I am generally supportive of…

I am generally supportive of the proposed changes to Section 28 including a single regulation and policy document for all CAs. I do however have serious concerns about the proposed amendments under Planning Act approvals. Section 28 permits are not a duplication under planning approvals and this is especially the case in rural Ontario. Many of our municipalities are struggling with staff retention in planning and engineering, and they do not have the technical expertise or technology or data to replicate CA services. CAs provide extremely cost-affordable and timely technical services to ensure development is safe and the resultant developments can be insured. Our municipal partners rely on us to provide them with specific data related to hazards and wetlands, which are also hazardous sites. There are developments within our watershed which have proceeded against our advice and the resultant developments have issues with flooding, black mould, etc. This may impact the ability of homeowners to insure these dwellings in the future.

Section 28 regulations and permits should continue to be factored into any planning approvals. Wetlands should not be developed for a variety of reasons; they not only provide flood storage but they are also hazardous in that developments within wetlands will be prone to flooding and may not be insurable in the long-term.

Definitions within the CA Act should be consistent with PPS definitions. This will prevent confusion and frustration for the development community, as well as municipal planning & engineering staff. In some jurisdictions, applying a 30-metre setback from all wetlands will be more restrictive than the policies currently in place. This is a step in the right direction. Section 28 regulations must continue to apply under planning approvals, whether they are severances or plans of subdivision.

Thank you for your consideration.