Comment
I am against these changes for the following reasons.
Taxpayers, municipalities and our natural systems will bear the costs of the Province’s affordable housing legislation released last month.
While I support efforts to address the ongoing housing crisis, many of the proposed changes related to Conservation Authorities (CAs) will have significant impacts and costs while doing little to increase housing supply.
Proposed changes and their impacts:
Although Conservation Authorities (CAs) have been providing cost-efficient, watershed-wide natural hazard protection for more than 70 years, Bill 23 seeks to:
-download responsibilities to already-overburdened municipalities, including assessing water quality and ecological impacts, establishing and enforcing waterfront setbacks, and evaluating wetlands.
-exempt some development activities from needing any natural hazard permits;
-prohibit consideration of land conservation and pollution control by CAs, which would remove the ability to protect natural resources that support existing residents and recreational tourism;
-alter the provincial wetland evaluation system to reduce the number and extent of these natural water reservoirs; and
Cumulatively, these changes will have significant downstream impacts for homeowners in the form of increased risk of flooding, erosion and landslides, poorer surface and drinking water quality, loss of tourism and recreation opportunities, and higher homeownership costs in the form of increased insurance premiums, flood damages and emergency response.
Weakening the regulatory ability of CAs to protect people and property from natural hazards like flooding, erosion and slope failures - leading to greater risk of property damage and public safety.
Eliminating the CA’s ability to address water quality issues through planning and permitting, leading to increased nutrients and sediment in lakes and rivers. We know from the 1990s this causes excessive weed growth and algae blooms that have economic impacts on property values, agriculture, tourism, recreation, fisheries and sources of drinking water for many residents.
Reducing wetland evaluations and protections, leading to increased flooding, erosion and drought, as well as diminished groundwater, which is the source of drinking water in much of rural Ontario. Studies have shown the loss of wetlands in the Rideau watershed alone would increase flood levels by 10%. Many other watersheds would be affected in similar ways. WE CANNOT AFFORD TO INCREASE FLOODING.
Downloading more responsibilities to municipalities who have indicated will lead to inefficiencies, delays and increased risk and costs.
Freezing development fees, which will pass development costs to taxpayers instead of growth paying for growth.
The Provincial Government needs to reconvene their multi-stakeholder Conservation Authorities Working Group to consider the impacts of these proposed changes. The working group has proven it can provide effective recommendations to government that increase housing supply without jeopardizing public safety, dismissing natural systems or downloading additional responsibilities to municipalities.
The Ontario Association of Municipalities (AMO) shared similar concerns, stating “many of the proposed amendments to the Conservation Authorities Act and the Planning Act in Bill 23 are concerning, as they signal a move away from environmental protection at a time when climate change impacts are being felt more at the local level. Bill 23 proposes sweeping changes to the regulatory responsibilities of Ontario’s 36 conservation authorities that, if passed, will undermine the collaborative and productive changes put forward by the Ministry led Conservation Authority Working Group over the past two years”.
It is well understood that water flows across municipal boundaries – and so do the impacts of development. That’s why over the past 70 years, municipalities have formed 36 CAs across Ontario to assess and understand the cumulative impact of development within each watershed. At a time when climate change is causing more frequent and intense storm events, the role of CAs has never been more critical.
Not a barrier:
The Province’s “Housing Affordability Task Force Report” introduced 55 recommendations to increase the housing supply in Ontario, and CAs were not named within the report.
CAs save municipalities and developers time and money, as the cost-efficient CA system allows member municipalities to share the expertise of CA hydrogeologists, biologists and engineering staff to review planning applications instead of each hiring their own – a huge savings for taxpayers.
CAs also save the Province and taxpayers money by reducing the financial impacts of severe flooding like Eastern Ontario experienced in 2017 and 2019. The province’s own Special Advisor on Flooding, Doug McNeil, in his 2019 report found that Ontario’s unique CA system remains the fundamental reason why Ontario has not seen the same catastrophic flooding impacts in the billions of dollars as Alberta and BC, which do not have CAs to direct development away from high-risk areas.
STOP DESTROYING GREEN SPACE AND REMOVING PROTECTIONS FROM NATURAL HAZARDS.
Submitted November 15, 2022 6:14 AM
Comment on
Proposed updates to the regulation of development for the protection of people and property from natural hazards in Ontario
ERO number
019-2927
Comment ID
68802
Commenting on behalf of
Comment status