Loss of Local Decision-Making: Bill 23 does not work for Eastern Ontario

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Dear Premier Ford, Minister Clark, Minister Smith, and Minister Piccini,

With housing affordability affecting much of Ontario, we understand your government’s target to build 1.5 million new homes over the next 10 years.

Conservation Authorities (CAs) have always supported long-term sustainable growth. In fact, our role is to ensure land-use decisions made today do not impede future growth tomorrow. We accomplish this by ensuring development has minimal impacts on flooding, erosion, slope stability and water quality by guiding development away from natural hazards and protecting the function of natural features. This can only be accomplished when evaluating growth and its cumulative impacts across a watershed, which is the value and service CAs provide to municipalities. Water flows across municipal boundaries and so do the impacts of development.

In Eastern Ontario, CAs have been working closely with municipalities to reduce barriers to development and streamline processes to provide the best service possible to municipalities, communities, homeowners, and developers. For many, this includes modernizing policies and procedures, streamlining approvals, reducing timelines, meeting and reporting on service standards, and promoting pre-consultation with applicants. CAs are not a barrier to growth, but an assurance that growth is safe and sustainable, and we have been a source of cost-effective expertise for municipalities and developers for decades.

We are committed to doing our part to help increase Ontario’s housing supply, but it needs to be accomplished through smart, sustainable growth that will not have detrimental impacts down the road.

We are concerned that some changes proposed in the More Homes Built Faster Act will:

  • Weaken the ability of conservation authorities to continue protecting people and property fromnatural hazards such as floods;
  • Diminish our ability to protect critical natural infrastructure like wetlands which reduce flooding,droughts and improve water quality in lakes and rivers; and,
  • Place new downloaded responsibilities on municipalities related to natural hazards and natural resources that they are unprepared and under resourced to tackle.

Recommendations:

  1. Municipalities should retain the choice to enter into agreements with conservation authorities for natural heritage and water-related plan review services.
    – Recent legislative amendments by this government now require agreements to include defined terms, timelines, and performance measures, and CAs have demonstrated that they can provide these comments to municipalities ina cost-effective and timely manner. CAs are also already prevented by these earlier amendments from commenting beyond natural hazards if they do not have an agreement with a municipality.
  2. Development that is subject to plan approval should not be exempt from requiring a conservation authority permit.
    – The planning process is not sufficient to ensure natural hazard concerns are addressed through appropriate design and construction. This change would also place additional responsibility and liability on municipalities
  3. Conservation authorities should determine which types of developments are deemed “low risk” through their regulations policies.
    – CAs are already able to create exemptions and streamline review processes that areappropriate locally, given watersheds have unique conditions
  4. Maintain “pollution” and “conservation of land” as considerations when conservation authorities are reviewing permit applications but provide a clear definition of each to ensure a consistent approach on how it is applied.
    – Streamlining these definitions will allow CAs to provide consistency to municipalitiesand developers and meet obligations under other pieces of legislation that requirewater quality-related comments from CAs.
  5. Continue to protect wetlands to reduce flooding, provide flow augmentation.
    – Wetlands are critical pieces of natural infrastructure and municipalities cannot affordto build the infrastructure it would take to replicate wetland function to protectupstream and downstream communities from flooding and drought.
  1. Do not freeze fees to ensure growth pays for growth.
    – Recent legislative amendments by this government now require CAs to demonstrate through their budget process that development review fees are offsetting, but not exceeding, program costs.

Thank you for the opportunity to share our concerns and recommendations with you.

Our goal is to support you in creating more housing in Ontario while ensuring changes to Ontario’s land use planning and permitting system do not have unintended and irreversible consequences on the protection of people, property, and natural resources.

We sincerely hope that you will remove the amendments we have highlighted from Bill 23 before it is passed, and that you will reconvene your government’s Conservation Authorities Working Group to work with your Ministry to propose alternative improvements and refinements to conservation authority development review processes.

Sincerely,

Martin Lang, Chair
Raisin Region
Conservation Authority
James Flieler, Chair
Quinte Conservation Authority
Pierre Leroux, Chair
South Nation River
Conservation Authority
Jan O’Neill, Chair
Crowe Valley Conservation Authority
Pieter Leenhouts, Chair
Rideau Valley
Conservation Authority
Eric Sandford, Chair
Lower Trent Conservation Authority
Jeff Atkinson, Chair
Mississippi Valley
Conservation Authority

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