the Ministry to withdraw ERO-025-1078, reassess it jointly with ERO-025-1145, and re-establish a regulatory framework grounded in contemporary freshwater science, Indigenous rights, and the precautionary principle.
Subsequent Ministry correspondence dated November 6, 2025, confirms that ERO-025-1145 and ERO-025-1078 form part of a single, coordinated initiative to streamline Crown land and in-water approvals, reinforcing ORA’s concern that these proposals must be assessed together for their cumulative ecological and governance impacts.