I am in FULL SUPPORT of the…

I am in FULL SUPPORT of the proposal.

FYI - I was asked recently "What are the biggest challenges you face in growing your company in Ontario?" My answer included competing “AGAINST Ontario's Conservation Authorities" that claim to provide the same (in-house) professional engineering design/analytical services to their member municipalities - but while not providing adequate response times for urban development application reviews and construction permit approvals. Those services are subsidized by taxpayers and do not include proper risk transference from a professional practice liability and licensing perspectives and where public health issues are in play. This current process must stop.

What could the Ontario Government do to help me grow my company in Ontario? First, reduce the current red tape process affecting the land development industry. This includes review time delays by Conservation Authorities (CAs) and their level of effort charges back to my clients. My clients are now experiencing first submission review delays (by CAs) of between 12 - 16 months. In fact, my company's fees for doing the work in the first place (plus taking on the risk via professional engineer sealed reports, plans, etc.) can be the same cost or less than the review fees charged by CAs to my clients.

I agree with the proposal to reduce the size of Conservation Authorities (wherever feasible) and consolidate staff plus resources in order to provide more cost-efficient services. Where appropriate, a “fee-for-service” licensed professional engineering roster could be implemented for land development reviews by municipalities and if possible (i.e. as an enhanced option to compliment the Conservation Authority service delivery model) and to help expedite development and permit reviews - but only if there are no conflicts of interests or legal / ethical concerns.

A downsizing of services by Conservation Authority services is a good thing and to have CAs focus on only the ‘core’ legislated requirements under the Conservation Authorities Act (flood forecasting, flood damage prevention, stream health monitoring and land stewardship programs). This was how all CAs operated when I started practicing professionally. Other current services (such as surface water and groundwater quality management programs, subwatershed planning and GIS services) should also be "uploaded" to the affected upper tier municipality and aligned with the Planning Act, Source Water Protection and/or other applicable legislation. If feasible, Conservation Authority administrative offices (with less staff per the subject proposal) could then be located to County or Regional Government offices. This would provide better integration of the proposed service re-allocations, better communications, better visibility with lower tier/member municipalities and maybe more important from a public safety perspective, also ensure dependable IT communication systems, data storage and security needs during emergency (flooding) related events.

Finally, an audit should be undertaken immediately of CA technology approval programs, such as this one described at https://sustainabletechnologies.ca. I know of companies who have been "pressured" to sign up for this specific program or else their products would not be endorsed by the CA team administering this program. This is not acceptable. In fact, the affected companies had even shown they had all required industry (standard) certifications. Their product performance claims were also supported by other qualified independent (3rd party) reviews too.

Thank-you for the opportunity to comment.