By Mike Renzella
The Haldimand Press
HALDIMAND—All three local Conservation Authorities operating within Haldimand County have now voiced their concerns with Bill 23, dubbed the More Homes, Built Faster Act, which aims to build 1.5 million homes provincially over the next decade.
The Press previously reported on concerns from Niagara Peninsula Conservation Authority. Since then, both Grand River Conservation Authority (GRCA) and Long Point Region Conservation Authority (LPRCA) have voiced concerns of their own with the bill, which reduces a CA’s role in the regulatory and permitting process for approving new housing developments in several ways.
GRCA recently sent a letter to Premier Doug Ford to lay out their recommendations for changes. They include:
Allowing municipalities to continue voluntary agreements for review and commenting with Conservation Authorities by removing the clauses in Bill 23 that prevent this from occurring.
Development subject to Planning Act authorizations should not be exempt from Conservation Authority permits, and CA regulations should not be delegated to municipalities.
The multi-stakeholder Conservation Authority Working Group should continue working with the Province to provide solutions for shared goals and objectives.
Conservation Authority development fees should not be frozen since they are based on cost recovery.
Additional time for consultation on the provincial proposals to ensure that the Province, Conservation Authorities, and other stakeholders fully understand the potential short- and long-term implications of the proposals.
“Municipalities rely on the benefits of long-standing conservation authority partnerships. In our view, the proposed changes undermine the core mandate of Conservation Authorities and may put people – and their homes – at risk,” read the letter, which asks for Schedule 2 of Bill 23, which contains the changes impacting CAs, be removed.
While a GRCA meeting to discuss the changes was rescheduled, the meeting’s agenda contained a report on the situation.
“Several of these legislative and regulatory changes will undermine the work done to date, shift responsibilities and liability to municipalities, and increase costs for the municipalities and taxpayers,” read the report.
The report posits that the exclusions will “nullify the core functions of CAs and open up significant holes in the delivery of our natural hazard roles, rendering them ineffective. This will negatively impact our ability to protect people and property from natural hazards, which seem to be more and more prevalent with extreme weather events.”
It projects that such changes could result in longer response times and increased costs for development approvals, due to municipalities’ lack of capacity or expertise in water resource engineering, environmental and natural resource planning, and regulatory compliance. The report outlined the hazards in excluding CAs from offering advisory support: “Many lower-tier and upper-tier municipalities rely on CAs for their expertise … as many smaller municipalities may lack this expertise. CAs provide these programs and services to municipalities in a cost-effective way across the watershed.”
The act also calls for a freeze on conservation authority fees, which GRCA says will “quickly create a program deficit,” as currently CAs operate on a cost-recovery framework. “The GRCA has commenced a fee study to evaluate our current development/permit fees to implement rates more reflective of cost recovery…. We also consult with watershed municipalities and other conservation authorities to ensure our fees are consistent and fair with other similar organizations.”
The act also tasks CAs with identifying owned lands suitable for housing development: “The majority of the land that is owned by the GRCA contains significant natural heritage features or is hazardous land that would not be suitable for development. That being said, the GRCA will incorporate a review of our landholdings for housing as we complete the mandatory inventory.”
The GRCA report also looked at proposed changes for Ontario’s Wetland Evaluation System, expressing concern over who would ultimately be the decision-maker when rezoning existing wetland spaces for potential development: “Removal of wetland complexing is problematic and will lead to a less standardized approach to wetland evaluation.”
While GRCA supports reviewing existing wetland evaluation policies, “this needs to be
based on ecological rationale. Staff suggest that any changes to the technical manual should be carefully vetted by qualified experts,” suggesting the proposed changes “do not reflect the best available science, would allow for more piecemeal assessment of wetlands, and will result in further wetland loss.”
LPRCA also wrote a letter to the provincial government, addressed to the Standing Committee on Heritage, Infrastructure, and Cultural Policy; below are the highlights.
“There’s no question that Ontario has a housing supply and affordability issue that needs to be pragmatically addressed. We support the government’s commitment to streamlining processes and reducing unnecessary barriers to development. We are proud of our proven track record of providing regulatory services that are streamlined and client-centred. We work hard to provide the best customer service to the municipalities, communities, residents, and developers we serve.”
The letter continues, “We are concerned that the proposed legislative changes may have unintentional, negative consequences. Rather than creating conditions for efficient housing development, these proposed changes may jeopardize the Province’s stated goals by increasing risks to life and property for Ontario residents.”
Like GRCA, LPRCA is looking to see the bill changed to allow CAs to provide advice to municipalities “beyond the narrow natural hazards scope set out in the Provincial Policy Statement,” allowing municipalities instead to “select the plan review services they require” as “instead of making the permitting process more streamlined, these proposed legislative changes remove an existing efficiency.”
The letter also states that any development subject to Planning Act authorizations should not be exempt from requiring CA permits. It explained, “The municipal planning process on its own is insufficient to ensure natural hazard concerns are addressed through design and construction. CA permits deal with matters such as building location relative to hazards and floodproofing design elements that are not included in the Building Code.”
