I would urge the MNRF NOT to…

I would urge the MNRF NOT to proceed with this proposed regulation.

As it is written, this essentially completely undermines the role and purpose of conservation authorities. The way this is written, is essentially makes any and all development open to an exemption from permits. This will result in proponents trying to avoid permits and review almost every time and create a bureaucratic mess. Additionally, whether or not the minister chooses to exempt a project, the fact of the matter is that CA's have lots of in house expertise and do not make permitting decisions on a whim. They are based on a careful risk assessment of the project they are reviewing and permitting, and a Minister choosing to exempt a project does not make these risks go away, it just pretends they never existed. The Minister's office DOES NOT have the expertise to make these decisions in a way that CA's do. Additionally, for a government that claims to be cutting back on "red tape", you would think that proponents being able to simply duplicate the permitting process, using up valuable time and expertise would be of concern. There may be conditions where permits need to be reviewed, but they should only be for extreme circumstances, not frivolously, and are probable best handled by conservation authority boards. Let the conservation authorities work and do what they were created to do instead of putting increasing power into the hands of the Minister's office.