Comments on ERO 019 2927…

Comments on ERO 019 2927 Proposed updates to the regulation of development
for the protection of people and property from natural hazards in Ontario

Comments as follows:

1) The definitions suggested for wetlands and hazardous lands as well as that of development activities should be those that were extant before Bills 66 and 23. Any other definitions are not really legitimate.

2) The definition of watercourse includes both an identifiable depression and a defined channel having a bed and banks or sides. By leaving a out the identifiable depression, the tributaries of a stream may be includes forgotten in planning. Planning on a watershed basis obfuscates poor planning where only stream channels are considered and not the entire watershed. Planning must be done for weather events, flooding, and climate change. Hence, there is a need to keep the definition of watercourse more comprehensive.

3) The Government of Ontario must continue to prevent development in stream valleys and in areas by lakes where there are lands susceptible to weather events, flooding, and climate change.

4) Development must continue to be setback 40 m from wetlands and streams. This provides a safe setback and allows for the means to plan for weather events, flooding, and climate change.

5) Allowing certain activities to proceed with out the need of a permit if certain conditions are met leaves the conservation, and preservation of stream valleys, wetlands, and hazard lands open to the whims of outside interests. Permitting always provides oversight and that’s where Conservation Authorities can provide accountability and transparency. This is lacking if an activity is not required to have a permit.

6) Conservation Authorities provided valuable government oversight of development applications before Bills 66 and 23. Limiting the site-specific conditions a Conservation Authorities may attach to development applications prevents a good deal of government oversight of the abuse of natural areas, streams, flood plains, and so-called hazard lands. Such limitations can of themselves be considered hazards to public safety.

7) Maintain the public consulting process such that citizens may comment on and provide public insight into development applications on municipal, regional, and provincial levels. That is a mark of democracy and responsible government.
 
8) Consultations and permitting must always have proper information.

9) Development must not be at the expense of natural areas, streams, flood plains, and even hazard lands with natural values.

10) When speaking of regulatory and financial burdens, is that re development interests or is it referring to the citizens of Ontario? Care must be taken here if the question is about development interests. The interests of the citizens of Ontario are necessarily first and foremost. What may be a burden to some interests may in fact originally have been enacted in the interests of citizens.

11) Streamlining and making processes more efficient must not be at the expense of citizens, municipalities, or the Conservation Authorities. Much legislation, in the past, was enacted in the interests of citizens. The people of Ontario, natural areas, streams, floodplains, and hazard lands with natural values must be considered first over outside interests.

Thank you for the opportunity to comment on ERO 019 2927 Proposed updates to the regulation of development for the protection of people and property from natural hazards in Ontario.