Thank you for allowing…

Thank you for allowing public comment on changes to the Drainage Act.

When developing a "process for simple drain improvement projects" the authorities determining "minimal impact on the environment" are the MNRF, the DFO, the MOECP and the CWS.

Municipalities, contractors and proponents cannot be expected to provide the biological and ecological expertise working within the Ontario public interest. That is the role of government.

The Environmental Assessment Process which may be inconvenient for "some stakeholders" is a necessary component of responsible decision making and for the public good as a whole. Careful consideration of all factors by trained professionals may take a little more time, but can prevent invaluable losses downstream.

Streamlining of drainage approvals must in no way jeopardize migratory bird, pollinator or aquatic habitats.

Species at risk habitat must be identified by appropriate provincial and federal authorities, then excluded from disturbance prior to approval.

Rural drainage projects can and should integrate functional watercourses within natural habitats.

Drainage improvements should include auditing and conservation of ecological services provided by functional riparian corridors and the establishment of those services when absent.

Those ecological services include runoff filtration, thermal regulation, flood management and spawning habitat, among others.

It is my hope that the provincial government will consider these and other recommendations that integrate flow management with environmental protection.

I look forward to further consultation.