Clarification: Please…

ERO number

019-2986

Comment ID

55589

Commenting on behalf of

Kettle Creek Conservation Authority

Comment status

Comment approved More about comment statuses

Comment

Clarification: Please clarify if the regulation will require conservation authorities to deliver all mandatory programs and services or will delivery still be contingent on local capacity and support from member municipalities?

Clarification: Please clarify that MECP will continue to be a funding partner for the proposed mandatory Provincial Water Quality and Quantity Monitoring program.

Recommendation: That the province restore Section 39 funding to 2018 levels and continue to fully fund Source Protection Authority Responsibilities under the Clean Water Act through provincial transfer payments as municipalities do not have the capacity to absorb these program costs.

Recommendation: That the province include passive recreational opportunities (such as walking trails) that are provided free of charge to the public as an eligible mandatory activity on conservation authority lands. Passive recreation on CA owned lands is a cost-effective means of reducing encroachment and other illegal activities and promotes equitable access to green infrastructure.

Recommendation: That completion of the required documents (conservation land management plans and strategies and the watershed-based resource management strategy) be phased in similar to requirements under the AODA where smaller conservation authorities are given more time to comply with new requirements. This will ensure implementation can progress for larger conservation authorities while providing smaller conservation authorities, with less capacity/resources, time to complete these tasks.

Recommendation: KCCA supports allowing flexible agreement arrangements with municipalities (e.g. agreements with multiple municipalities, agreements covering multiple program and services) as this is an efficient use of financial and administrative resources.

Recommendation: KCCA supports the Minister being able to grant an extension for completing a municipal agreement where an authority, with the support of one or more municipalities, submits a written request.

Recommendation: In order to complete transition plans by December 31, 2021 and municipal
agreements by December 31, 2022, final regulations, including the levy regulation are required. A substantial delay in the finalization of regulations may make these timelines unachievable.

Recommendation: That the province work with conservation authorities and Conservation Ontario to prepare sample strategies and management plans or provide training on how existing documents may be revised to fulfill the intent of the regulation.

Clarification: The minimum functions and activities of the Community Advisory Board is to provide advice and recommendations to the authority on strategic priorities, programs and services, additional opportunities for community engagement and community outreach opportunities. However, there is no distinction between mandatory and non-mandatory programs and services. Can the province provide clarification on the Conservation Authority’s Board of Directors requirements to accept/follow or implement the recommendations of the Advisory Committee?

Recommendation: If required to form a Community Advisory Board, conservation authorities’ Board of Directors should be able to develop and approve a Terms of Reference that outlines the composition, activities, functions, duties and procedures that best meets the local needs and available resources. As few requirements as possible should be prescribed to ensure the Community Advisory Board can meet the local watershed needs.

Recommendation: That the minimum number of members be changed from 5 to “5 or 3 where a conservation authority has 10 or fewer municipally-appointed members on its Board of Directors”. Smaller CAs may have difficulty in recruiting and retaining members and providing administrative support to a larger committee, which may further stress limited staffing and financial resources.

Recommendation: That with the support of one or more municipalities, that the CA be able to defer the establishment of the Community Advisory Board until 2023 to allow sufficient time following the development of transition plans, municipal agreement and budget to develop a terms of reference, advertise, recruit and appoint members.

Recommendation: That CAs not be required to enact Part 1 Offences under the Provincial Offences Act
but that the tool exist for those CAs that choose to use it for the orderly and safe use of their properties.

Supporting documents