To whom it may concern, I’m…

To whom it may concern,

I’m writing to express profound disappointment and concern with the proposed changes to the Conservation Authorities Act and associated regulations outlined in the ERO postings referenced above (note that this letter has been submitted concurrently). As CAs and municipalities have made clear in the weeks since Bill 23’s introduction, there is a fundamental need to maintain a watershed view on hazard land management in Ontario, and while public statements by Minister Smith ostensibly support a continued role for CAs in this realm, the contents of the posting and the doors opened by items for further and future consideration suggest otherwise.

It seems that CA oversight in development review has been targeted as a major source of delay despite a lack of evidence in support of this assumption, and that the role of CAs protecting Ontarians’ lives and property is not respected by those at the helm. Much of what’s proposed to be eliminated is better considered “green tape” than it’s better-known ideological cousin – restricting MOUs with municipalities to provide environmental planning services, reducing commenting scope on development applications (the extent of what will be permitted remains murky), removing development regulations beyond 30m from large and significant wetlands, and freezing fees (and therefore review and program delivery capacity) at the minister’s discretion are equal parts vindictive and short-sighted.

Proposed future transfers of CA regulatory responsibilities to municipalities is another head-scratching proposition: it’s not likely to speed up approvals or produce more housing starts, unless the minister is banking on a lack of expertise translating into quicker (riskier) decision-making. It also undermines the fundamental principle of CAs in Ontario: that risks, impacts, and mitigation strategies are best determined and developed at the watershed scale. Environmental effects do not stop at municipal boundaries, and to downplay this reality is to set the province back decades.

The proposed removal of permitting requirements for projects already in receipt of CA approval through a Planning Act application may be appropriate if implemented carefully – that said, inspection and final design (which often takes place during permitting) will need to be front-loaded and dealt with through site plan. While it may reduce some administrative duplication, it will do little to expedite overall approval timelines for Planning Act applications – the work will simply take place earlier, opening up the opportunity for oversights and mistakes. It may also have the unintended consequence of uncoupling the building permit process from hazard management. It may also have the unintended consequence of uncoupling the building permit process from hazard management.

Additionally, the request that CAs review their landholdings to identify those suitable for housing is so preposterous so as not to warrant more than a few words in response. Individual submissions by CAs and Conservation Ontario will make clear to misguided partisans in the Minister’s Office that lands held by CAs provide significant ecosystem services and are, largely, natural hazards as defined in the PPS. These also tend to be areas located outside of urban boundaries not suitable for sprawling, expensive suburban development.

I sincerely hope that common sense and a more pragmatic view prevails, and that these myopic policy directions are revised to maintain an appropriate role for CAs in Ontario’s development framework.