Dear Minister, There is a…

Dear Minister,

There is a Canadian Tire close to where I live, that built their warehouse in a floodplain. The local applicable Conservation Authority was essentially bullied into allowing them to do so, since businesses and municipalities stifle whatever political will and resources would be available to prevent such a misdirected development. Of course, that warehouse now gets flooded frequently - and guess who foots the bill for fixing it? It is WONDERFUL that we have an assigned body (Conservation Authorities) whose purpose is to govern development in areas like that to PREVENT damage to property and potential loss of life.
I grew up in a small town; I recall a local politician who wanted to build a certain building in a low-lying area next to a creek and playground. It was both the then-MNR and the local Conservation Authority who gave a resounding 'No' to that project, despite the proponent's huffs, puffs, consternation, complaining, and accusations of being anti-development - and thank goodness that project didn't go forward, because less than 10 years after that whole mess that entire area was under 6 feet of water. Lesson? People shouldn't get to build somewhere just because they want to and they have the money. This isn't China. It is GOOD to have controls on development; we already have so little natural areas left - if in the past we let people build wherever they wanted to, whenever they wanted to, our landscape would be an unrecognizable mess of nothing but suburbs and concrete.
One of the CAs' main mandates is to manage/control development in hazard areas (slopes, wetlands, floodplains etc.) to help prevent loss of life and limit property damage; this naturally lends itself to also helping conserve the biodiversity within these lands.
I ask you to refer to the Government of Canada Map - "Natural Hazards of Canada: A Historical Mapping of Significant Natural Disasters"; however the hard copy poster version (which I own) is easier to read than the version of it I can find online. The map shows the financial costs and loss of life from various natural disasters across Canada over time - tornados, landslides, ice storms, etc., including floods. You will see that the economic damage and loss of life from floods in Ontario is rather limited, following the creation of Conservation Authorities in the 1960's. This is an especially stark contrast to Canada's other provinces, where the high economic costs and loss of life from floods has continued since the 1960's onward...And today, our own provincial government seeks to continue to limit the abilities of the body assigned to protect us from ourselves by these proposed changes to the Conservation Authorities Act? Why - because you hope that the proposed changes won't cause too much damage? Hope is not a plan, politicians. Genuinely CONSULT with qualified planners, hydrologists, geologists, geomorphologists, and biologists about the potential and/or guaranteed effects of these changes before you default to just giving development proponents and businesses what they want because they want it and will pay for it. Nobody's perfect, but please let the Conservation Authorities do their jobs and GIVE THEM THE RESOURCES TO DO THEIR JOBS WELL - just because some businesses don't like it doesn't mean it doesn't work.

Thank you for allowing me to comment on the proposed changes to the Conservation Authorities Act. I have several outstanding concerns regarding the significant limitations of the language in these proposed changes. CA’s work protects and enhances water quality, water flow, aquatic life and community health, creating additional benefits of a healthier living environment for people as well as the natural environment.

The value of CA’s guidance and expertise that they provide should not be overlooked. In response to the proposed recommendations made to” modernize CA operations”, there are a few concerns as found within documents ERO No. 013-4992 and 013-5018:

1. The absence of reference to the critical importance of protecting and rehabilitating natural infrastructure alongside built infrastructure;
2. The proposed constraints and changes to the role of CAs in permitting and municipal plan review and the limitations of their overall mandate; and
3. The absence of watershed management planning and investment in watershed science and the collection of data.

Concern 1: The absence of reference to the critical importance of protecting and rehabilitating natural infrastructure alongside built infrastructure I am disappointed to see a continued sole emphasis on improving the built infrastructure of the Province without the careful consideration of Ontario’s greatest resources – its natural infrastructure of land and waters, wetlands, forests and floodplains. This was especially noticeable within EO No. 013-4992 where it is stated “As more extreme weather events occur that threaten our homes, businesses and infrastructure…” By targeting the health and resiliency of the Province’s natural infrastructure to better manage water, sediments and nutrients as an equally important priority, this approach lessens the pressure and reduces potential damage on built infrastructure. This approach should be rigorously reviewed given that degraded natural infrastructure resulting in massive sedimentation, erosion and catastrophic flooding can lead to damage of built infrastructure.

Concern 2: The proposed constraints and changes to the role of CAs in permitting and municipal plan review and the limitations of their overall mandate According to EO No. 013-4992, the Province is seeking to streamline and concentrate CA development permitting and their role in municipal plan review. Alterations to the regulation include: “Exempt low-risk development activities from requiring a permit including certain alterations and repairs to existing municipal drains…”; and “Allow conservation authorities to further exempt low-risk development activities from requiring a permit provided in accordance with conservation authority policies”.

I strongly suggest that the Provincial Government explicitly defines the term “low-risk development” in order to ensure these thresholds are understood in greater detail, and to better understand the potential consequences of this request. Multiple, small-scale, “low-risk” developments have cumulatively led to major impacts on water volumes, water quality and degraded habitat. One of the greatest strengths of Conservation Authorities is their role in regulating development and floodplains so people are safe and costly damages are avoided from all activities in and near floodplains and wetlands.

Concern 3: The absence of watershed management planning and investment in watershed science and the collection of data. Throughout both of the reviewed documents, the term “watershed” was worryingly absent whether intentionally or not. It is a fact that we cannot manage the quality and quantity of our aquatic resources if we are not considering the entire watershed as a whole. Watersheds are the fundamental units of management and has been demonstrated by the most rigorous science available. This contextual management of water resources provides the best pathway in managing balance between public good and private interest: a key role of government. Monitoring of water flow, groundwater recharge and other factors are critical for ensuring sound, factual and rational management of water resources.

Ongoing watershed streamflow and water monitoring before, during and after an event provides the necessary information to understand the watershed’s response to events and where the flood and erosion risks have formed. Additionally, watershed technical studies provide valuable input to municipal land use plans, future infrastructure design, regulation of development in and near floodplains, support for emergency response, and flood line maps. Without up to data, to the CAs they will no longer be able to “deliver on their core mandate of protecting people and property from flooding and other natural hazards” in the face of a rapidly changing climate. Experts are already recognizing that our regional and 100-year flood frequencies are changing with enormous implications on protecting people and property, as witnessed in the recent Muskoka floods.

The benefits of these long-sighted programs are often overlooked as it is only when these regulations are ignored do people comprehend the importance of these modern approaches to development and the value of the proactive work and services of Conservation Authorities. It was demonstrated in the 1990s and early 2000s during the previous activities in watershed planning that Conservation Authorities are perfectly situated to expedite and coordinate these studies since they are linked both to their local watershed municipalities and to Provincial interests.

I believe that this is still the case given that Provincial agencies are no longer in the business of active management of the environment or natural resources. In its submission to the 2001 O'Connor Inquiry into the Walkerton contaminated water tragedy, Conservation Ontario made the argument that, "Watershed management is not so much about managing natural resources, but about managing human activity as it affects those resources. The drainage area of the river provides the natural boundary for managing and mitigating human and environmental interactions. Because human activity includes actions by governments, municipalities, industries and landowners, watershed management must be a cooperative effort. Effective watershed management can prevent community water shortages, poor water quality, flooding and erosion. The expense of undertaking watershed management is far less than the cost of future remediation."

Thank you for the opportunity to provide input at this stage of the process.