The proposed change will…

ERO number

019-2927

Comment ID

71863

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

The proposed change will create a single province wide regulation for all CA’s to implement. It will also remove Conservation of Land and Pollution from what CA's regulate. This will impact the CA’s ability to maintain important ecosystem services. Further, 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.

Furthermore, the proposed change to the definition of watercourse will prevent Conservation Authorities from regulating many headwater drainage features and higher order streams which lack definable bed, and banks or sides. A significant amount of scientific literature is 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.