Thank you, and good evening.
My name is Ray Orb, and I am the vice-president of the Saskatchewan Association of Rural Municipalities. I am also the reeve of the Rural Municipality of Cupar, in Saskatchewan.
I would like to begin by thanking the subcommittee on Bill C-38 of the Standing Committee on Finance for inviting me here to present our views tonight.
SARM represents all 296 rural municipalities in Saskatchewan and acts as the common voice of rural Saskatchewan.
SARM serves as the principal advocate in representing the municipal governments of the province on priority issues, including the changes to the Fisheries Act being proposed through this bill.
Distinction of waterways. SARM applauded the federal government for the changes to the Fisheries Act that were announced in April by federal fisheries minister Keith Ashfield. The changes to the act provide the long-awaited distinction between vital Canadian waterways that support fish populations and smaller bodies of water that do not house fish. It is our understanding that the amendments to the Fisheries Act will focus protection rules on significant threats to fish and will set clear standards for routine projects concerning smaller fish-free water bodies.
Currently the Fisheries Act applies the same protection to rivers and streams as municipal drains and farmers' irrigation canals. This adds unnecessary costs and extended timelines to routine municipal road construction projects. For example, in 2011, in my municipality, we were involved with a culvert replacement project in a non-fish-bearing area. DFO required us to attain a permit, which caused a time delay, and the overall cost was increased significantly. The culvert accommodated drainage for farmland. There were no fish in the area, but the project was treated as if there were.
If DFO clearly defined waterways to allow an RM to determine whether or not they needed to consult with the department, it would expedite projects where DFO approvals aren't required. This will save RMs time, which is a priority in Saskatchewan, with its short five-month construction season.
In many cases, municipalities have been required to install larger culverts to accommodate the passage of fish when constructing roads around all bodies of water, regardless of whether fish were present or not. The rules need to be clarified to support municipal governments while continuing to protect fish habitat where fish are present.
The changes to the act are welcome news if they translate into allowing routine municipal road construction projects to proceed without unnecessary costs and delays in the future.
Avoiding duplication. SARM is also encouraged by the proposed changes to the Canadian Environmental Assessment Act of 2012, which will establish a new federal environmental assessment regime. We understand that for larger-scale resource projects this will mean that firm timelines will be placed on reviews, requiring that they be completed within two years. We hope these changes will foster increased cooperation between the federal and provincial governments when it comes to the environmental assessment process.
The province of Saskatchewan is experiencing rapid growth with our natural resource sector; therefore, allowing for a more streamlined approval process could mean increased economic activity to our province, which will benefit our members, the province, and the country as a whole.
SARM would hope that in the future a similar approval process could be implemented for municipal infrastructure projects as well. This will reduce the regulatory burden, which will help all levels of government.
Public cost share. SARM would also like to take this opportunity to express our concerns regarding the costs associated with implementing fish-accommodating structures that are required by the Fisheries Act when fish are present. The need for protection of fish and fish habitat is widely supported and is viewed by SARM as necessary to prevent the loss of this valuable natural resource. That said, we are concerned that the Fisheries Act continues to place the onus on the individual or municipality to bear the cost of compliance with the act. This includes the requirement to install larger culverts, and burying them underground in many cases, to accommodate fish movement. These requirements are above and beyond those that would normally be utilized in a typical road construction project, thus adding additional costs.
A good example of these costs comes from the RM of White Valley in the fall of 2011. The RM was replacing a culvert in one of their existing municipal roads that intersected a seasonal running stream. They consulted with DFO. DFO assessed the stream and determined that fish were present. DFO then required the RM to accommodate fish by installing a larger culvert, which in turn added $28,000 to the overall road project costs. The taxpayers of the rural municipality are left to pay the additional costs of the culvert required to accommodate the fish. SARM does recognize the importance and value of protecting fish but believes it is a benefit that is realized by all of Canadian society. SARM would like to ask that the federal government share in these costs that are currently fully absorbed at the municipal or individual level.
In contrast, under the Species at Risk legislation, a landowner discovers that there is an endangered plant or animal living on his or her property. Compensation is paid to the landowner for the loss of the use of the property, thereby recognizing the public benefit. SARM would encourage the federal government to consider providing funding to municipalities and individual land owners for the costs they accumulate while taking measures to maintain fish and fish habitat.
Thank you for the opportunity to appear today. I would be pleased to answer any questions you may have.