I believe that adjusted…

I believe that adjusted language should be used in the proposed Section 28.1 of the Conservation Authorities Act and Section 9 of Regulation 41/24: Prohibited Activities, Exemption and Permits are problematic. Conservation Authorities have neither the resources or skill set to opine on matters that require the expertise and judgment of a professional coastal engineer.

Flooding, erosion and dynamic beach hazards are real and material risks to life and property. These risks are properly managed when qualified experts (and only qualified experts) make the decisions about how to mitigate those risks.

Requiring the use of qualified experts is why Ontario has bridges that don’t fail, buildings that don’t fall, tunnels that don’t collapse, and why piers, lighthouses and other important infrastructure can safely be built in areas subject to flooding, erosion and dynamic beach hazards.

Granting Conservation Authorities the ability to opine on how to mitigate flooding, erosion and dynamic beach hazards will put the CA at odds with qualified experts, increase costs to property owners, delay development and increase appeals to the Minister and/or Ontario Land Tribunal. Further, CA’s and the province may be exposed to liability if the CA attaches conditions to a permit which are misaligned with professional recommendations.

These two sections must be re-written to require Conservation Authorities to follow the advice of qualified experts, and to remove the ability for Conservation Authorities to attach conditions to the professional opinion of a qualified expert (other than conditions related to true ecological matters, such as the timing of when to do the work so as to avoid spawning season, as an example).

Thank you for reviewing my comments.