The Ontario Federation of…

The Ontario Federation of Anglers and Hunters Foundation (OFAH Foundation) is dedicated to preserving Ontario's natural heritage through conservation research, habitat restoration, and educational initiatives that promote sustainable outdoor activities. As a leader in conservation, we work collaboratively with partners, experts, and communities throughout Ontario to protect and enhance fish and wildlife populations for today and future generations. We have reviewed “ERO 025-1363: Streamlining environmental permissions for mineral exploration” and offer the following comments for consideration.

OFAH Foundation appreciates the value of Ontario’s mineral industry and supports increased efficiencies where they pose no risk to conservation. However, this proposal includes legislative changes that would weaken critical environmental checks and balances; in particular, the proposed exemption of early mineral exploration activities from requiring a Permit to Take Water (PTTW).

The stated intent of this proposal is to remove unnecessary burdens for low-risk activities. However, despite many requests for clarification from us and other conservation organizations, it remains unclear how the province has identified these “low-risk” activities, nor has there been any direct evidence for the necessity of these changes. Given that the Water Resources Act already exempts activities that pump less than 50,000 litres of water per day from requiring PTTWs, we urge the Ontario government to outline exactly what thresholds these activities have met to justify their inclusion in this proposal.

Water in Ontario
Ontario’s water resources are under stress. Research indicates that our lakes, rivers, streams, and even groundwater are, in many cases, vulnerable and overburdened with pollution, invasive species, and overconsumption (Sandhu et al. 2023; Sorichetti et al. 2022, MECP, 2023; Penfound & Vaz, 2022; Yao et al. 2021). Despite their temporary nature, early exploration activities have the potential to be ecologically impactful and contribute to this trend.

Exploratory borehole drilling and trenching, for instance, often require dewatering, resulting in reduced aquifer and/or surface water levels, which can lower baseflow to streams, and reduce water availability for ecosystems and communities (Iqbal, 2023). It is critical to note that even temporary dewatering can be impactful for some ecosystems, such as fens, marshes and cold-water streams that support many vulnerable species (Cusell et al. 2015). Brook trout, for instance, are highly sensitive to flow, dissolved oxygen, and temperature. In the context of a changing climate, these prized fish face unprecedented stressors across much of the province already, making even small changes to their waterways consequential. (Haxton et al. 2019).

A growing body of evidence suggests that cumulative effects are largely under-assessed and poorly mitigated in Canada, despite playing a significant role in environmental degradation (Foley et al. 2017). Given that hundreds of exploratory projects occur in Ontario each year, and each of these may drill and dig hundreds of trenches and holes, understanding the watershed-level impacts of these activities should be a key priority for the province.

OFAH Foundation Recommendations
For these reasons, we believe that Ontario’s freshwater systems are in need of additional monitoring and oversight efforts, not less. Given that current PTTW requirements (use of > 50,000 L/day) represent a threshold the province itself has deemed environmentally consequential, broad exemptions for early exploration activities would mean removal of critical oversight that exists specifically to identify, prevent or mitigate ecological impacts like those described above. Likewise, by removing the requirement for a PTTW, these exemptions would significantly reduce or eliminate opportunities for third-party appeal and review, resulting in a loss of transparency and accountability. In effect, the proposal places further compliance responsibility on proponent without critical mechanisms of external validation or oversight. All of this is especially important when considered in the context of Ontario’s recent cooperative Environmental Impact Assessments agreement with the Government of Canada, which places a new level of responsibility on the province’s environmental assessment, compliance, and monitoring systems.

In addition to their regulatory role, systems like those managing Permits to Take Water provide critical datasets that support long-term water research. In 2025, researchers with Toronto Metropolitan University analyzed Ontario PTTW data spanning 1960 to 2022 to assess patterns in water use and inform monitoring and management. The authors make a point of highlighting “… the importance of open, transparent water data as the foundation for sustainable management and stakeholder engagement to enhance water governance.” (Sadi et al. 2025).

For all these reasons, the OFAH Foundation strongly recommends the province retain requirements for Permit to Take Water (PTTW) for early exploration activities.

Ontario’s water systems are the centerpiece of almost all life in our province; their integrity is inseparable from the health of terrestrial and aquatic ecosystems and, in turn, from the healthy living of all Ontarians. It is imperative that the Ontario government ensure that economic priorities do not take precedence over the condition of these systems, and that decisions are made with full transparency and accountability in mind. We are grateful for the opportunity to comment on this matter and welcome the prospect of engagement on any future natural resource policy measures.

References

Cusell, Casper; Mettrop, Ivan S.; Van Loon, E. Emiel; Lamers, Leon P.M.; Vorenhout, Michel; Kooijman, Annemieke M. (2015). Impacts of short-term droughts and inundations in species-rich fens during summer and winter: Large-scale field manipulation experiments. Ecological Engineering, 77: 127-138. https://doi.org/10.1016/j.ecoleng.2015.01.025

Foley, Melissa M.; Mease, Lindley A.; Martone, Rebecca G; Prahler; Erin E.; Morrison, Tiffany H.; Murray; Clarke, Cathryn; Wojcik, Deborah. (2017). The challenges and opportunities in cumulative effects assessment. Environmental Impact Assessment Review. 62: 122-134. https://doi.org/10.1016/j.eiar.2016.06.008

Iqbal, Irtiqa. (2023). Assessing the Environmental Impact of Water Borehole Drilling. Environmental Pollution and Climate Change. 7(5): 353. DOI: 10.4172/2573-458X.1000353

Ministry of the Environment, Conservation and Parks. (2023). Ontario’s Great Lakes Strategy. Ontario’s Great Lakes Strategy | ontario.ca Accessed January 26, 2026.

Penfound, Elissa & Vaz, Eric. (2022). Analysis of 200 years of change in Ontario wetland systems. Applied Geography, 138. https://doi.org/10.1016/j.apgeog.2021.102625

Saadi, Sima; Johns, Carolyn; & Parades, Diana. (2025). Groundwater permits in Ontario: an analysis of open data. Canadian Water Resources Journal. https://doi.org/10.1080/07011784.2025.2584825

Sandhu, Guneet; Weber, Olaf; Wood, Michael O.; Rus, Horatiu A.; Thistlethwaite, Jason. (2023). An Interdisciplinary Water Risk Assessment Framework for Sustainable Water Management in Ontario, Canada. Water Resources Research. 59(5). https://doi.org/10.1029/2022WR032959Digital Object Identifier (DOI)

Sorichetti, Ryan J.; Raby Melanie; Holeton, Claire; Benoit, Nadine; Carson, Lucas; DeSellas, Anna; Diep, Ngan;, Edwards, Brie A.; Howell, Todd; Kaltenecker, Georgina; McConnell, Chris; Nelligan, Clare; Paterson, Andrew M.; b, Rogojin, Vasily; Tamanna, Nure; Yao, Huaxia; Young, Joelle D. (2022). Chloride trends in Ontario’s surface and groundwaters. Journal of Great Lakes Research. 48(2): 512-525. https://doi.org/10.1016/j.jglr.2022.01.015