I have practiced…

I have practiced environmental planning in various positions at MNR, Conservation Authorities, and municipalities for over 15 years.

Overall, I agree with and welcome the creation of standardized and clearer processes across conservation authorities, which will help provide greater clarity for conservation authorities, municipalities and developers. Every conservation authority is having to create their own policies, application forms, complete application check lists and terms of references. The province should lead this to avoid duplication of resources and provide consistent direction.

The funding system is flawed in that large conservation authorities with small populations receive little funding and do not have the financial resources to have the necessary experts and complete detailed mapping. They do not have the tools to adequately protect life and property from natural hazards in an efficient manner. More populated areas like Toronto are well funded and are able to do the job better. A more balanced approach is need.

However, I do not agree with consolidating 36 conservation authorities into 7. This is likely to undermine local expertise and responsiveness (e.g. ability to go out to a site visit), create chaos, and ultimately working against the outcomes the government aims to achieve.

1. What do you see as key factors to support a successful transition and outcome of regional conservation authority?
- If amalgamation is to occur each conservation authority should remain as a satellite office to ensure staff are there to efficiently serve the public at the front counter and attend site visits.
- Regional offices could serve as any policies that need to be unique to say Lake Erie, Lake Ontario, Lake Huron and Georgian Bay. If there are Great Lakes efforts that could be integrated into watershed and conservation authority planning that may be useful.
- Boundaries should be based on draining to the Great Lakes or a similar body of water such as the St. Lawrence River.
- There should be no demotions.
- Planning, Permits and Enforcement are typically one department. Perhaps having distinct departments for Planning Act applications, enforcement, building permit related inquiries.
- Province should complete engineered flood plain mapping for all settlement areas.
- Create clear guidelines on when development and site alteration are not appropriate. Setting minimum setbacks for wetlands, erosion hazards and floodplains would be helpful. For example, Conservation Halton has a 15 m setback from major valleys and 7.5 m from minor valleys. Consistent with the Greenbelt and Oak Ridges Moraine, a minimum 30 m setback should be applied to wetlands. In many cases the 6 m erosion access allowance is not adhered to. I have seen quite a few building permits approved within 6 m of a steep slope. Better legislation or regulations is needed to provide clear standards that cannot be interpreted. Interpretation leads to different approaches and delays in the planning process.
- Use the best possible science available to map wetlands, particularly in settlement areas. Part of the delay for subdivisions is having to confirm wetland boundaries which cannot be done in winter. Is there an alternative method?
- Provide provincial standardized direction on headwater drainage systems, how to evaluate, how to protect.
- The Conservation Authorities Act should line up with direction in the Provincial Planning Statement (the PPS). The PPS does not permit development and site alteration in flood plains, except for additions, however many conservation authorities permit buildings such as barns and accessory structures.
- O. Reg. 41-24 currently permits accessory structures right beside wetlands and watercourses. Provided standardized and minimum setbacks would help. Only structures such as docks, that must be located along a river, should be permitted.

2. What opportunities or benefits may come from a regional conservation authority framework?
- Province could create standardized terms of references for studies, these must be very detailed and easy to understand. Topics could include floodplain delineation, slope stability assessments, stormwater management, wetland impact, landscaping guidelines.
- Better funding to complete engineered flood plain mapping, wetland and erosion hazard delineation.
- Sharing of experts such as water resource engineers and geoscientists, however they need to be knowledgeable about local conditions.
- Standardized permitting forms, fees and complete application requirements.
- Standardized policies and guidelines - however, these could be put into regulations or a provincial policy.
- Province could create standard conditions for permits, plans of subdivision, plans of condominiums, and site plans.

3. Do you have suggestions for how governance could be structured at the regional conservation authority level, including suggestions around board size, make-up and the municipal representative appointment process?
-Creating a new system will likely create confusion and chaos.
- Perhaps look at other models like the Niagara Escarpment.
- Need to have environmental expertise on the board, not just representatives that support growth no matter the risk to life and property.

4. Do you have suggestions on how to maintain a transparent and consultative budgeting process across member municipalities within a regional conservation authority?
- No. But budgeting should not be based on population. Perhaps it could be based on area. Funding needs to be equal for every conservation authority so they have financial resources and the proper tools to process development.

5. How can regional conservation authorities maintain and strengthen relationships with local communities and stakeholders?
- In person training and education sessions.
- There needs to be recognition that there is room for improvement both with conservation authorities and developers. In many cases applicants are given specific recommendations. They resubmit say a plan of subdivision, in which they have not addressed any or most of the comments from the conservation authority. This results in significant delays and frustration in the development process. Perhaps having specific qualifications or courses completed for those completing the studies or a penalty where it is clear they have not addressed provincial requirements on developing in or near natural hazards.
- Conservation Authorities should have sufficient staff to determine wetland boundaries. In many cases the consultant must do this, submit it for review and approval. In cases such as a simple building permit, the conservation authority should be able to help out an owner. An owner should not need to do an assessment.
- They need to have local offices so they can attend site visits.