The Municipalities in South…

ERO number

019-1187

Comment ID

44987

Commenting on behalf of

South Nation Conservation

Comment status

Comment approved More about comment statuses

Comment

The Municipalities in South Nation Conservation’s (SNC) jurisdiction have some of the highest numbers of municipal drains in Ontario: with over 1,200 drains throughout the watershed.

We provide local, practical, knowledge and expertise to drainage superintendents, the Province, and municipalities to ensure timely and efficient reviews for drain maintenance and improvements supporting our 16 member municipalities.

As a Conservation Authority and municipal partner, SNC is pleased to provide the following comments on the Drainage Act Discussion Paper.

Local Challenges expressed by Member-Municipalities:

Within SNC’s jurisdiction, certain areas include soils prone to erosion that are challenging to manage during drain maintenance and improvement projects. These types of soils require appropriate reviews of proposed work to manage negative impacts on neighbouring property owners, individual properties, and the environment. Minor projects, as proposed, in some areas could lead to major issues if not appropriately reviewed.

With productive agricultural lands and lower levels of forest cover in the region, some Municipalities are already experiencing an increase in drain maintenance and improvement requirements. Further, additional fields being tile drained, change of agricultural land use from pasturelands to corn and soybeans for example, and high runoff rainfall events have demonstrated lack of capacity in certain municipal drains.

With excellent farmland, our area has observed many farm purchases and consolidation of farm fields. For example, when fields merge, the proposed amendments categorize “minor improvements” as: creating or widening a crossing, and relocation of a drain on an individual property as minor improvements to be streamlined. Where drains, drain hundreds of acres, these drain relocations on “individual properties” could cause unintended consequences on receiving drains (specifically, drains that are currently undersized to receive run off more quickly from larger fields and where windbreaks and hedgerows have been removed to consolidate fields to accommodate larger equipment).

The Conservation Authority and Municipalities are often called to assist in mediating disputes between property owners on these matters. These calls could be more frequent should processes lack oversight and accountability.

In Eastern Ontario, there is a serious shortage of drainage engineers. In our view, this issue is sometimes the cause of delays on drainage projects. Unless this situation is remedied, there will continue to be delays, regardless of other streamlining measures.

Current Efforts:

SNC understands the government’s commitment to streamline approvals. We work proactively with drainage superintendents to find efficiencies and support the important role drainage plays in our agricultural landscape. We continuously update information available on municipal drains in our jurisdiction. This includes the fish and fish habitat data, which provides clarity and certainty for drainage superintendents on project timelines.

We helped create the DART Protocol that streamlines project reviews under the Conservation Authorities Act. SNC further streamlined project approvals by reviewing drain projects under the Fisheries Act through our agreement with Fisheries and Oceans Canada. This one window approach allowed drainage superintendents to work directly with SNC staff who had the local knowledge and experience to ensure projects proceeded safely and timely.

South Nation Conservation looks forward to opportunities to work with the Ontario government on water management in Eastern Ontario.