Thank you for the…

Thank you for the opportunity to comment on the Ministry of Natural Resources and Forestry’s proposal to amend the Conservation Authorities Act. I am writing to you in response to Bill 23, the More Homes Built Faster Act.

I understand and agree that there is a housing supply and affordability issue in Ontario that needs to be pragmatically addressed, and therefore support the government’s commitment to reducing unnecessary barriers to development and streamlining processes. That said, I have several concerns and recommendations with the proposed amendments and therefore offer the following comments for your consideration in amending the Conservation Authorities (CA) Act and any associated documents.

Ontario Wetland Evaluation System Classification Changes

Wetlands play a critical role in a healthy, functional environment. Changing the classification system will mean further wetland loss and may result in serious flooding, putting the safety of communities at risk. Wetlands are a natural, cost-effective strategy for protecting downstream properties from floods, adapting to climate change, and retaining water to lessen drought impacts. By changing the classification system, existing Provincially Significant Wetlands could lose their status and un-evaluated wetlands are unlikely to meet the standard for additional protection. This could lead to wetlands being filled in, resulting in loss of habitat and numerous species, decreased storage area for water resulting in decreased flood storage but increased potential for erosion, and poorer water quality. These losses will have detrimental effects on tourism and recreation industries. Loss of wetlands will also result in the necessity of more stormwater ponds which require more maintenance and monitoring than wetlands. The government must be prudent when considering changes like offsetting, which could negatively affect the ability of wetlands to reduce flooding and confuse roles in wetland management and protection between municipalities and CAs.

I recommend that:

· The province re-engage the multi-stakeholder Conservation Authority Working Group and work with the working group to determine the unintentional negative implications of these proposed changes, and develop better alternatives, prior to proceeding with current proposed amendments.

Thank you