Proposal: Exempt low-risk…

Proposal: Exempt low-risk development activities from requiring a permit including certain alterations and repairs to existing municipal drains subject to the Drainage Act provided they are undertaken in accordance with the Drainage Act and Conservation Authorities Act Protocol;

Comment: “low risk” is far too loose of a term. May I suggest that the “exemption” for a permit include “all activities required to ensure the proper function of an existing Municipal Drain including Projects as defined in Section 78 of the Drainage Act provided they are undertaken with guidance from D.A.R.T. and/or best current Engineering mitigation practices for Municipal Drains.

Proposal: Allow conservation authorities to further exempt low-risk development activities from requiring a permit provided in accordance with conservation authority policies;

Comment: The updated Regulations need to include specific examples or criteria of what constitutes “low risk”. What one CA deems low risk may not be the same as a different CA. Furthermore a CA will often come back to the applicant that they need to “prove” the activity is low risk which would require additional expensive studies.

Proposal: Require conservation authorities to notify the public of changes to mapped regulated areas such as floodplains or wetland boundaries;

Comment: A timeframe needs to be provided that dictates when the CA needs to notify the public by. Example: within 3 months of the CA becoming aware of the changes.