I adopt the following…

I adopt the following comments from Conservation Ontario:

We are concerned that some changes proposed in Bill 23 will:
• Place new responsibilities on municipalities for natural hazards and natural resources that may lead to inefficiencies, uncertainties, and delays in the development review process;
• Weaken the ability of Conservation Authorities to protect people and property from natural hazards; and
• Reduce critical, natural, infrastructure like wetlands and greenspaces that reduce flooding and protect waters in our lakes and rivers.

Schedule 2 of Bill 23 – subsection 7(2) and associated amendments should be removed in its entirety from the schedule. Complementary amendments to remove 13(2) and 14(1) are also required.
The Province recently confirmed the mandate of Conservation Authorities, which includes regulating development to address the risk of natural hazards. Subsection 7(2) proposes to exempt certain types and locations of development from the regulation process. This could create a two-tiered approach to the protection of people and property. This exemption is contrary to the core mandate of Conservation Authorities and may put people and property at risk.

Advice should be sought from the Conservation Authorities Working Group about development activities that may be suitable for exemption from requiring a permit using existing clauses within Section 28 (3) and (4) of the Conservation Authorities Act. In our view, this approach avoids unintended risks to public safety, properties, or natural hazards.