1) The exemption should…

1) The exemption should apply to all municipalities under Strong Mayor Powers and apply to all parcels of urban residential land, especially existing vacant lots of record. Conservation authorities should not strictly regulate and prohibit the use of vacant land in private ownership for the purposes of conservation as this is considered de facto expropriation:

On October 21, 2022, the Supreme Court of Canada ruled that "regulations that leave a rights holder with only notional use of the land, deprived of all economic value, would satisfy the test for a de facto expropriation requiring compensation. It could also include confining the uses of private land to public purposes, such as conservation" (Annapolis vs. Halifax).

2) While many people in the City of Toronto would like to build a garden suite in their backyard, conservation policies and regulations do not permit new development in the floodplain. This means people living in regulated areas cannot convert an existing shed into a garden suite, even though zoning by-laws allow for that conversion.

3) As part of the permitting process, conservation authorities should only act as "commenting agencies" that determine which technical reports are required, review those reports and provide comments to the municipality as it relates to their policies and applies to a development proposal. If conditions are imposed, they should be reviewed and approved only by the municipality.

There is no cookie cutter approach, but conservation authorities have been given too much power, which they love to abuse. One of the CA conditions of my permit approval was that I get municipal approval first. Go figure! Therefore, it would be best to just have ONE municipal approval and exempt a CA permit for new housing in cities with Strong Mayor Powers. Less cost and less time for everyone involved.

Thank you.