Comments on Schedule 2 of…

Comments on Schedule 2 of Bill 108 re Conservation Authorities Act - ERO 013-5018

I am commenting on the Schedule 2 of the More Choices Act - Bill 108 -having to do with the "Modernizing Conservation Authority Operation - Conservation Authority Act. My comments as follows:

a) I have read the Conservation Authorities Act - R.S.O. 1990, CHAPTER C.27 - and it already contains sufficient provisions for transparency and accountability. I see no reason to waste legislative time and taxpayers monies amending this Act for transparency and accountability. The Act itself is publicly available in eLaws and that in itself is a public transparency and accountability.

b) I believe the provision of an Investigator is a duplication of provincial practices that is already done by the Government of Ontario i.e. that the Minister can order a financial or forensic audit of Conservation Authority. This has been done in the past with the aid of third party accounting firms qualified to make such audits. Provision of an Investigator is an unnecessary that must not be borne by the taxpayers of the Province of Ontario. It is an extra expense that wastes taxpayer dollars.

c) A Mining and Lands Tribunal is mentioned in Schedule 2 as well as a Mining and Lands Commissioner. The role of the Mining and Lands Tribunal and that of the Mining and Lands Commissioner needs to be communicated and or explained in relation to Conservation Authorities.

d) Conservation Authorities were meant to act locally. The Minister is being given too many provisions to act provincially as laid out in Section 40 (4) The Minister may make regulations. Let the Conservation Authorities do the job they are meant to do without overly interfering with their operations.

e) I have always found Section 33 of the Conservation Authorities Act - R.S.O. 1990, Chapter C.27 to be blatantly unfair to taxpayers and to the Conservation Authorities. I do not believe that Conservation Authorities should be assessed for municipal taxes by the Municipal Property Assessment Corporation. The lands owned by the Conservations Authorities are owned by "We the People of Ontario" much the same as the Crown Lands under the jurisdiction of the Government of Ontario. Therefore, since the lands owned by the Conservation Authorities are owned by "We the People of Ontario", why should land that is already paid for by taxpayers' dollars be taxed a second time - municipally. That is unfair and it is a waste of taxpayers' monies that could be directed to the affairs of the Conservation Authorities.

f) In accordance with provisions outlined in various parts of the More Homes More Choices Act - Bill 108 - when are the unproclaimed parts of the Conservation Authorities Act - R.S.O. 1990, Chapter 27 to be proclaimed?? A long period of time, relatively speaking, has passed since those parts of the Act were legislated. A period of 120 days is mentioned, much, in Bill 108. Perhaps the Minister could have such a proclamation made 120 days from June 01, 2019. Such unproclaimed parts of the Conservation Authorities Act could be proclaimed, separately, at the Ontario Government's leisure.

g) My final comment is that I would like to see the Ontario Government publicly list the Consultants and or any Consultation processes they have gone through. I want to see where my taxpayer dollars are being spent on the Consultants. I also want to know if the Ontario Government actually did use Consultants rather than hearing that Consultations were done without the proof. That is transparency and accountability.

h) Although, this comment is "anonymous" I wish to thank the Environmental Registry of Ontario for the Opportunity to respond in this fashion as both a citizen and taxpayer of this great province.