JFSA Comments: J.F. Sabourin…

JFSA Comments:

J.F. Sabourin and Associates Inc. is a specialized consulting firm that has been providing services in water resources engineering, environmental management, and land planning to private and government clients in Ontario, Quebec, and further abroad for more than 30 years. Our team specializes in both the technical engineering activities related to natural hazards and the policy interpretation component, through project specific and broader initiatives. Our expertise has enabled us to be considered experts at provincial tribunals, as well as providing third party reviews, and advising on guidelines and policy relating to these areas. Our staff includes an experienced former Conservation Authority Planner to liaise and coordinate development and other environmental projects through municipal and Conservation Authority review processes. This gives us unique and significant insight into the issues, interpretation, and pragmatic application of the Natural Hazards section of the Provincial Policy Statement.

In general, we support the work of Ontario Conservation Authorities as the provincial representatives and technical experts to advise on matters relating to flooding. For them and the municipal approval authorities to do this work well and with confidence, they require clear direction in provincial level policy, and specific language and guidance to ensure they can consistently and appropriately evaluate proposals that relate to natural hazard / flood plain activities. Our comments on the above-mentioned posting are consistent with this position and our experiences over the past 20 years.

Core Element Environment and Natural Resources: Natural and human-made hazards
-ERO 019-8462 Proposal: Streamlined and clarified policy direction for proposals in hazard areas, while continuing to protect people and property in areas of highest risk . Ensure that policies of the PPS are outcome-oriented, and some policies allow flexibility in their implementation provided that the original intent of the policy is upheld.

-Recommendation: Revise terminology, definitions, and direction regarding site alteration in flood plains to accommodate establishment of development lands where the hazard can be safely removed without negative impacts. Details provided in attached document.

-Why: Provide municipalities, landowners and CA’s with up-to-date and defensible policy support to consider currently sterilized lands in settlement areas for additional housing opportunities. Modern water resource engineering software and models can establish where site alterations in the flood plain are effective and appropriate and do demonstrate impacts (if any).
Flood plains should not be protected like natural features. Not all flood plains are the same. Flood plains are a hazard that in some cases must be avoided, but in other situations can be overcome to support housing objectives such as intensification and access to existing infrastructure with capacity, while keeping people and property safe.