The More Homes, More Choice…

The More Homes, More Choice 2019 Bill 108 proposes amendments to 13 different Acts including the Conservation Authorities Act as Schedule 2 (CA Act). The following comments are restricted to the CA Act.
The Act maintains that the purpose is “to provide for the organization and delivery of programs and services that further the conservation, restoration, development and management of natural resources in watersheds in Ontario;
21 (1) For the purposes of accomplishing its objects, an authority has power:
a) to study and investigate the watershed and to determine programs and services whereby the natural resources of the watershed may be conserved, restored, developed and managed”.
This suggests that there is recognition that the monitoring, study, management and restoration of various environmental components of a watershed are critical activities for the management of conditions that impact hazards, drinking water, management of conservation lands and general health and well-being of the environment in which we live, and that supports all human activity including development within Ontario.

One cannot separate environmental conditions from the activities that support human development and growth of the economy. In fact, scientific data and observations as well as insurance claim statistics associated with climatic trends confirm that we need to dedicate even more attention towards environmental conditions.

Conservation Authorities (CAs) are the on-the-ground actors in this work. They monitor the watershed and also act as the operational arm for several Provincial monitoring programs (such as the Provincial Water Quality and Groundwater Monitoring networks, natural heritage and invasive species, etc.). Without CA’s this work would not get done and the data to assess conditions and develop models and innovative solutions would not be collected. Scientific and environmental consultants in Ontario regularly request these data from CAs. CAs also manage the resources and support sustainable development with innovative scientific solutions for low impact development that have been proved to reduce flooding impacts where implemented. CAs also promote behavioral shift in human understanding and environmental awareness, effectively engaging landowners which also helps to shifts the cost of environmental sustainability from Provincial and Municipal sources. The activities of CAs directly support the intent of Bill 108 and limiting the mandate of the Province’s partner and operational arm will have detrimental impacts to the environment as there will be no agency to monitor or address the growing list of emerging issues.

These activities should be included as “in scope” activities in the proposed revised CA mandate as specifically the hazard management and source water protection functions cannot be done without these type of natural resource management tasks.
The proposed mandate suggests that mandatory services should be restricted to:
1. Programs and services related to the risk of natural hazards.
2. Programs and services related to the conservation and management of lands owned or controlled by the authority, including any interests in land registered on title.
3. Programs and services related to the authority’s duties, functions and responsibilities as a source protection authority under the Clean Water Act, 2006.
4. Programs and services related to the authority’s duties, functions and responsibilities under an Act prescribed by the regulations.

It is suggested that the Province recognize the connection between resource monitoring and management and these objectives, and either broaden the proposed mandate or include the following items in the current 4 item list through definition:
• Operations, inspections, maintenance or reconstruction of dams, channels, and erosion and ice control structures
• Flood forecasting and warning (hydrometric monitoring, data management, models, communications)
• Drought forecasting and warning (low water response teams)
• Watershed wide ambient condition monitoring (ecology, species (terrestrial and aquatic), groundwater, climate)
• Emergency operations with municipalities (data support, communications, media, vulnerability assessments; post event assessments)
• Plan input and review for hazards, storm water management and feature protection (planning, engineering; ecology)
• Regulation (permitting and enforcement)
• Watershed planning to input to hazard management and planning decisions; determine effective mitigation measures including protection and expansion of natural areas and wetlands
• Floodline/Hazard and Risk Mapping (hydraulic and hydrologic modelling; base mapping; air photography, field assessment)
• Watercourse, shoreline and slope erosion control
• Hazard land securement
• Training/ Communications and Education
• Scientific research related to risk reduction and hazard mitigation/ adaptation (Low impact development, assessment and valuation of ecological goods and services).

As well, restoration activities (tree planting, wetland restoration, forest management) and monitoring of watershed health have been long standing activities that have ensured that the impacts of land use change on hazards have been minimized.

You cannot take the watershed out of the water. Floodplains cannot be managed if resource managers do not look back up the watershed and engage in review of proposals that may impact the runoff of water. We can watch floodplains get bigger or the Province can with the help of CAs, actively engage in their management and perhaps reduction by taking certain measures. It is clear that climate and weather patterns that produce flooding are on the rise.

The quality and quantity of drinking water cannot be managed if CAs are not looking at the watershed and ensuring that the water to support the supply continues to get where it needs to go. Municipal sources of drinking water are dependent on water resource management activities.

The Province is encouraged that water management is becoming increasingly important and tools and the Act need to be updated to recognize this and not serve instead to constrain serve to constrain the work of CAs. The Province is further encouraged to change the terminology in the Proposed Bill from Programs and services related to the risk of natural hazards to programs and services for the protection and management of natural hazards.

It is hoped that the Province accepts these comments and can acknowledge that the CAs provide many services that promote and sustain the very environment needed for the More Homes, More Choice 2019 Bill 108. The CAs can be viewed as an economical delivery agent in the fruition of the Provincial government’s goals.