Re: ERO 019-2927 Proposed…

Re: ERO 019-2927 Proposed updates to the regulation of development for the protection of people and property from natural hazards in Ontario

While it makes sense to streamline the approvals process to bring clarity and consistency to the decision-making process that reduces costs, concern remains regarding the proposed approach of restricting the focus of Conservation Authorities to natural hazards.

First there is the unproven assumption that Conservation Authorities (CAs) impede growth, necessitating the removal of their powers to resolve the affordable housing supply crisis.

Restricting their focus to flooding and other natural hazards ignores their essential oversight role related to threats such as pollution. Undermining Conservation Authorities' regulatory ability to protect people, property, livelihoods, and natural heritage areas from natural and manufactured hazards to increase our housing supply is concerning. Removal of "conservation of lands" and "pollution" as part of their permit decision process is highly questionable, as is the failure to identify who will fulfill this oversight role.

The province needs to strengthen rather than weaken CAs role in providing science-based watershed-level planning across the province. These agencies manage water budgets, of both groundwater and surface water, throughout the watershed. They serve a vital role in maintaining healthy ecological systems. They ensure there is enough water for farmers. They safeguard the groundwater aquifers which municipalities rely on for their drinking water systems, ensuring that these aquifers are not over-pumped, are adequately recharged and are free of contaminants.

Removing CAs' responsibility to oversee pollution and land conservation goes against The Clean Water Act 2006. The intent of the Clean Water Act (CWA) is to protect existing and future sources of drinking water, as part of the government's overall commitment to protecting and enhancing human health and the environment. Source protection represents the first barrier in the multi-barrier approach to providing a safe supply of water. The Act clarifies CAs' role in source water protection and their oversight in source protection regions.

Ideally, coordination should recognize and apply the expertise, knowledge, and experience that both municipalities and CAs bring to the planning approvals process. Coordination should not come at the expense of burdening municipalities with hiring staff or consultants to undertake work previously performed by CAs. It is crucial to maintain a total watershed perspective offered by CAs that an individual municipality or consultants would not appreciate.

The province has not provided a viable alternative regarding what body will replace CAs approval role. It is not in the public's best interest to transfer these functions to municipalities that lack the resources and expertise to protect sensitive ecosystems and groundwater aquifers adequately.