ERO (Environmental Registry…

ERO (Environmental Registry of Ontario) number 013-5018
Modernizing conservation authority operations-Conservation Authorities Act

Thank you for the opportunity to comment on the Conservation Authority Act and how Conservation Authorities operate.
Conservation Authorities play an important role in the management of water resourses and in protection of people and property in a relatively small portion of Ontario but where the majority of Ontario residents, live, work and play.
Having many years of experience working with Conservation Authorities it has been my experience that there are inconsistencies between what each CA delivers or prioritizes in services, or believe is their responsibility to deliver or are simply creations of opportunity supported by municipal levy.
There exists a duplication of services and additional burdens of cost and project delay when a proponent finds an application for development as an example redirected for CA review. Properly coordinated and with information sharing technologies there should be no reason to involve CA’S in this process once mapping is completed and shared with local and regional Municipal planning departments.

1. Disentangle the broad based areas of involvement as in itself CA’s are a real impediment (red tape) to timeliness, development and growth. Define “Core Mandate” supported by Drummond Report 2012 – 13-2, 13-7, with so many different groups
2. Powers of Authorities needs to be reviewed, focused on properties they own and with agreement of the supporting Municipalities
3. MOA’s with Municipalities for services beyond core mandated Role, specific services to Municipalities benefit
4. Revisit the name “Conservation Authority” Does Sudbury have it right? “Conservation Sudbury”- RENAME, remove the name “Authority” ie “Grand River - Conservation Services” or “Toronto Region water resource and Conservation Services” as examples.
5. Establish an arms length, balanced, training and orientation program for new members (Directors) (could be digital) prior to individual and specific CA orientation.
6. Base Levy restricted to CoL or CPI indexed-inflation rate index?) for core mandated services. All other projects, programs on contract basis or through contract, donation or other source funding
7. CVA Levy application, review, reconfigure, scrap present model while making sure Levy, mandated not to support “pay to play” facilities-parks. They should be entirely self funded, self administered.
8. Review money being spent from levy to be members of Conservation Ontario. In effect municipal money is being spent to lobby for more programs and power costing Municipalities more in services and levy not essential, not part of core mandate of the CA’s
9. Review setbacks and restrictions, ie 1:100yr, other CA 1:250yr flood mapping, ignores upgrades to infrastructure, drainage, culverts, bridges, Setbacks from Woodlots, etc. Why are there inconsistencies between CA’s and why if infrastructure has been improved to minimize risk are the areas of setback increasing
10. Amalgamate CA’s for efficiencies, (Source water protection it was done) also referred to in the Drummond report
11. Separate land holdings and parks from core business responsibilities (privatize?)
12. Mapping, shared with Planning, adopted but Planning is one stop shop. Clear definitions, not convoluted by open ended language, ie new information, screening areas, etc. Too much overlap, delays and cost
13. Provincial Policy Statement: Review by present Gov’t is necessary –to fit the Premiers “Open for business” principles. The Provincial Policy statement sets the table and does not fit the Open for Business mantra.
14. Create an independent Commission (Conservation Services Advisory Council) appointed by the Public Appointment Secretariat to review policies and practices, efficiency opportunities, new programs, (ie Policies and Procedures for Conservation Authority Plan Review and Permitting Activities)to make recommendations to the Minister (similar to the Fish and Wildlife Heritage Commission)