Comments on Schedule 2 of…

Comments on Schedule 2 of Bill 108 re Conservation Authorities Act - ERO 013-4992

I am commenting on the Schedule 2 of the More Choices Act - Bill 108 -having to do with the "Focusing conservation development permits on the protection of people and property". My comments as follows:

a) I question whether an omnibus regulation governing ALL Conservation Authorities is really practical given that Conservation Authorities act locally to perform their mandates. Perhaps there is a reason that there are 36 individual conservation authority approved regulations under the current Section 28 (1) of the Conservation Authorities Act - R.S.O. 1990, CHAPTER C.27. The 36 regulations are locally tailored to local conditions and an omnibus regulation may not properly address them.

b) Definitions for the following terms are already properly laid out in the Definition Preamble of the Conservation Authorities Act - R.S.O. 1990, CHAPTER C.27: wetland, watercourse, and pollution.

c) How would the regulatory restrictions between "30 m" and "120 m" of a wetland be changed. For example: In Durham Region, municipal practice has been to set back 120 m from Lake Ontario where
development is concerned and 30 m from the so-called boundary of a wetland such as Frenchman's Bay? Such restrictions need to be clearly defined.

d) Exempting any low level development activities from requiring a permit opens the process to abuse whereby sensitive watersheds, wetlands, and adjacent embankments can and could be damaged.

e) I thought Conservation Authority policies were clearly set such that ALL development requires a permit. As in my (d) above, allowing low level development without a permit if it is in accordance with set Conservation Authority Policy invites abuse. The Conservation Authorities must ask for permits for any and all development because of this.

f) Although, this comment is "anonymous" I wish to thank the Environmental Registry of Ontario for the Opportunity to respond in this fashion as both a citizen and taxpayer of this great province.