The following comments are…

The following comments are in response to the proposed updates to the regulation of development for the protection of people and property from natural hazards in Ontario. As a part of the Housing Supply Action Plan, the government is proposing to streamline approvals under the Conservation Authorities Act to focus on natural hazards and help meet Ontario’s housing supply needs. The proposed regulation would focus permitting decisions on matters related to the control of flooding and other natural hazards and the protection of people and property.

General comment: The North Bay-Mattawa Conservation Authority (NBMCA) staff support the goal of increasing affordable housing supply. Our programs and services support safe development alongside watershed management and economic growth by taking a coordinated, collaborative and balanced approach. NBMCA will continue our positive working relationship with the province. We recommend that Conservation Authorities Working Group (CAWG) continue to work with the province and other stakeholders. NBMCA participated as a member on the CAWG. NBMCA looks forward to working positively with the province.

1. Proposal: Consolidate the various natural hazard regulations across all 36 conservation authorities (CAs) into one regulation.
Comment:
We recognize this may help provide a more consistent approach across all 36 CAs in regulating natural hazards. However, the consolidated Regulation should be flexible so as to consider and incorporate local watershed conditions, such as differing regulatory flood standards. Within the NBMCA jurisdiction, the current flood event standards used to determine the maximum susceptibility to flooding of lands or areas are the Timmins Flood Event Standard, the 100 Year Flood Event Standard and the 100 year flood level plus wave uprush (described in Schedule 1 of O. Reg. 177/06).

2. Proposal: Update definition of “watercourse” from “an identifiable depression in the ground in which a flow of water regularly or continuously occurs” to “a defined channel having a bed and banks and sides, in which a flow of water regularly or continuously flows”.
Comment:
• Clarity and guidance on the definition of bed and bank should be provided to ensure consistency across all CAs.
• Allow for CAs to create Best Management Practices factsheet to share with property owners and contractors when dealing with drainage.

3. Proposal: Update the regulated buffer around wetlands to 30 metres for all wetlands, now 120 m for Provincially Significant Wetlands.
Comment: Adequate time should be provided for map updates.

4. Proposal: Streamline approvals for low-risk activities, which may include exempting some activities from requiring permits if certain requirements or conditions can be met (i.e. register activity with CA).
Comment:
• Explore the option for a streamlined authorization within the CA where staff can complete a streamlined review based on the eligible activities (for example, where a desktop review can be completed and staff can sign-off on authorization).
• Reduced review timelines can be applied.

5. Proposal: Limit site-specific conditions that a CA may attach to a permit to matters dealing with natural hazards and public safety only.
Comment: Maintain the ability for CAs to include conditions on permits to address the risk of erosion and sedimentation into water features.

6. Proposal: Provide flexibility for a CA to Information/Analysis permits up to 60 months and Information/Analysis extensions as necessary.
Comment: This proposed change is supported.

7. Proposal: Require CAs to have service delivery standards.
Comment: None - NBMCA has developed delivery standards and can update as required.