The proposed changes will…

ERO number

019-2927

Comment ID

71843

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

The proposed changes will result in one province wide regulation for all CA’s to implement. From a Planning Ecology perspective the proposed changes to remove Conservation of Land and Pollution will impact the CA’s ability to maintain important ecosystem services which benefit the entire NPCA watershed. Wetlands and watercourses and their respective buffer areas are critical for ensuring water quality and quantity objectives are met, limiting the CA’s ability to regulate certain aspects of these features will not result in positive outcomes for water quality, quantity or biodiversity.

It's noted that the proposed change to the definition of a watercourse will prevent Conservation Authorities from regulating many headwater drainage features and higher order streams which lack definable bed, and banks or sides. There is a significant amount of scientific literature available which demonstrates the importance of headwater drainage features and higher order streams in providing and maintaining water quantity and quality. Limiting the CA’s ability to regulate these features while requiring them to ensure that flooding and erosion concerns are not impacted downstream is not an effective proposal. Rather than limiting the ability of the CA to regulate these features, there would be benefit to incorporating a definition of headwater drainage features in the Act and maintaining the existing definition of a watercourse in order to recognize the critical function these features play in watersheds.