The key concerns are related…

The key concerns are related to service continuity/improvement and efficiency, specific to review and approval timelines.

Technical Criteria: The proposed consolidation will combine multiple CAs with various complexity of criteria and mapping available. It is unclear whether existing local criteria will apply and how long the existing criteria, terms of reference, higher level study criteria and next steps will remain valid and honored through the transition. If a new criteria will be established, what will be the basis for the new criteria? (e.g., based on existing CAs most recent, strictest or least strict, CA with the most development, or predominant in terms of land cover compared to others being amalgamated)

The concern is that potential introduction of a new criteria could result in re-work of watershed specific studies or other higher level reports that have already established criteria for future development.

For example, the City of Kawartha Lakes is predominantly within KRCA jurisdiction, while portions are also in GRCA, LSRCA, ORCA. With the proposed consolidation, the City will now be within Huron-Superior RCA (LSRCA member) and Eastern Lake Ontario RCA (KRCA, GRCA and ORCA members). The criteria for LSRCA and KRCA are very different: volume control (25mm vs 5mm); phosphorus targets (zero export with an offsetting policy vs. best efforts to show no increase post-dev); regional storm (primarily Hazel, with one river system using Timmins vs. only Timmins).

Staffing: It is unclear whether current CA offices will remain functioning to support local residents, developers and municipalities. Select CAs that are development driven often have a working relationship with the development industry and municipal partners that exists through the local experienced technical staff. The reality is that things are done very differently across the CAs., including interpretation of the PPS and natural hazards identification. While streamlining the review and approval process is welcomed, there are concerns of a potential loss of the knowledgeable staff that can efficiently administer review and approvals. There is a reciprocal opportunity to service smaller CAs with more experienced staff to facilitate development approval reviews. Thoughtful staffing transition will be key to success of the consolidation.

Boundaries: The proposed CA jurisdiction will now cover spatially large areas of land that do not necessarily exhibit similar properties (soils, temperature, rainfall) and have a greater variation in watershed response. Although this may be addressed as part of watershed and sub-watershed specific studies, this will impact the overall individual CA criteria establishment.

For example, if we look at the Flood Hazard Criteria Zones of Ontario and Conservation Authorities (Feb 2008, https://tcp.mto.gov.on.ca/sites/default/files/2021-09/ctyd%20-%20Highwa…), we see that the Eastern Lake Ontario RCA will cover all three zones (e.g., Hazel, Timmins, 100-yr Regulatory storm events).

Timing: In the near term, as with any change there is plenty of opportunity for delays due to confusion on the part of CA staff regarding criteria changes, workload re-balancing, knowledge of adjusted policies, ect. To mitigate the potential pain for the development industry as the CAs adapt, what are the new target timelines to support the "help get shovels in the ground faster on homes and other local infrastructure projects".