From the Town of Halton…

From the Town of Halton Hills Planning staff:

Thank you for the opportunity to provide comments on the proposed updates to the regulation of development for the protection of people and property from natural hazards in Ontario. Below please find the Town of Halton Hills’ comments:

Staff have no concerns with the proposal to streamline approvals for low risk activities which may include exempting the need for a permit if certain requirements or conditions are met. However, the decision of what type of activity and the conditions that must be met must be determined in collaboration with local Conservation Authorities in order to avoid potential impacts and capture local conditions and constraints.

In light of the proposed changing roles and responsibilities of Conservation Authorities, identifying Provincial standards for spill hazards and floodplain mapping would be helpful.

Staff have no concerns with the proposal to make limits consistent across all Ontario Conservation Authorities while still allowing for local context. Consistency among Conservation Authorities is important, particularly in municipalities located within different watersheds.

Staff supports the proposal that any enlargement to the regulated area must be communicated to the public in an appropriate manner. Conservation Authorities must ensure that local municipalities and the public are well informed of any significant enlargements to the regulatory limits and have the opportunity to provide feedback through the process. Duplication in the effort to map hazards such as by preparing models/mapping as part of municipal planning processes and updates by Conservation Authorities of their model/mapping for areas that have already been studied at the local level should be avoided.

Section 3 of the Regulatory Consultation Guide proposes an exemption for certain developments from requiring a permit under the CA Act. Town staff appreciate the need to explore exemptions, while noting the following:

As with staff comments on other ERO postings, we believe the Conservation Authorities provide the expertise and technical knowledge on matters related to natural hazards. They should therefore be the primary point of contact for advising on matters related to permit exemptions.

Simply exempting an entire municipality could be problematic. Halton Hills falls under the Regulatory Areas of three different CAs, where the impacts of exemptions could vary. For example, the area covered by Credit Valley Conservation is more closely tied to the Town’s current drinking water resources. As a result, close evaluation of potential impacts would be needed before considering permit exemptions.

Municipalities should still seek comment from applicable CAs where an exemption is in place. This would help confirm that there have been no recent changes to the area that could impact development (e.g. unexpected flooding event, storm damage resulting in the removal of vegetation).