Good afternoon, I am writing…

Good afternoon,

I am writing as a Professional Engineer with over 20 years of experience practicing in Ontario as a civil and environmental consulting engineer. My practice routinely supports Conservation Authority (CA) development review and permitting for both urban and rural lands, including floodplain, erosion hazard and shoreline processes across multiple CA jurisdictions.

Support for a Common Development Review Procedure

I support the Province’s objective of establishing a more consistent development review framework across Conservation Authorities. From a practitioner perspective, the current system results in materially different interpretations of similar hazards between jurisdictions, leading to uncertainty, duplicated technical work, and extended approval timelines.

A common development review procedure, particularly one that standardizes technical expectations, submission requirements, and review pathways would significantly improve predictability while strengthening hazard protection outcomes.

Concerns with Proposed Huron-Superior Regional Conservation Authority Boundaries

While consistency is a worthwhile objective, I have concerns with the proposed Huron-Superior Regional Conservation Authority, particularly with respect to boundary logic and operational coherence.

The inclusion of geographically and physically disparate watersheds, i.e. combining southern Ontario conservation authorities (including NVCA and LSRCA) with the Lakehead/Thunder Bay region raises concerns from a hydrologic, shoreline process, and service-delivery standpoint. These regions experience fundamentally different shoreline dynamics, erosion mechanisms, hydrology, climate influences, and development pressures.

From a professional and practical perspective, this grouping does not appear to align with the stated goal of watershed-based governance. A Huron Regional Conservation Authority, without the inclusion of far-removed northern watersheds, would better support consistent and technically defensible hazard review.

Township of Tiny and Shoreline Governance (Page 16 - Municipal List)

I wish to specifically address the inclusion of the Township of Tiny, which is listed on page 16 under municipalities proposed to fall within the Huron-Superior Regional Conservation Authority.

The Township of Tiny is almost entirely shoreline-based, with complex erosion, flooding, and dynamic and non-dynamic beach hazards along Georgian Bay. Development pressure along this shoreline is ongoing and increasing.

In recent years, the Township has attempted to address shoreline hazards through municipal shoreline by-laws and policy instruments, despite limited internal technical capacity to assess coastal and geomorphic hazards at the level required. These efforts have, in practice, resulted in regulatory approaches that appear inconsistent, difficult to interpret, and in some cases more political than environmental in nature. There is also limited transparency or recourse when technical disagreement arises.

In this context, I believe the functionality and role of the Southern Georgian Bay Shoreline Engineering Association (SSEA) should be formally reviewed as part of this provincial initiative.

Including the Township of Tiny and shoreline lands currently influenced by SSEA processeswithin a properly resourced Huron Regional Conservation Authority would significantly strengthen hazard protection by:

placing shoreline regulation within a consistent, technically grounded framework,
reducing reliance on ad hoc municipal policy-making for complex coastal hazards, and
ensuring hazard decisions are supported by qualified technical review with clear accountability.
From a public safety and environmental protection standpoint, this would represent a substantial improvement over the current fragmented approach.

Importance of Maintaining Local Hazard Context

Hazard assessment is inherently site- and system-specific. Shoreline erosion, dynamic beach processes, flooding, and slope instability cannot be effectively managed through overly generalized or centralized approaches.

Consistency should be achieved through standardized procedures and technical guidance, not through the dilution of local and sub-regional expertise. Any regional authority must retain localized technical capacity closely aligned with the physical systems being regulated.

Exclusion of Certain Conservation Authorities - Policy Questions

I also wish to raise a policy-level question regarding the exclusion of certain Conservation Authorities from the proposed regionalization framework, including, for example, NBMCA, as well as other authorities that appear to remain outside the proposed restructuring.

From a practitioner perspective, it is unclear:

what criteria were determinative in excluding certain CAs while consolidating others,
whether excluded CAs are expected to continue operating under existing governance and review models indefinitely, and
how consistency objectives will be achieved where some authorities are restructured and others are not.
Clarifying the rationale for these exclusions—and how consistency will be pursued across both restructured and non-restructured authorities—would help practitioners, municipalities, and applicants better understand the long-term regulatory landscape.

Practitioner-Focused Recommendations

To achieve meaningful consistency while preserving effective hazard protection, I recommend the Province consider the following:

Implement a province-wide Conservation Authority Development Review Procedure, including:
standardized technical submission requirements for flooding, erosion, slope stability, and shoreline hazards;
clear scoping thresholds for studies, peer review, and pre-consultation;
consistent approaches to conditions of approval and clearance.
Establish clear service standards for completeness review, technical review timelines, and escalation pathways where professional disagreement arises.
Maintain localized delivery and decision-making capacity within any regional authority to ensure hazard-specific expertise remains embedded at the watershed and shoreline scale.
Formally engage practicing consultants, including civil and environmental engineers, planners, and geoscientists in the development of review procedures and technical guidance. Consultants routinely navigate multiple CA jurisdictions and are well positioned to identify where inconsistency and inefficiency currently undermine outcomes.
Closing

I support the Province’s goal of improving consistency and predictability in Conservation Authority development review. However, boundary configuration and shoreline governance matter, particularly in areas experiencing sustained development pressure and complex coastal hazards.

Refining the proposed Huron-Superior configuration to a Huron Regional Conservation Authority, strengthening shoreline oversight in municipalities such as the Township of Tiny, reviewing the role and coverage of SSEA, and clarifying the rationale for excluding certain Conservation Authorities would materially improve the effectiveness and credibility of this initiative.

I would welcome the opportunity to participate further in consultation from a practitioner and technical perspective and would be pleased to assist in developing practical, defensible review procedures that improve outcomes for regulators, municipalities, and applicants alike.

Respectfully submitted,

Michelle Dada, P.Eng., Consulting Engineer

MNT Consulting Group Inc.

705-427-0711 | michelle@mntconsulting.ca