Whom It May Concern: Thank…

Whom It May Concern:

Thank you for the opportunity to provide input on the proposed updates to the Regulation of
Development for the Protection of People and Property from Natural Hazards in Ontario. The City
of Brampton has reviewed the proposed updates outlined through this posting and offer
responses to the Discussion Questions below.

For Discussion: Improved coordination between Conservation Authorities Act regulations and municipal planning approvals

Section 28 of the Conservation Authorities Act, as proposed to be amended by the More Homes
Built Faster Act, 2022, provides for exemptions for development authorized under the Planning
Act from the requirement to obtain a permit under the Conservation Authorities Act. This
exemption would apply in the municipalities set out in regulation and could be subject to certain
conditions also set out in regulation. Conservation Authorities would continue to permit other
activities not subject to municipal authorization.

The Ministry has not proposed a regulation utilizing this exemption tool as part of this regulatory
proposal but is requesting initial feedback on how it may be used in the future to streamline
development approvals while still ensuring the protection of people and property from natural
hazards. Considerations for the use of this tool include:

1. In which municipalities should the exemption apply? How should this be determined?
All municipalities under the jurisdiction of Conservation Authorities who request exemptions and
can demonstrate that they have the necessary expertise to conduct the reviews previously
carried out by the Conservation Authorities.

2. Which Planning Act authorizations should be required for the exemption to apply?
Site Plan and Draft Plan authorizations should be exempt from Conservation Authority permits,
specifically related to stormwater management and discharges in to regulated watercourses,
provided that there is no gap in the review of these issues once the Conservation Authority
review is eliminated.

3. Should a municipality be subject to any requirements or conditions where this
type of exemption is in place?
Yes, municipalities should be required to respect the Conservation Authority natural hazard
policies and requirements for discharging into regulated watercourses. This can be
accomplished by requiring municipalities to update their stormwater design standards to reflect
Conservation Authority natural hazard policies and requirements.

4. Are there any regulated activities to which this exemption shouldn't apply?
Municipal exemptions should not be provided to "Activities to straighten, change, divert or interfere in any way with the existing channel of a river, creek, stream or watercourse or to change or interfere in any way with a wetland".

The definition of watercourses should exclude roadside and other ditches. This can be
accomplished by each municipality maintaining a map of watercourses, municipal drains and
ditches in a schedule of an Official Plan, Asset Management Plan and in the system mapping
prepared for CLI ECA, in consultation with Conservation Authorities.

Municipalities do not have the resources or expertise to ensure compliance with Conservation
Authority policies and requirements associated with watercourses and wetlands.

The City of Brampton would like to thank the Province for the opportunity to provide feedback and
comments on the proposed changes.

Sincerely,
Michael Won
Commissioner (A),
Public Works and Engineering

Steve Ganesh, MCIP, RPP
Commissioner (A),
Planning, Building and Growth Management