Thank you for the…

Thank you for the opportunity to provide comment on the “Proposed Changes to Ontario Regulation 299/19: Additional Residential Units. Nottawasaga Valley Conservation Authority (NVCA) provides the following comments for your consideration:

Bill 23 proposes changes to strengthen the existing additional residential framework which would allow “as-of-right” up to 3 units per lot in settlement areas with full municipal water and sewage services.

NVCA is concerned that the proposal may put people and property at risk of natural hazards. Municipal planning documents (Official Plans and Zoning By-Laws) may not contain the most up-to-date natural hazard mapping. As a result, many existing properties subject to natural hazards are zoned for residential uses. By only considering zoning intentions, without recognizing that some homes are already built on hazard lands, this approach may put many more residential units in flood prone areas, increasing the risk to life and making effective flood emergency response more difficult and more expensive.

It is recommended that an amendment be made to the “as-of-right” zoning to specify “except in areas subject to natural hazards”. Conservation authorities can help determine appropriate development locations outside of natural hazard areas. Our expertise includes identifying flooding and erosion hazards, ensure the additional units conforms to the significant threat policies and designated Great Lakes policies found within source protection plans made under the Clean Water Act.