Comment
1. updating the definition of “watercourse” from an identifiable depression to a defined channel having a bed, and banks or sides
This change in wording will turn the clocks back 10 years and lead to confusion and poor decisions by proponents and decision makers. The current wording was invoked to clarify the importance of headwater drainage systems and to ensure a consistent approach was applied to decision making on these systems. How will a section of a watercourse be addressed that varies in presence of banks? These are prevalent on the landscape where streams flow into and out of small wetlands or swales. Many conservation authorities have adopted a decision framework to both guide how to ensure flood risk does not increase and that development can occur. Adopting this new definition destroys that framework. The end result will be an increased risk of downslope flooding at a time when extreme weather events already increase risk.
2. streamlining approvals for low-risk activities, which may include exempting some activities from requiring a permit if certain requirements or conditions are met (i.e., requiring that an activity be registered with an authority before it can proceed)
Conservation authorities must maintain the ability to identify low risk activities in their watersheds. Landscapes vary too much across the province to create a single list of activities that are of low risk. In fact it may vary within a watershed.
Submitted December 4, 2022 9:54 AM
Comment on
Proposed updates to the regulation of development for the protection of people and property from natural hazards in Ontario
ERO number
019-2927
Comment ID
77804
Commenting on behalf of
Comment status