ERO Letter Ministry of…

ERO Letter
Ministry of Municipal Affairs and Housing
777 Bay St, Toronto ON
M5G 2G2

June 25, 2021

Re: Regulatory proposals (Phase 1) under the Conservation Authorities Act (ERO 019-2986)

Thank you for the opportunity to review and comment on Environmental Registry of Ontario posting ERO 019-2986. Please accept this letter in response. The Town of Caledon is pleased to provide initial comments on the Regulatory proposals (Phase 1) under the Conservation Authorities Act. Our comments here should be viewed as subject to Council’s endorsement. Additional or modified comments may be forthcoming upon presentation to Council.

Town staff support efforts to work with municipalities and Conservation Authorities to clarify roles and responsibilities under the Conservation Authorities Act in an effort towards enhancing the achievement of core mandates and fiscal responsibility with public resources.

Staff note,

• Caledon and neighbour municipalities such as Orangeville and Wellington County exchange a significant amount of surface and groundwater supply between shared watersheds and each benefit from the valuable support that Conservation Authorities provide through their science-based activity. If too little priority is placed on maintaining high quality watershed science, stewardship actions and environmental education programs, there exist opportunities within the current list of mandatory and non-mandatory Conservation Authority programs for the creation of significant inequities among Conservation Authorities across the Province and more notably within watersheds that include multiple municipal jurisdictions. As a municipality containing portions of four (4) Conservation Authority jurisdictions, Caledon welcomes opportunities to work with the Province and partner agencies to promote consistency in the areas of service provision, environmental sustainability, development process and protection of our residents and their assets.

• The system approach of the watershed resource management study is valuable in helping ensure that relationships within a watershed are not overlooked, however, it is also important that this broader strategic review of the watershed does not result in overlooking smaller, yet critical, habitats that may be at risk.

• It is appropriately recognized that the management of natural hazards will continue to be an important mandatory role carried out by the Conservation Authorities. The risk and impacts posed by natural hazards are informed by the health of local natural heritage systems. It is important that monitoring the health of natural heritage systems continues as a mandatory program and service with a heightened awareness of climate change. This could possibly be captured through the mandatory resource management strategy.

• The list of non-mandatory programs and services among Conservation Authorities highlights the funding challenges of particular programs and the continuing emergence of natural hazard and natural heritage mandates not previously addressed, prioritized or anticipated. As the effects of climate change continue to become further established it would appear that issues such as invasive species management will have a greater impact than previously accounted for. It would appear that any process for the review of Conservation Authorities roles and core mandates would benefit from consideration of what current or emerging issues might be appropriate for recognition as new core mandates along with those that continue to be of established significance.

• The Town of Caledon is in support of the Provinces call for changes that “will improve the governance, oversight and accountability of conservation authorities, while respecting taxpayer dollars”, however the Town of Caledon does have some reservations regarding the precedent of the Province’s extended oversight of non-mandatory programs and services that are wholly funded by the municipality.

Kyle Munro, MCIP, RPP
Community Planner, Planning Services Team
Planning Department

Tel: 905-584-2272 x.4247
Fax: 905.584.4325
Email: Kyle.munro@caledon.ca