It is difficult to assess…

ERO number

013-4992

Comment ID

26357

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

It is difficult to assess the proposed revisions to the regulations pursuant to the Conservation Authorities Act because the posted rationale is vague. It would be preferable to specify the problems supposedly from the particular provisions in the existing regulations that are slated for revision.
The only change in a regulatory standard specified in the posting is the reduction of the regulated buffer around some wetlands from 120m to 30m, however the reason for this change (for example, an explanation for the 120m setback and an explanation for why the rationale for such a generous setback is invalid) is not presented.
Consistency is suggested to be part of the rationale for the changes, but the proposal details fail to show (or even claim) that the regulations are currently not being applied consistently.
I surmise from the language of the posting that part of the aim of the change is to narrow the scope of CA control to the “protection of people and property”, and by implication to limit the ability of CAs to regulate land use for the sake of protecting natural heritage, amenity value, biodiversity, ecological functioning, connectivity and so on—in short, to protect the environment. If that is the case, I would strongly oppose the changes. In my experience, Conservation Authority staff members have a wealth of expertise relevant to the protection of the local environment, and their ability to draw on that broad expertise in the permitting process is a worthy part of the conservation toolkit in Ontario.
I have no objection to requiring CAs to notify the public of hazard land boundary changes, though the proposal does not say anything to support the implication that CAs currently fail to do so.
I do not necessarily oppose exempting certain low-risk activities from the permitting process in order to reduce the administrative burdens on both CAs and landowners, but without more detail on what activities are to be exempted and why it is impossible to say whether the changes are advisable.