Hello, I am a Civil Engineer…

Hello, I am a Civil Engineer working for municipal government here in Ontario. The Proposed Changes to the Ontario Heritage Act and its regulations: Bill 23 (Schedule 6) - the Proposed More Homes Built Faster Act, 2022 is a huge violation of environmental protection and preservation and will cause serious problems for flooding and natural ecosystem destruction for generations to come if it is passed. Please do not pass these changes and instead please consider the impacts on future people and living creatures in Ontario.

According to Conservation Ontario, Bill 23 would have the following devastating effects:
• place new responsibilities on municipalities for natural hazards and natural resources
that may lead to inefficiencies, uncertainties and delays in the development review
process;
• weaken the ability of conservation authorities to protect people and property from
natural hazards; and
• reduce critical, natural infrastructure like wetlands and greenspaces that reduce
flooding and protect waters in our lakes and rivers.

The proposed changes will not achieve the objectives that the government is looking for in order
to quickly address the housing crisis. More likely, they will create additional delays and
increased costs.
Municipalities have successfully relied on the benefits of long-standing conservation authority
local watershed science to guide decision-making. The proposed changes to delegate CA
regulatory responsibility to individual municipalities are contrary to the core mandate of
conservation authorities and may put additional people - and their homes - at more risk. The
ability of conservation authorities to regulate development in all hazardous areas is critical for
successful emergency preparedness and to prevent the worst outcomes.

I believe the following changes must be made:
1) Allow municipalities to enter into agreements with conservation authorities for review and comment on development applications such as natural heritage and water resources plan review.

2) Development subject to Planning Act authorizations should not be exempt from requiring a conservation authority permit and conservation authority regulations should not be delegated to municipalities. The ability of conservation authorities to regulate development in all hazardous areas is critical for successful emergency preparedness and to prevent the worst outcomes.

3) The Multi-stakeholder Conservation Authority Working Group needs to continue working with the Province to implement changes.

4) Development needs to pay for development. Putting a freeze on CA development fees will create larger issues in the future.

5) Careful consideration is required when identifying CA lands to support housing development. Conservation authority lands protect against flooding and erosion, contribute to public well-being as well as protect important sources of drinking water and biodiversity. They also contribute to climate change adaptation measures by capturing emissions, cooling temperatures and protecting water quality. Regardless of the source of funding for the lands, clear policies are needed to protect
these locally significant conservation lands and land use should only be considered for
housing in exceptional circumstances. Special considerations related to zoning, natural heritage, integration of provincial and municipal owned land or publicly accessible lands and trails are also included. Process improvements are proposed to enable CAs to sever and dispose of land that does not meet their requirements for ownership.