My comments are based on 30…

My comments are based on 30 years of experience as a consultant working with development industry to obtain approvals for land uses approved under Official Plans. Conservation Authorities take a significant role in this process acting as the environmental review agency for municipalities and issuing permits. I strongly urge the Province to remove conservation authorities from Planning Act approvals and reduce their authority to the issuance of permits for hazard lands for the following reasons:

CA's regularly ignore the municipal policies and Official Plan land use designations with regard to significant natural heritage features and impose their own opinion on significance.

They require EIS reports to be submitted and ignore the conclusions of those reports without any scientific justification or rebuttal of the report findings. The majority of the CA's ecology staff lack experience and objectivity, imposing their own personal bias when making a decision on significance.

The lack of experience results in delays of often years in approvals because staff cannot make a decision and request more information. For example, approval from TRCA on one project in Vaughan took 14 years and 6 EIS reports and during that time the development limit did not change from that staked at the outset of the project. This type of delay is not unusual with CA's within the GTA.

Natural heritage features vary in their significance based on ecology. CA's often refuse development within low quality small natural heritage features regardless of significance. There is no point having a permitting process for wetlands unless you are prepared to issue permits. There is no point demanding an EIS to assess a wetland if you are going to ignore the scientific findings.

CA's have no appreciation for timeliness in approval reviews. Most EIS reports can be reviewed in 2-3 hours by a qualified ecologist/planner. It takes months to get any response on an EIS and usually the response is no we won't accept it without any technical justification. Then you must engage in a length consultation process to define what their issue is and reach agreement on how it can be addressed.

CA's are implementing ecological offsetting policies that require landowners to be hundred's of thousands or millions for the removal of a natural heritage feature all parties agree is not significant and can be removed. I have one client who will have to pay the Nottawasaga Valley Conservation Authority 3.5 Million to remove forest approved for development by the NVCA through a secondary plan process. To put this in contest the NVCA operating budget in 2017 was approx. 5 Million. I appreciate some authorities have funding challenges but this type of gouging is totally inappropriate and is a cost borne ultimately by the purchaser of new homes.

If CA's are to remain in the approvals process beyond the issuance of permits there needs to be specific review parameters incorporating the municipal OP policies and natural heritage mapping as the basis for their comments and requiring them to meet technical criteria in their review that forces staff to provide a scientific review of the data provided. This hopefully will avoid the personal issues staff bring into their reviews.

There needs to be a strict review timetable comparable to the Class EA process that requires a 30 day review period for minor projects and 60 day for major projects.

The CA's need to stop comments on stormwater design issues that are the responsibility of the municipality's that assume the operation and maintenance of the facility. CA comments should only deal with is the capacity of the storm water pond sufficient, does it meet storage requirements for major events and is the discharge design appropriate. One reason for major delays is CA's commenting on all aspects of the design which is a duplication of the municipal staff.

CA staffing requirements and organizational structure needs to be reviewed. Part of their financial problems is being top heavy in senior staff positions who do nothing to help expedite the review and approval process. One experienced manager should oversee at least 10 staff involved in project approvals.

Currently many municipalities use peer review on development applications. This results in a developer paying a municipal peer reviewer and the CA to review the same information and apply the same policies. Often their opinions differ and then the process of resolving the issues becomes length. I recommend unless a permit is needed municipalities just use peer review, which will provide a review from experienced professionals applying the municipal policies and not imposing their personal bias.

CA need to have regard for the need for the agricultural industry to bring lands into production where appropriate. The economics of farming requires larger land bases for individual farmers to make a living. Currently CA so no to any removal of natural features, regardless of the situation.

If the province does not undertake significant measures to control CA's the land use planning approval process will continue to degrade for landowners. The difficulty in dealing with CA's is resulting in a growing opposition by landowners and municipalities which if not corrected will result in reduced economic growth and more violations out of their frustration.