First, we understand that the Ministry of Natural Resources and Forestry (MNRF) is working on a summary document to help the public understand the proposed amendments to the Conservation Authorities Act (CAA) contained in Bill 139. As of the date of this letter, this additional explanatory information is not publicly available and the current deadline for comments is June 30, 2017. The public will better informed about the implications of the proposed amendments with the explanatory document in hand. And, as the Environmental Bill of Rights, 1993 (EBR) provides for “means by which residents of Ontario may participate in the making of environmentally significant decisions by the Government of Ontario” (s2(3)(a)), effective public participation is facilitated by ensuring there is adequate time to consider the potential impacts of the proposed amendments.
Second, as Bill 139 contains more than simply amendments to the CAA, consideration of the impacts has the potential to be complex and warrants more than 30-days for the public to be able to effectively provide feedback.