“Consolidating and…

ERO number

013-4992

Comment ID

31112

Commenting on behalf of

Kawartha Conservation

Comment status

Comment approved More about comment statuses

Comment

“Consolidating and harmonizing the existing 36 individual conservation authority approved regulations into 1 Minister of Natural Resources and forestry approved regulation.”

Comment:
This is a positive change that will provide consistency and clarity across the province resulting in a more streamlined process.

“Update definitions for key regulatory terms to better align with the other provincial policy, including “wetland”, “Watercourse”, and “pollution”.

Comment:
This is a positive change that will provide clarity on terms that are often confused and misunderstood. It will help to better define our regulatory role and permitting. We anticipate providing more comments once the definitions are circulated for review.

“Defining undefined terms including “interference” and “conservation of land” as consistent with the natural hazard management intent of the regulation.”

Comment:
This is a positive change that will provide clarity. We anticipate providing more comments once the definitions are circulated for review.

“Reduce regulatory restrictions between 30m and 120m of a wetland and where a hydrological connection has been severed.”

Comment:
The intent of this change is understood, however, there is a need to define what ‘severing a hydrological connection’ means as it relates to both surface and ground water. The physical site condition regarding a severed hydrological connection could be difficult to determine pending the definition proposed. We note that groundwater connection could still be important in the context of reducing flooding and managing natural hazards.

The context of the reduction in regulatory restriction will be helpful to understand, which we anticipate in future consultation.

“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:
This is a positive change. There is a need to clearly define what is meant by “low-risk development activities”. Kawartha Conservation currently implements a streamlined permit for these activities including Letter of Permission for low risk development activities. In addition, the DART protocol is meant to address common permitting activities and requirements thereof. The DART protocol erosion and sediment controls are insufficient and need updating to current standards if this change moves forward.

“Allow conservation authorities to further exempt low-risk development activities from requiring a permit provided in accordance with conservation authority policies.”

Comment:
There is a need to clearly define what is meant by “low-risk development activities”. We support this change.

“Require conservation authorities to develop, consult on, make publicly available and periodically review internal policies that guide permitting decisions.”

Comment:
This is a positive change and one that Kawartha Conservation already does as part of our regular business. We welcome standardized rules for this.

“Require conservation authorities to notify the public of changes to mapped regulated areas such as floodplains or wetland boundaries.”

Comment:
This is a positive change and one that Kawartha Conservation already does as part of our regular business. We welcome standardized rules for this.

“Require conservation authorities to establish, monitor and report on service delivery standards including requirements and timelines for determination of complete applications and timelines for permit decisions.”

Comment:
This is a positive change that will provide consistency. Kawartha Conservation currently does this through our CALC reports provided at every Board Meeting.

“Proposing to bring into force un-proclaimed sections of the Conservation Authorities Act associated with conservation authority permitting decisions and regulatory enforcement.”

Comment:
This is a positive change as it will allow for a streamlined development process. As an example, the ability to issue stop work orders would reduce the number of charges currently held up in the court process, allowing for conservation authorities to protect natural hazard features in the interest of public safety and speed up the development process. This makes us consistent with other regulatory authorities in Ontario.

Thank you for the opportunity to review and comment on the draft policy changes; we look forward to a further opportunity to provide input on the proposed regulation (in consultation with other conservation authorities) prior to the regulations taking effect