Thank you for the…

Thank you for the opportunity to comment re the proposed changes to the Conservation Authorities and, review of their policies.

My Background...
As a Lake Huron shoreline property owner in Bruce County for 23 years and now, in Lambton County for 19 years, I have realised/seen/experienced no benefit from the existing Conservation Authority governance or policies. As a property tax contributor to their funding for over 40 years, I have realised no benefit. Municipal infrastructure and residential development was already established on these shoreline properties for many years.

From the 'Proposal Background' ....

'Permitting administered by Conservation Authorities helps to ensure that development does not happen in unsafe areas and that it does not worsen the impacts of flooding or erosion in surrounding areas.'
The housing development on mine, and neighbouring properties, happened. The development of infrastructure to support housing development on these shoreline properties, happened. All these years later, these developments remain as they were with minimal to no impact on my family and neighbours' safety or, worsening the impacts of flooding or erosion in surrounding areas. And, many new developments have happened along the shorelines in these communities as well. Furthermore, we have taken it upon ourselves to invest in mitigating approaches to protect ourselves and our investment from possible erosion due to the nature of the shoreline we reside on. And, it is obviously working. However, any further minor development in these properties is being stone-walled by this governance group. Given our vested interest in this property and our desire to age in place, this should not be the obstacle that it presents for us and many other shoreline property owners.

The local governing Conservation Authority established stable slope allowances (SSA), erosion rates, SSA +25 year line and SSA +50 year line based on historical data and mapping activity which is outdated. They apply this data to specific property ranges. Based on 'recession data reviewed from 1935-2007, average annual recession rates were used to determine erosion allowances for various reaches within the shoreline reconnaissance undertaken in 2010. The AARR applied to our property, which does not take into account mitigating measures implemented, implies that we have lost 9 metres over the past 16 years...this has simply not happened. In fact, it would suggest that the residence that has been here for over 50 years should already be in the water - NOT. Based on this, i have been advised that 'based on existing technical information, Authority policies do not permit any new development on the property.' Sounds more like a blanket prohibition than 'permitting'. In this day and age with the technology available, the Authorities should be held accountable to justify these prohibitions with real evidence and current data. Interesting that the Provincial Policy Statement 2005, Sect 3.1.6 'does allow that development and site alteration may be permitted in those portions of the flood and erosion hazard lands where the effects and risk to public safety are minor so as to be managed or mitigated in accordance with provincial standards.' All to say...private stewardship of private shoreline properties should be encouraged and, recognized in consideration of future, size-appropriate development needs. Allowing modest, size-appropriate development, including residential infill, garages, additions, or secondary suites, in conjunction with mitigating measures, promotes positive environmental outcomes rather than accelerating erosion through neglect. Policies should promote solutions, not prohibit them. A review at a provincial level to modernize shoreline policies to better balance environmental protection with real-world land use realities is necessary. Doing nothing and resorting to outdated policies and data mapping is not an option where municipal infrastructure, established roads and communities already exist along these shorelines.

'The important work that Conservation Authorities do to protect people and property from the risks of flooding and other natural hazards will not change.'
In my experience, there has been no work done by the conservation authority to protect me, my neighbours or our properties from the risks of erosion. It is solely been based on private and municipal stewardship. A modernized approach should hold these organizations accountable to report how their local tax payer funding / levies have been used to protect the people and properties they represent from the risks of shoreline flooding and erosion, especially if the funding model is based on assessed property values....shoreline property has an assessment premium loaded on it - where is the value?
Municipal representation in governance is also key. The tax base must be represented to ensure equity and consistency, as well as give a voice to those served.

As for the new proposed boundaries... I dont believe that southern Lake Huron is a good fit with Lake Erie region. Without knowing all the geographical considerations that go into redefining the boundaries, these two Lakes are very different. Possibly keeping Lake Huron as a whole in one region and Lake Erie as a seperate one. Maybe having a Southern Ontario Interior region and a Northern Ontario Interior region. I recognize there are many other interests represented (ie. urban, industrial, agricultural, watersheds, etc) and redefining the boundaries will need to take all into consideration.

Thank you for being open to comments and taking a fresh look at a long-standing establishment that can benefit from a different lens and a reality check.