I urge you not to proceed…

I urge you not to proceed with the proposed regulation for the following reasons:

1. The Minister’s new powers would apply to permits for a broad suite of activities pertaining to housing, transportation, economic development, employment and mixed-use developments. This would set the stage for widespread application to most if not all types of development activities requiring a CA permit.

2. CAs are uniquely positioned to arrive at technically-sound, watershed-appropriate permitting decisions based on their ability to model and map flood hazards and their understanding of local conditions and the local planning context. MNRF could only begin to try to replicate this expertise at enormous expense, borne by taxpayers. Worse yet, science-based decisions could simply become political decisions influenced by developers.

3. The permitting role of CAs helps to ensure that development activities do not put communities at risk from flooding and other climate change impacts through loss of wetlands, woodlands, farmland, etc. In the absence of such local knowledge, technical expertise and seasoned judgement, decisions made by the Minister could result in cumulative adverse impacts and increased risk to public safety, and private and public property.

As noted by Ontario’s Advisor on Flooding in 2019, the regulatory power of CAs with respect to permitting is a “critical component” of Ontario’s broader natural hazard management framework, designed to prevent loss of life, minimize property damage, reduce public and private expenditures, and control development impacts. The people of Ontario cannot afford to have this role undermined or circumvented at the behest of development proponents seeking to maximize private profits over the public interest.