“Unrestricted growth is the…

“Unrestricted growth is the ideology of a cancer cell.”

I do not agree with many the Province’s proposed changes to the Conservation Authorities Act, particularly splitting what Conservation Authorities do into mandatory and non-mandatory categories. This approach was rejected in the last review, held with wide public consultation, only 2 years ago.

Recommend: Watershed approach needs to be explicitly stated:
If you’re trying to manage water, you need to play by its jurisdiction. Using a watershed approach is the only way to effectively implement services that forecast flooding, provide flood risk reduction, improve water quality, reduce erosion, provide public outreach, etc.
A watershed approach is needed that considers activities throughout the watershed, linking both water and land-based natural resources.

Without a watershed based approach, headwater municipalities lack incentive to develop in a way that doesn’t impact downstream communities.

Recommend: The mandatory and non-mandatory approach should be abandoned:
Although natural hazard protection and management, conservation and management of conservation authority lands, and drinking water source protection are important – they are far from the only important work Conservation Authorities do. And rather ironically, by potentially limiting Conservation Authorities to these services, it limits the ability to do them effectively. This has the potential for making it much more difficult, and less effective to deliver on a combination of watershed-based programs and services that together successfully protect the health and safety of Ontarians.

Not doing these effectively put lives and property at risk. And that risk costs people and the economy financially.

Recommend: That Conserving and Restoring Natural Resources should be added as a high priority service:

Reducing risk of loss of life and damage to property is not just about keeping people from building in hazard zones (flood, erosion, river meander, etc), but managing the watershed to keep those high risk areas from growing. For example, it’s widely understood that wetlands help reduce flooding. But it’s not always appreciated how large that benefit is. For example, in the Nottawasaga Watershed the Minesing Weltands reduces the downstream flood peak by half. Without this wetland, Wasaga Beach probably wouldn’t exist – definitely not in its current form. Southern Ontario has lost 70% of its wetlands, and much of the flood control they contributed. And despite some protective legislation and policy (which should be strengthened and loopholes closed), Ontario continues to lose critical wetlands. Proposed and recently passed legislation make further significant loss a certainty. And this will result in flood and erosion hazard areas growing. And this growth puts people at risk, because it results in flooding areas that were previously safe. Add in climate change and the threat to people’s lives, homes and communities is put further at risk. It should be a time to build up these systems, and increase resiliency to increase extreme flood events. These natural systems, be they wetland, forest, meadow, riparian buffers aren’t just ‘nice to have’ green trimmings – they provide billions of dollars in real ecosystem services – like flood reduction. Engineering these benefits would be prohibitively expensive – if you want to bankrupt Ontario it’s a good way to do it.

Endanger these natural services, and you’ll pay for it.

Likewise protecting areas of high rain/snow infiltration (like forests and natural areas, followed by well-managed agricultural area), critical groundwater recharge areas – help reduce river flooding. Conservation Authorities and their municipal partners have been at the for-front in promoting Low Impact Development – water smart development that reduces the risk of urban flooding, which increasing threatens peoples safety and expensive infrastructure (remember Finch washing out in 2005? – see footage https://www.youtube.com/watch?v=ttSkj2uERf0). Low Impact Development also improves water quality, and reduces the municipalities cost of maintaining stormwater management ponds – which can run into the millions. And in the case of older municipalities which may still have combined sewer systems – reduces the risk of raw untreated sewage flowing into our lakes and rivers – water we drink and swim in.

Recommend: increased efficiencies sharing skilled staff to help member municipalities:
Conservation Authorities provide highly skilled support to their many municipalities, particularly to those smaller rural ones. Sharing these human resources is cost effective, particularly with highly skilled staff such as water engineers, hydrogeologists, biologists/ecologists, planners, and water quality experts. This should be continued and encouraged.

Recommend: Conservation Lands should be Expanded to Reduce Number of Homes and Properties at High Flood Risk:
This spring’s horrific floods have illustrated the terrible human and economic cost of living within flood hazards. Extreme flooding is more common – insurance industry statistics bear this out – impressive since overland flood insurance is rather new, and most people don’t have it.
Unfortunately, many Ontarians live in floodplains, because they built prior to the Conservation Authority regulations that reduce flood risk. Additionally, land-use and climate change are expanding high flood risk areas.

Ontario should follow the lead of other provinces and nations and buy-out people at high flood and hazard risk (like Alberta did after 2013; Quebec proposes; and the Netherlands has done for a while now). The lands should be restored to improve flood capacity, and offer recreational opportunities. This will be more cost effective in the long run than many repeated emergency relief payments.

Recommend: Conservation Authority Services should include Monitoring & Reporting,
Information informs management and Conservation Authorities should continue to monitor water and lands. This information provides local municipalities, the province and federal government with critical information need to make, implement and amend policy and services. Given that many watersheds have impaired water quality, that fails to meet Provincial Water Quality Objectives, particularly for bacteria and phosphorus (which can cause toxic algae blooms), and hydrology is changing do to climate change – continued monitoring is critical to flood prevention, reduction and mitigation, safe drinking water, water budgets and healthy Great Lakes.

Conservation Authorities should also continue to be the local liaison on behalf of the Province for drought management, as they have experience with local stakeholders to pro-actively respond to drought, and co-operate on water takings in a way that minimizes economic and environmental impact (e.g. https://www.nvca.on.ca/Shared%20Documents/Innisfil_Creek_Drought_Manage…).

Recommend: Conservation Authorities should continue to provide outreach and education opportunities to engage residents:

CAs engage hundreds of thousands of youth and adults in:
• outdoor recreation
• learning about the watershed, nature and ways to reduce flood risk, protect their drinking water and restore habitat and water quality;
• outreach and technical assistance to rural and urban landowners through stewardship to protect water quality and quantity through restoration, rehabilitation and natural infrastructure.

Recommend: Conservation Authorities should expand stewardship programs:
It’s not enough to protect Conservation Lands in order to meet Provincial and Watershed restoration targets, such as meeting Provincial Water Quality Objectives like recreational bacteria limits and phosphorus, stream connectivity, reducing thermal impacts exacerbated by climate change, and enhancing biodiversity and habitat for species – both rare and common. These programs help mitigate non-point pollution sources from river-adjacent urban and agricultural lands that lead to poor water quality (high fecal bacteria counts, nutrient loads and low dissolved oxygen).

Since most (usually over 90%) of the watersheds are privately owned, engaging landowner in voluntary stewardship projects is critical to making Ontario a great place to live - with clean, swimmable, fishable, drinkable water, healthy habitats and healthy communities.

Watershed stewardship programs provide landowners and volunteers with technical advice and financial assistance to do projects that improve water quantity, safeguard drinking water, restore habitat, reduce flood and erosion risk, provide enhanced groundwater infiltration, protect agriculture and top-soil, and adapt to stresses posed by climate change. For example:

• Planting native trees & shrubs to store carbon, shade cold-water trout and salmon streams, increase stream bank stability to protect against more extreme storm events

• Increasing forest cover on critical groundwater recharge areas to increase infiltration, reducing flood potential and enhancing river base-flow

• Mitigating on-stream dams (bypasses, bottom-draws, decommissioning) and their thermal stress on cold water dependent recreational fisheries (past projects we’ve done show that even a small dam can raise downstream temperatures 4-6 degrees Celcius, which can warm the water past brook trout’s upper lethal limit of 24 degree Celcius). Over 1.27 million anglers fish in Ontario each year, and contribute $2.2 billion dollars a year in the province. Locally, my watershed supports an important cold and warm water fishery, that provides significant recreational opportunities and tourism (Essa Salmon Festival, See the Salmon Run, etc).

• Protecting and enhancing riparian and coastal wetlands, which are critical for flood attenuation and shoreline erosion protection

• Create healthier waters by reducing nutrient runoff. A warming climate makes conditions for potentially toxic algae growth, and speeds decay - which can lower dissolved oxygen, threaten recreational fisheries and impair beaches. It’s critical to reducing phosphorus runoff - as a limiting nutrient, a single kilogram of phosphorus can grow 500kg of algae (Vallentyne, 1974). Toxic algae blooms (like the one that shut down Toledo’s drinking water intake) are becoming more common. Most rivers in Southern regularly exceed the Provincial Water Quality Objective for phosphorus. A little runoff prevention goes along way when it comes to phosphorus.

• Reducing bacteria runoff and leaching to rivers, lakes and groundwater with agricultural best management practices, and improved septic management. This helps safeguard drinking water - though municipal systems are well protected through Source Water Protection, private wells fail drinking water tests 30-50% of the time. So unsurprisingly, an estimated 90 Canadians die and 90,000 become ill (Health Canada). Between 1974 and 2001, there were 288 outbreaks of water-borne disease. Rural citizens are at increased risk.

Likewise, fecal bacteria runoff/leaching threatens safe recreational. Locally, the Nottawasaga River regularly exceeds recreational bacteria limits, putting the downstream – putting at risk safety and the economy of the very popular Wasaga Beach (the longest freshwater beach in the world) and the Tiny Beaches. Tourism is very important to the community, approaching $1 billion for Simcoe and Grey Country. WATER is the key distinguishing feature of the region (Georgian Triangle Tourist Association, 2007).

• Reduce river-fragmentation due to on-stream dams that impact fisheries and water quality. A study predicted a 50% loss of cold-water trout and salmon fisheries habitat based on a doubling of carbon dioxide scenario (Eaton & Scheller, 1996). Dams, even small ones, cause significant thermal pollution.

Recommend: Provincial Funding should be renewed and expanded to safeguard people:
It is difficult to not to mention that the Province’s financial contribution to achieving its stated prioritization of flood management is at odds with its recent 50% cut to the flood management budget. I assume that this is meant as a download to municipalities or cut to services in other program areas, since it’s difficult to credit that ‘efficiencies’ will be found – since the province’s funding to this hasn’t increased since 1995 (which is effectively a stealth download). This would hardly matter since it’s all the same taxpayer, except it puts those living in watersheds with smaller populations (and consequently smaller property tax bases) at higher risk – and unlikely to receive the same quality of service, safety and risk reduction. Provincial programs should strive for fairness – particularly in regards to public safety.

This $7.4 million in provincial funding cut is penny-wise and pound foolish. And I’ll bet, if service cuts result, that it costs the province, feds, municipalities and Ontarians far more than was saved. Funding should be re-instated and increased so that outdate flood and hazard mapping, common in small Conservation Authorities can be updated, and public safety increased. It is also in the interests of developers, as lack of staff capacity during the review process can result in costly delays. Though the cost of not reviewing development proposals is far more costly.

Conservation Authorities have a variety of responsibilities around flood management in Ontario, that include:
• Forecast flooding and issue warnings
• Monitor streamflow, rainfall and snow packs
• Floodplain mapping
• Manage and operate $2.7 billion in flood infrastructure such as dams and dykes
• Provide planning support and advice to the Province, municipalities and the federal
government to minimize flood impacts
• Regulate development activities in floodplains
• Contribute to municipal emergency planning and preparedness activities as well as recovery activities
• Inform and educate the public about flooding
• Protect, restore and rehabilitate natural cover that contributes to reducing the impacts of flooding

In a related note, cuts to programs like the 50 million trees program are counterproductive to flood management. Tree cover – which has one of the highest rain infiltration rates, and helps reduce flooding. Below 30% forest cover, particularly in the headwaters – and rivers become very flashy – prone to flash flooding and significant erosion. These trees need to be located within the watershed, in order to benefit it (planting more in Northern Ontario won’t help a southern communities). In my local watershed, the Nottawasaga Valley – though the Conservation Authority helps plant between 120,000 to nearly a-quarter-million trees - it does not keep pace with forests lost to develop pressures. With an estimated impact of that program cut, the CA will likely plant 70-80% few trees and the rate of forest loss will increase. Which puts those very developments at risk – as these cumulative changes increase the flood area. (General comparison of infiltration rates by landuse:
https://www.researchgate.net/figure/Generic-summary-of-infiltration-rat…)

Ontario, in partnership with Conservation Authorities, has long been a leader with a flood management system and a source water protection system that are the best in Canada. Cost-wise, all this is done for 95% of the population covered by Conservation Authorities for $30 per Ontario household per year for all the CAs’ programs and services. This only happens with a holistic watershed-wide approach, that includes conserving natural resources.

The Province needs to allow the CAs to develop a more flexible and streamlined budgetary process with the municipalities in order to avoid onerous and inefficient process that will result for CAs and municipalities if core watershed management activities are categorized as non-mandatory and require individual Municipal Council agreement. It also speaks to why a watershed based approach is important, headwater municipalities lack incentive to develop in a way that doesn’t impact downstream communities. For example, why would Mono Township be motivated to do projects (flood reduction, water quality, etc), if the primary beneficiary is Wasaga Beach downstream? The current watershed model enables municipalities to share the costs and benefits.