Thank you for the…

Thank you for the opportunity to provide comments on the “Regulation detailing new Minister’s
Permit and Review powers under the Conservation Authorities Act”.

LPRCA has reviewed the proposed regulation and can provide the following comments for the
Province’s consideration.

1. Uncertainty, confusion, and time delays may result in enacting the Minister’s powers
 There is very little information relating to how the Minister will review permit applications,
and what technical information they have in order to review the application in comparison
to a Conservation Authority. Will the Minister utilize the Conservation Authority’s
resources, will they use internal staff or outsource to consultants for review? The utilization
of third-party consultants may add time delays and add additional costs to the process for
which Conservation Authority staff provide a cost-effective service for the review.
 It is uncertain how a Ministerial decision-making process would be faster or more efficient
than LPRCA’s permit approval process. LPRCA over the past several years has greatly
improved the permitting process and in 2023, LPRCA staff issued all permits for
development within 30 days of receiving a complete application. The average permit
turnaround time for a minor application was 3 days in 2023 and 3.7 days for major
applications.

2. Potential increased risk to life and property
 Conservation Authorities throughout the Province have the most up-to-date information
relating to natural hazards including floodplain mapping. It is unclear how an application
would be evaluated by the Minister and whether or not the same criteria utilized by
Conservation Authorities would be utilized.

 Due to liability concerns, if the Minister is to make a decision on a permit application it
should be the responsibility of the Ministry to follow up on the application to complete
compliance inspections and undertake any enforcement requirements if necessary.

3. The broad range of circumstances for which the Minister’s powers could be enacted
 The Province is proposing a broad range of circumstances for which a Minister may enact
their powers, it is suggested that only in extreme and unique circumstances should the
Minister enact their powers.

LPRCA supports the Province’s goals in order to meet housing targets and provide clarity,
transparency and an efficient permit review process for applications. It is important to note that
Conservation Authorities are the leaders in providing technical information and assessment of
risks related to natural hazards, including preventing or mitigating those risks through their
mandatory programs and services. The responsibilities of delivering these services should remain
with the Conservation Authority and only under extreme circumstances should the Minister enact
their powers under the proposed regulation.

Thank you again for the opportunity to provide comments. We appreciate your consideration of
the proposed changes in this submission to identify solutions that will increase Ontario’s
housing supply without jeopardizing public safety.

Sincerely,

Robert Chambers
Chair