Hello, I am writing this…

Hello,

I am writing this comment with the concern that these proposed new boundaries will dysregulate current permitting obligations of conservation authorities in order to cut corners in regional construction development permits. Conservation authority permits are required for development activities in floodplains, wetlands, and watercourses. It was clear in the 2022 boundary changes for the Ontario Greenbelt that 7,400 acres of land was going to be reclassified as settlement sites which would expand their available use for construction despite being previously recognized as vital for land-use protection due tot heir ecosystem services and potential agricultural services. This was a big strip of protected lands near the GTA, as the proximity of these ecological services to urbanized areas is vital for water filtration, flood prevention, natural air cleaning, and many more ecosystems services. (this proximity requirement for ecological services is referred to as the proximity effect change in the article cited below from Liu et al. (2016).) Another big strip to protecting these valuable ecosystems occurred earlier this year with the changes to the Endangered Species Act, which removed protections for particular at risk species habitats from construction development. It is clear given the development of these policy shifts that ecosystem, and animal protections in the province are being removed for the sake of economic development. This is where I have growing concern for the newly proposed boundaries for conservation authorities along with the development of a provincially mandated council that will "aid" in permit approval process. I have personally seen the permitting departments of many conservation authorities, and most agree that they do need more support, but not in terms of making their regionally specific decisions, provincially mandated/led, but in terms of funding and jobs. Permitting construction may take a specific period of time to return results back to construction companies, but that period is required in order to review the regulated environmental standards and protections of a given area. Having a provincial body that has no integrated knowledge of the specific regional environmental and social impacts of a specific construction project can have devastating impacts on communities and our environment.

For example, Hamilton is confined by the well-known Niagara Escarpment, and has older sewage and waste water infrastructure that may not be able to handle excess runoff from the development of a construction development up on the escarpment. Lumping their permitting boundaries in with other Lakeshore horseshoe communities like Toronto means that these specific regional, topographic, and infrastructure considerations have the potential to be overlooked given the comparison to an ENTIRELY different city with entirely different needs. Many conservation authorities have voiced their concerns as they have wanted more equitable support for years, but are not being met with more jobs, resources, and funding, and are instead being met with policy changes that with streamline permits to watershed boundaries that may not be comprehensive to their watershed needs.

I have many concerns as listed above with the proposed new boundaries and their implications for permitting support in conservation authorities, because at the end of the day its as if permitting departments have been washing the dirty dishes for construction companies for years, making sure that they don't develop in floodplains or significant areas, and they've been begging for a dishwasher (more funding and support) from the government and instead the government said why don't we just stop washing the dishes, what could go wrong? Which ultimately is not just inconsiderate of regional societal and environmental implications but it is also sort of disrespectful to the conservation authorities in general. I hope you take these comments, and the comments of Indigenous Liaisons and the comments of conservation authorities seriously in the coming months.