We have reviewed the…

We have reviewed the proposed amendments to Regulation 828 and the Bruce Trail Conservancy is broadly in support based on the details provided. The proposed amendments would appear to meet the objectives of providing greater certainty and clarity for landowners, businesses and organizations operating within the NEP. In particular for the BTC, exempting more “environmental management activities” from development permits, such as upgrades to trail systems, construction of boardwalks and stairs, and other restoration activities, is very much welcome.

As a conservation land trust operating almost entirely within the Niagara Escarpment Plan area, we are eager to learn more specific details about some of the changes being contemplated. The BTC typically executes severances for conservation purposes (conservation severance) several times every year, some of which are already exempted from the requirement for a development permit. However, conservation severances of vacant land (for example) still require a development permit under current regulations. We would appreciate clarification if this is one of the amendments being proposed. This change, in particular, would meet the stated objective of amendments to the regulation of “making it easier for conservation organizations to carry out activities that will benefit the escarpment environment”. As stated previously, BTC has already protected over 16,000 acres on the Niagara Escarpment, under current regulations. Changes to the regulation to exempt conservation severances from the requirement of a development permit will enable BTC to work faster and with the urgency required to protect sensitive habitat from development or mismanagement.

Please see attached letter for our additional comments.