November 10, 2022

In an effort to build 1.5 million homes in Ontario over the next 10 years, the Provincial Government is proposing a series of changes to legislation under Bill 23. This will directly impact Conservation Authorities and their ability to provide science-based watershed advice for the purpose of protecting communities from environmental hazards and preserving vulnerable ecosystems and valuable public green spaces.

Brad McNevin, CAO says, “We want to do our part to help the government meet its housing goal, but the proposed changes outlined in Bill 23 would have many serious, negative impacts to our environment which would contribute to issues with water quality, public safety, increased taxes, and a higher demand for new infrastructure and maintenance.”

Conservation Authorities across the province are concerned that some changes proposed in the More Homes Built Faster Act will:

  • Place new responsibilities on municipalities related to natural hazards and natural resources that may lead to inefficiencies, uncertainties, and delays in the development review process;
  • Weaken the ability of conservation authorities to continue protecting people and property from natural hazards;
  • Reduce critical and natural infrastructure like wetlands that reduce flooding and protect waters in our lakes and rivers; and,
  • Be unable to perform a review and commenting role on development applications as a ‘municipal’ or ‘other’ program or service for prescribed Acts. The Acts proposed to be prescribed in the regulation include:
    • The Aggregate Resources Act
    • The Condominium Act
    • The Drainage Act
    • The Endangered Species Act
    • The Environmental Assessment Act
    • The Environmental Protection Act
    • The Niagara Escarpment Planning and Development Act
    • The Ontario Heritage Act
    • The Ontario Water Resources Act
    • The Planning Act

These services include natural heritage systems management programs and policies that have exceptionally consequential impacts on conservation authorities' ability to achieve their core mandates including the protection of people and property from flood hazards as well as the protection of sources of drinking water.

McNevin adds, “Conservation Authorities work closely with local Municipalities who rely on the benefits of our long-standing partnerships. In our view, the proposed changes undermine the core mandate of Conservation Authorities and may put people – and their homes – at risk.”

To avoid unintended consequences, we request the removal of Schedule 2 of Bill 23 and changes to the Conservation Authorities Act that limit the ability of Municipalities to enter review and commenting agreements with Conservation Authorities and those that delegate Conservation Authority regulations to Municipalities. We offer instead the following amendments for consideration:

  • Allow Municipalities to continue voluntary agreements for review and commenting with Conservation Authorities; this means removal of the clauses in Bill 23 that prevent this from occurring.
  • The current model enables Municipalities to use existing expertise within Conservation Authorities to fulfill responsibilities for natural heritage and water resources, while saving time and money for applicants.
  • Development subject to Planning Act authorizations should not be exempt from Conservation Authority permits, and CA regulations should not be delegated to municipalities. This approach could result in building permits issued in error and other unintended results. The watershed, not municipal boundaries, should continue to be the scale used to assess natural hazards.
  • 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.

If you are concerned about the changes brought on by Bill 23 and would like to have your say:

  • Appear before, or make a submission to, the Standing Committee reviewing Bill 23. Submissions are due by 7:00 PM on November 17, 2022. Learn more:
  • Submissions can also be made to the Environmental Registry of Ontario posting. The deadline is November 24. To submit a comment:

Quinte Conservation is a community-based environmental protection agency. It serves 18 municipalities in the watersheds of the Moira, Napanee and Salmon Rivers and Prince Edward County. It provides cost-effective environmental expertise and leadership. Quinte Conservation’s main goal is to create a sustainable ecosystem where people and nature live in harmony. More information about Quinte Conservation is available at


For more information contact:
Brad McNevin, CAO (613) 968-3434 ext. 103