the Council of Tay Valley…

the Council of Tay Valley Township is making this submission to the ERO to express concern with the
proposal as presented. Due to the lack of definitions provided for key concepts proposed to
be changed, i.e., “wetland, watercourse, pollution, interference and conservation of land” the
Township is unable to form an opinion at this time on the proposed new regulation.

However, the Township has concerns with the stated intention to update definitions for key
regulatory terms including: “wetland”, “watercourse” and “pollution” if these new definitions
weaken the Conservation Authorities’ ability to protect water and water related resources.

The Township also has concerns with the narrow focus on regulation of “impacts to the
control of flooding and other natural hazards”. This focus seems to leave out protection of
shorelines and the prevention of interference to watercourses or wetlands. These types of
impacts are currently frequently reported to the Township by residents who are concerned
about negative impacts to water quality. The Township passes on the concern to the
appropriate Conservation Authority for investigation and resolution. Who will provide this role
if the Conservation Authority regulations do not allow this service to continue?

The Township agrees with the recommendation to “reduce regulatory restrictions where a
hydrological connection to a wetland has been severed” as this is current practice for the
Conservation Authorities they provide services to our Township – Rideau Valley
Conservation Authority and Mississippi Valley Conservation Authority.

However, the proposal to reduce regulatory restrictions between 30m and 120m of a wetland
does not seem prudent and flies in the face of numerous Environmental Impact Studies
undertaken in the Township that identified impacts that need to be mitigated in those cases.
Generally a 50m setback from Provincially Significant Wetlands is recommended by studies
undertaken in the Township.

The Township agrees with the concept of exempting low-risk development activities from
requiring a permit including certain alterations and repairs to existing municipal drains subject
to the Drainage Act provided they are undertaken in accordance with the Drainage Act and
Conservation Authorities Act Protocol and allowing Conservation Authorities to further
exempt low-risk development activities from requiring a permit provided in accordance with
Conservation Authority policies. However, the term “low impact” has not been defined and
requires careful definition.

The Township requests a future opportunity for comment when the definitions in the
proposed regulation are prepared.