2026-2029 Business Plan - Niagara Escarpment Commission (NEC)
Annual Business Plan 2026- 2029 To provide for the maintenance of the Niagara Escarpment and land in its vicinity substantially as a continuous natural environment, and to ensure only such development occurs as is compatible with that natural environment. Niagara Escarpment Commission An Agency of the Government of Ontario Contents…
Annual Business PlanTo provide for the maintenance of the Niagara Escarpment and land in its vicinity substantially as a continuous natural environment, and to ensure only such development occurs as is compatible with that natural environment. Niagara Escarpment CommissionAn Agency of the Government of OntarioContents1. The Niagara Escarpment1. 1 Executive Summary2. The Niagara Escarpment Commission (NEC)2. 1 Mandate3. Resources to Deliver3. 1 Budget3. 1. 1 NEC – Other Funds3. 2 NEC Organizational Structure3. 2. 1 Organizational Structure4. Priorities for 2026-20274. 1 Natural Resources Management and Economic Development4. 1. 1 Modernize Legislation, Regulations and Policies4. 1. 2 Communications and Outreach4. 1. 3 Outdoor Recreation Opportunities4. 1. 4 Monitoring the Niagara Escarpment4. 2 Service Delivery Excellence and Modernization4. 2. 1 Fiscally Responsible Service Delivery4. 2. 2 Responsive Customer Service4. 2. 3 Business Process Improvements4. 2. 4 NEPDA Compliance and Enforcement4. 3 Organizational Leadership4. 3. 1 Attraction, Retention and Employee Engagement5. Performance Measures and Annual Performance Targets5. 1 Financial Measures5. 2 Customer Satisfaction5. 3 Internal Processes5. 4 Commissioner Engagement6. Risk Assessment & Mitigation Strategies6. 1 Strategic Risk: Reputational6. 2 Strategic Risk: External Environment6. 3 Operational Risk: Legal6. 4 Operational Risk: Financial Resources6. 5 Operational Risk: Human Resources6. 6 Operational Risk: Information & Information Technology6. 7 Operational Risk: Climate Impacts6. 8 Operational Risk: Program Delivery7. Inventory of NEC’s Artificial Intelligence (AI) Use7. 1 AI Use CasesAppendix 1 – Ongoing Legislative & Policy ComplianceAppendix 2 – Municipalities within the NEP Area1. The Niagara Escarpment1. 1 Executive SummaryTheNiagara Escarpment Commission (NEC)operates as a regulatory agency under theMinistry of Natural Resources (MNR), dedicated to maintaining and enhancing the Niagara Escarpment while enabling compatible development across one of North America’s most significant natural landmarks. The Commission administers theNiagara Escarpment Planning and Development Act(NEPDA) through a 17-member governance structure representing public and municipal interests. The business plan for April 1, 2026, to March 31, 2029, establishes the Commission’s strategic response to growth pressures in a region projected to exceed 14 million residents by 2051. The plan addresses critical challenges, including high staff turnover, aging legislative frameworks, and service delivery expectations, while delivering on the agency’s mandate as delegated by the Minister. The plan advances three strategic priorities throughout the planning period. Natural Resources Management and Economic Development encompasses legislative modernization initiatives and support for compatible outdoor recreation opportunities. Service Delivery Excellence centers on enhanced client responsiveness and the implementation of streamlined digital service platforms. Organizational Leadership focuses on comprehensive talent management strategies and succession planning frameworks to ensure operational continuity and workforce stabilization. The Commission operates with a budget forecasted to increase from $2. 97 million to $3. 14 million over three years, supporting 24 full-time equivalent positions across Georgetown and Owen Sound offices. As a non-revenue generating agency, all funding is provided by the Ministry of Natural Resources. Performance measurement utilizes the Balanced Scorecard methodology, establishing key performance indicators across financial stewardship, customer satisfaction, internal processes, and Commissioner engagement. Risk assessment identifies medium-level concerns, including staff turnover and IT system vulnerabilities, with comprehensive mitigation strategies addressing each category. The plan positions the Commission to fulfill its mandate while adapting to modern service delivery expectations through enhanced operational efficiency, legislative modernization, and strategic technology integration. 2. TheNiagara Escarpment Commission (NEC)The Niagara Escarpment Commission (NEC) was established in 1973 as a regulatory agency operating at arm’s length from the provincial government. It functions in accordance with theNiagara Escarpment Planning and Development Act(NEPDA) and the Ontario Government’s Agencies and Appointments Directive (AAD). The Commission is composed of 17 members appointed by Order-in-Council: nine members, including the Chair, represent the public at large, while eight members are municipally sponsored and represent the counties, cities, and regions within the Niagara Escarpment Plan (NEP) area. The NEC reports to the Ontario Legislature through the Minister of Natural Resources. Commission meetings are typically held on a monthly basis to consider development permit applications, land-use proposals, policy items, and amendments to the NEP. Meetings are open to the public and conducted in a hybrid format, combining in-person sessions at the NEC’s Georgetown office with virtual participation via Microsoft Teams. For a current listing of Commission members, please visitNEC’s website – Commission Biographies. The NEC operates according to the principles of professional public service, emphasizing transparency, fairness, inclusivity, diversity, anti-racism, and thoughtful stewardship of public resources. 2. 1 MandateThe Commission is responsible for its functions as set out in theNiagara Escarpment Planning and Development Act(NEPDA), including promoting the NEPDA and the Niagara Escarpment Plan (NEP), administering the Niagara Escarpment Plan (NEP) and operating system of Development Control. Since approval of the NEP, its f decision-making on application for Development Permits have been the Commission’s ongoing responsibility, as delegated by the Minister. The Commission undertakes compliance monitoring, investigations, and enforcement activities to ensure adherence to the NEPDA and NEP. The Commission participates in hearings on development or planning proposals as necessary and serves as a commenting agency under thePlanning Act and the Environmental Assessment Act. The Commission also provides advice, input and recommendations on NEP amendments and Park Management Plans for the Niagara Escarpment Parks and Open Space System (NEPOSS), which includes publicly owned land in the NEP area. The Commission supports NEPOSS implementation and undertakes land stewardship, research, and communication activities. The Commission engages, consults, and cooperates with Indigenous peoples and communities across the Niagara Escarpment Planning Area. The purpose of the NEPDA is:“To provide for the maintenance of the Niagara Escarpment and land in its vicinity substantially as a continuous natural environment, and to ensure only such development occurs as is compatible with that natural environment. ”The NEP was established under the NEPDA and serves as a framework of objectives and policies to strike a balance between development, protection and the enjoyment of this important landform feature and the resources it supports. The NEP shares the same purpose and objectives as the NEPDA and seeks to protect the geologic feature of the Niagara Escarpment and lands in its vicinity substantially as a continuous natural environment while allowing for compatible development. The objectives of the NEPDA and NEP are:To protect unique ecological and historical areas. To maintain and enhance the quality and character of natural streams and water supplies. To provide adequate opportunities for outdoor recreation. To maintain and enhance the open landscape character of the Niagara Escarpment in so far as possible, by such means as compatible farming or forestry and by preserving the natural scenery. To ensure that all new development is compatible with the purpose of the NEP. To provide adequate public access to the Niagara Escarpment; andTo support municipalities within the NEP Area in the exercise of the planning functions conferred upon them by the Ontario Planning Act. TheGreenbelt Actrequires a review of the Greenbelt Plan every 10 years, in coordination with a review of the Niagara Escarpment Plan (NEP) and the Oak Ridges Moraine Conservation Plan. The current NEP came into effect on June 1, 2017. Furthermore, all agencies of the Ontario Government are subject to a mandate review every six years, led by Treasury Board Secretariat. A review of the NEC was completed in 2018, and it concluded that the mandate was being implemented appropriately. The MNR completed an updated mandate review during the 2025-26 fiscal year (ending March 31, 2026). 3. Resources to DeliverThe NEC is a non-revenue generating agency that is funded through financial and employee allocations provided by the MNR. 3. 1 BudgetThe NEC is committed to achieving operational excellence through effective and efficient use of public resources to carry out its mandate. The NEC does not operate on a cost recovery model, and staff salaries, wages and benefits, and all operational costs are fully funded by the MNR. The budget projections inTable 1show minor increases from the 2025-2026 baseline allocation to account for inflation and cost of living. Commissioner per diems are paid as perSchedule B of the Agencies and Appointments Directive. The Commission meets monthly and enables Commissioners, permit applicants and interested parties to attend in person or virtually. The NEC provides quarterly reporting onCommissioner and Chair travel expensesthrough its website. Commissioner per diems are reported annually in the Annual Report. Table 1 – Budget Allocation with Percentage Changes from Baseline 2025-2029Standard AccountBudget Allocation2025-20262026-2027(% change)2027-2028(% change)2028-2029(% change)Salary and Wages$2. 4M$2. 45M(+2. 1%)$2. 5M(+4. 2%)$2. 55M(+6. 3%)Employee Benefits$380K$388K(+2. 1%)$396K(+4. 2%)$404K(+6. 3%)Salary, Wages and Benefits TOTAL$2. 8M$2. 85M(+1. 8%)$2. 9M(+3. 6%)$2. 9M(+3. 6%)Transportation and Communications$43K$44K(+2. 3%)$45K(+4. 7%)$46K(+7. 0%)Services, including Commissioner per diems$91K$93K(+2. 2%)$95K(+4. 4%)$97K(+6. 6%)Supplies and Equipment$31K$31. 6K(+1. 9%)$32. 2K(+3. 9%)$32. 8K(+5. 8%)TOTAL Other Direct Operating Expenses (ODOE)$165K$168K(+2. 1%)$172K(+4. 1%)$175K(+6. 2%)GRAND TOTAL$2,965K$3,018K(+1. 8%)$3,072K(+3. 7%)$3,137K(+5. 8%)Notes:All percentage changes calculated from Budget Allocation (2025-2026). Dollar amounts are shown in parentheses for reference. Forecasting based on approximately 2% annual increases. Employee benefits calculated at 16% of salaries. 3. 1. 1 NEC – Other FundsWith the approval of the NEP in 1985, the Niagara Escarpment Land Acquisition and Stewardship Program (NELASP) was created. The Ontario Heritage Trust (OHT) was assigned the responsibility of administering the program, which was to accept contributions from donors for the purpose of land acquisition and stewardship activities. While the program was terminated in 1998, the financial administration and assistance provided by the OHT to the NEC continues through a series of OHT Board approved “Component B Trust Accounts”, which are directly managed by the NEC. The OHT receives and flows funds for NEC projects based on NEC-approved revenues and expenditures. The NEC’s reliance on these accounts continues to diminish. The NEC will continue to operate in a fiscally responsible manner in the use of any of the funds that may be accessed over the next three fiscal years. Table 2shows the current OHT accounts, their purpose, and the corresponding account balance as of September 30, 2025, for the 2025-26 fiscal year. The amounts remain unchanged from the previous fiscal year (2024-25). Account NamePurposeBalanceLeading EdgeFund outreach, education, and conferences to promote work of the NEC and the Niagara Escarpment Biosphere Network$1,514. 43ONE Monitoring ProgramFund NEC’s ONE monitoring program and historically special projects related to the biosphere reserve$22,550. 47PublicationsFund marketing and promotional materials$12,483. 05Joint Agency Review Team (JART)Dufferin Aggregates provided a letter of credit for $25,000. The funds can be used by the NEC to retain a third-party consultant to undertake an expert peer review of any reports provided by Dufferin or other agencies in connection with the Adaptive Management Plan (AMP) for the Acton Quarry. The funds cannot be used for any other quarry. An additional $30,000 was deposited in 2023 prior to the commencement of below water table extraction in Phase 4 of the Dufferin Acton Quarry operation as per the Agreement with Dufferin. $55,000. 003. 2 NEC Organizational StructureThe Commission is supported by a team of employees seconded from the MNR. Most NEC employees work from one of two primary offices, located in Georgetown (Halton Hills) or Owen Sound. However, NEC staff also have a presence in the MNR Vineland office. 3. 2. 1 Organizational StructureThe NEC’s maximum staffing complement is 24 Full Time Equivalent (FTE) positions (Figure 2). This includes one Director (executive), who reports to the Deputy Minister of the MNR, two Managers, and 21 bargaining represented positions. There are also four recurring contract (seasonal) positions, which do not contribute towards the total FTE count. Figure 2:Organizational structure of MNR staff that support the NEC. Beyond the formal structure, the NEC relies on a team-based service delivery model. Through the model, multi-functional teams are assigned to geographically based client groups to deliver the full range of NEC services. There are three teams – one for each of the southern, central, and northern portions of the NEP area. 4. Priorities for 2026-2027NEC’s strategic priorities set goals to guide the Commission and its staff to achieve outcomes that support its mandate, as well as contribute to the delivery of MNR’s mandate and achievement of government priorities. NEC’s priorities focus on three main areas and are described below. 4. 1 Natural Resources Management and Economic DevelopmentWithin the area of the Niagara Escarpment Plan, the NEC supports economic growth and job creation compatible with the Escarpment environment and promotes sustainable outdoor recreation opportunities. 4. 1. 1 Modernize Legislation, Regulations and PoliciesThe NEC is working with the MNR to evaluate the NEPDA and its associated regulations for opportunities to further streamline permitting and expand upon exemptions, improving service to NEC clients and supporting provincial initiatives such as housing, where such initiatives are compatible with the objectives and policies of the NEP. Beyond the legislative and regulatory opportunities, theGreenbelt Actrequires a review of the Greenbelt Plan every 10 years, in coordination with a review of the Niagara Escarpment Plan (NEP) and the Oak Ridges Moraine Conservation Plan. . While this requirement remains in place, no review process has yet been launched. The MNR will support the review as the lead ministry for the NEP. The Commission will review proposed changes and provide recommendations to the Minister. The last review of the NEP was in 2015. 4. 1. 2 Communications and OutreachThe NEC will continue to undertake initiatives that support implementation of its current outreach strategy, which has three core goals:Raise awareness about the NEC and keep members of the public informed about Commission activities. Foster collaboration and engagement with ministries, municipalities, agencies, stakeholders, Indigenous communities, and other groups; and,Provide easy access to information related to theNiagara Escarpment Planning & Development Act(NEPDA), the NEP, and all associated policies, procedures, and processes. To promote broader access to information for all Ontarians, the NEC plans to continue with website improvements that will enable access to greater information. 4. 1. 3 Outdoor Recreation OpportunitiesThe Niagara Escarpment Parks and Open Space System (NEPOSS) consists of more than 163 parks and open spaces on public land owned and/or managed by conservation authorities, municipalities, Ontario Parks, Royal Botanical Gardens, the Bruce Trail Conservancy, Ontario Heritage Trust, Parks Canada and other conservation organizations capable of managing land in the public interest. NEPOSS strives to protect the Escarpment’s significant natural and cultural heritage resources while providing opportunities for compatible recreation and development. The Bruce Trail is the common linkage connecting most of the parks and open spaces. The NEC will continue to promote NEPOSS partners, sites and outdoor recreation compatible with the policies of the NEP through marketing and communications channels, including via its website, social media, and outreach events. 4. 1. 4 Monitoring the Niagara EscarpmentThe NEC will continue efforts to formalize a high-level approach to monitoring the effectiveness of the policies of the NEP. To achieve this, the NEC is collaborating with the MNR Science and Research Branch to utilize existing data sets that will enable an analysis of land use and land use change over time. By examining the percent of natural cover, changes in land use, and the extent of ecological connectivity, this information will allow for an assessment of the effectiveness of NEP policies in meeting the Purpose and Objectives of the NEPDA and NEP, and to inform future policy updates. 4. 2 Service Delivery Excellence and ModernizationThe NEC continues to examine the current business processes and tools that guide operational programs and seeks to improve client service through a variety of planned actions and initiatives. 4. 2. 1 Fiscally Responsible Service DeliveryAs an agency of the Crown that is fully funded by the MNR, the NEC is committed to maintaining OPS service level standards while managing its fiscal resources prudently and responsibly, as set out in Section 3 of this document. 4. 2. 2 Responsive Customer ServiceThe NEC will continue to identify opportunities for service delivery improvement and process efficiencies to provide enhanced client service. Priority service delivery projects involve providing stakeholders, partner municipalities and members of the public with improved access to information about the NEPDA, its regulations and the NEP, as well as greater clarity on the Development Permit application process and requirements, without needing to travel to an NEC office. Although the NEC offers in-person services, including pre-consultation services for Development Permit Applications where requested, the NEC is seeking to provide more transparency and make information more readily accessible from anywhere, on any device, at any time. 4. 2. 3 Business Process ImprovementsThe NEC is initiating or continuing several initiatives to modernize and, where possible, streamline business processes to improve stakeholder and applicant experience and increase agency transparency. These improvements include:Review the Development Permit application process to identify opportunities for efficiencies, modernization, and burden reduction, as well as areas that lack transparency and require development of new or updated guidance materialsStrengthening relationships with partner ministries and agencies to share information, build knowledge and enhance collaboration. 4. 2. 4 NEPDA Compliance and EnforcementThe NEC will continue to carry out regular compliance activities using a risk-based approach that considers factors including level of impact to the Escarpment environment and compliance history. Compliance and enforcement actions initiated will be proportional to the level of risk identified for each compliance case. To ensure the program consistently delivers high-quality and effective service, NEC will review and update procedures, protocols, and guidance documents and develop new materials as needed. Education, outreach, and communication remain key priorities to promote compliance with the NEPDA and related regulations. Planned activities include maintaining and enhancing publicly accessible information on the NEC website and engaging in information sharing with partner agencies. 4. 3 Organizational Leadership4. 3. 1 Attraction, Retention and Employee EngagementAs with many other organizations across the province, the NEC is experiencing challenges attracting and retaining employees and continues to experience moderate to high turnover. A key area of focus for 2026 – 2029 will be on efforts that support stabilizing NEC’s staffing contingent and connecting NEC staff with MNR colleagues, supports, and training opportunities. The Ontario Public Service has established a blueprint to address the fundamentals of attracting, developing, and retaining the talent needed to serve Ontarians with inclusion, integrity, and excellence. Inclusion: Respecting the dignity and human rights of every person so they feel welcomed, valued, and like they belongIntegrity: Demonstrating trust, honesty, accountability, and impartialityExcellence: Delivering high quality and timely public services and programsThe NEC supports theOPS People Planand is striving to meet the goals of the plan with a focus on workplace culture, modern work, and staff growth and development, building on achievements to date and enhancing them over the next few years. 5. Performance Measures and Annual Performance TargetsPerformance measurements serve as a key mechanism for evaluating the NEC’s effectiveness in advancing provincial objectives through the implementation of the Commission’s mandate. Performance measurements serve as a key mechanism for evaluating the NEC’s effectiveness in fulfilling its legislated mandate under the NEPDA, including administering the NEP, supporting the NEPOSS, and providing comments as a planning agency, while also ensuring strong governance and organizational accountability. The NEC’s performance measures are designed to promote accountability and transparency, support continuous improvements in program delivery, enhance responsiveness to client service needs, and provide evidence to inform future program modifications. Beginning in 2026-27, the NEC will introduce a new set of Key Performance Indicators (KPIs). These KPIs will be used to establish baseline data and guide the development of future performance targets. This forward-looking approach ensures that measures are both meaningful and achievable, while also aligning with organizational priorities and broader OPS initiatives. To guide this work, the NEC is using the Balanced Scorecard framework (an industry-recognized evaluation method), which considers performance across four perspectives: Financial Measures, Customer Satisfaction, Internal Processes, and Employee (Commissioner) Measures. Organizing KPIs under these categories provides a holistic view of performance and ensures progress can be tracked across all areas of the organization. Each KPI is presented in a consistent format that outlines:What we will measure– the key activity, process, or outcome being tracked. Why we are measuring it– the purpose and link to NEC priorities. The expected impact– how the measure supports accountability, service improvement, or organizational effectiveness. Over time, these KPIs will allow the NEC to track trends, identify opportunities for improvement, and demonstrate to the public, partners, and government the impact of its work. 5. 1 Financial MeasuresKPI 1: Budget Adherence(Annual Spending vs. Allocation)What we will measure:NEC’s total annual spending compared to the allocated budget, recorded as a % difference from allocation. Why we are measuring it:To ensure responsible use of public funds and demonstrate sound financial management. Expected impact:Builds trust with government and the public, supports transparency, and reinforces financial accountability in program deliver. 5. 2 Customer SatisfactionKPI 1: Frequency of Meeting OPS Service StandardsWhat we will measure:How often inquiries, calls, emails, and in-person services are completed within OPS service standard timeframes, tracked through service records. Why we are measuring it:To ensure the NEC consistently meets expected service levels and demonstrates accountability to both internal and public stakeholders. Expected impact:Meeting OPS service standards improves customer satisfaction, reinforces reliable service delivery, and supports transparent and efficient operations. 5. 3 Internal ProcessesKPI 1: Development Permit Application ResponsivenessWhat we will measure:Time taken to complete various milestones in the Development Permit Application review and decision-making process (e. g. , acknowledge application submissions, agency review, circulation of Notices of Decision, etc. ), which are tracked via the NEC Information System. Why we are measuring it:To support timely, efficient processing of applications, and demonstrate accountability to applicants and the public. Expected impact:Predictable processing reduces delays, improves client service, enhances public satisfaction, and reinforces transparency and efficiency in NEC operations. KPI 2: FIPPA Request Processing (Average Time to Complete and Number of Extensions Requested)What we will measure:The average number of days taken to complete FIPPA requests. The number of formal extensions requested annually. Why we are measuring it: To ensure NEC meets legislated timelines for FIPPA requests while identifying workload pressures or bottlenecks that may delay responses. Expected impact: Tracking both speed and compliance highlights where improvements are needed, ensures accountability under legislation, and builds public trust in NEC’s transparency and responsiveness. KPI 3: Number of Meetings Held AnnuallyWhat we will measure:The total number of Commission meetings held each year, against the standard of 11 meetings, tracked through meeting logs and cancellations. Why we are measuring it:To demonstrate the Commission’s ability to meet regularly, ensure decision-making continuity, and uphold accountability to the public and stakeholders. Expected impact:Regular meetings build stronger relationships among Commissioners, reduce delays or conflicts, and support timely, transparent decision-making in line with the Niagara Escarpment Plan. 5. 4 Commissioner EngagementKPI 1: Commissioner Positions FilledWhat we will measure:The number of filled versus vacant Commissioner positions, tracked against quorum requirement. Why we are measuring it:To ensure the Commission has sufficient members to meet quorum and maintain decision-making capacity. Expected impact:Maintaining quorum through timely filling of positions supports consistent decision-making, strengthens governance capacity, and reduces disruptions to Commission operations. KPI 2: Number of Commissioner Training Sessions Delivered AnnuallyWhat we will measure:The total number of training sessions provided to Commissioners each year, tracked through session records and attendance logs. Why we are measuring it:To ensure Commissioners are informed about policies, regulatory responsibilities, and best practices to support effective decision-making. Expected impact:Enhances the quality and consistency of Commission decisions, strengthens governance, and builds public confidence in NEC operations. 6. Risk Assessment & Mitigation StrategiesLike other organizations, the Niagara Escarpment Commission (NEC) faces a variety of internal and external factors that create uncertainty and have the potential to impact the agency’s ability to implement its mandate. The NEC identifies, assesses, and manages risk in accordance with the Ontario Public Service (OPS) Enterprise Risk Management Framework and Directive. Specific identified risks are related to the goals and objectives of the NEC as well as those of the Ministry of Natural Resources (MNR). The ability to identify and manage these risks is key to any organization’s success. The following describes the primary categories and sub-categories of risks determined to be most relevant to NEC, followed by an outline of the current risk management strategies and current status. The risks identified for this Business Plan remain the same as those identified in previous Plans. 6. 1 Strategic Risk: ReputationalRisk:Diverse needs and perspectivesRating:LowThe Niagara Escarpment traverses one of the fastest growing regions in North America with a projected population of more than 14 million by 2051. It is also a major source of close-to-market aggregate resources, prime agricultural land, and is one of the last remaining bands of continuous forest cover and natural heritage linkages in southern Ontario. Mitigation Strategy:To balance these diverse needs and perspectives, the NEC will continue to engage and work collaboratively with stakeholders, landowners, industry, and Indigenous communities to provide for the maintenance of the Niagara Escarpment and land in its vicinity substantially as a continuous natural environment, and to ensure only such development occurs as is compatible with the Escarpmentenvironment. 6. 2 Strategic Risk: External EnvironmentRisk:Reliance on other agenciesRating:LowNEC works in partnership with many other agencies, and these relationships and collaborative work are key to success. Uncertainty about events, occurrences, or circumstances external to the NEC or Ontario government can create risks associated with achieving our mandate. Similar to NEC, other agencies, such as municipalities, conservation authorities, and not-for-profit agencies, are also required to adapt their priorities and programs to meet the needs of their organizations to be responsive to social, economic, policy or regulatory changes. Mitigation Strategy:NEC continues to monitor these changes to identify risks to NEC programs and operational delivery. For example, these partners play a significant and important role in the protection and management of the Niagara Escarpment Parks and Open Space System. Changes to organizational structures, mandate, priorities, and finances in these partner organizations can be a risk to NEC’s ability to effectively implement the NEP, the protection of the Escarpment environment and to ensure public access and the provision of outdoor recreational activities. 6. 3 Operational Risk: LegalRisk:Indigenous relationships and reconciliationRating:LowAs an agency of the Government of Ontario, the NEC has a Duty to Consult where a statutory decision may impact Aboriginal and/or treaty rights. The NEC is committed to building and maintaining meaningful relationships with Indigenous peoples and communities that are based on trust and mutual respect, and that contribute towards reconciliation. Mitigation Strategy:The NEC will continue to work collaboratively with the MNR and other partner agencies on engagement or notification of Indigenous communities, to ensure that Indigenous voices are heard and respected. 6. 4 Operational Risk: Financial ResourcesRisk:Lack of revenue generationRating:LowThe NEC does not charge fees for permits or services provided, which means the NEC has no source of revenue generation. The daily operation of the NEC, which includes the salary and wages of staff supporting the Commission, is fully funded by the MNR. The NEC Chair and Director are accountable to the Deputy Minister and Minister of Natural Resources and must ensure responsible use of financial resources. Mitigation Strategy:NEC monitors financials monthly to ensure financial transparency, accountability, and monitor emerging pressures. The NEC will continue to manage its financial allocation as per OPS directives. 6. 5 Operational Risk: Human ResourcesRisk:Variable employee resource levelsRating:MediumThe NEC continues to experience moderate to high levels of turnover in many of its employee positions, with 21 of 24 positions experiencing at least one vacancy over the last fiscal year. The NEC also continues to experience challenges with attracting employment candidates. Employee positions are unionized, and compensation (i. e. salary, wages, benefits) is set out within OPSEU and AMAPCEO Collective Agreements, which may not be competitive with other sectors (e. g. , private business or industry, municipalities) if wages do not keep up with cost of living and inflation. Employee turnover and vacancies can impact retention of organizational knowledge, result in higher workload for remaining staff, increasing the risk of employee burnout, as well as cause process delays due to transition periods as files are transferred to new staff leads. Mitigation Strategy:The NEC employs numerous mitigation strategies to reduce this risk, including succession planning, early action to address known vacancies, and timely recruitment for planned and unplanned vacancies. Conversations regarding assessments of organizational structure and human resource needs is ongoing with MNR. 6. 6 Operational Risk: Information & Information TechnologyRisk:IT system failure or breachRating:MediumThe NEC Info System launched in March 2024 enables digital permit applications via an online portal as well as back-office functionality for the review and processing of permits and inquiries. The NEC collects limited personal information and no financial information as part of the application process; however, system breach or software failure remains a risk to business delivery. Mitigation Strategy:The NEC has multiple mitigation plans in place to reduce and mitigate these risks, which includes virus scanning software, two-factor authentication, other cyber security tools, as well as contingency planning in the event of a full or partial system failure or a system breach. Additionally, there is an ongoing support and maintenance agreement which addresses system bugs, maintenance, and failures, to ensure the system remains operational or is repaired in the event of a system or component failure. In the event of a system failure or breach, the NEC would follow existing OPS protocols. 6. 7 Operational Risk: Climate ImpactsRisk:Climate, environment, and emergency managementRating:LowSeasonal and extreme weather events—such as ice storms, heavy rainfall, or prolonged drought—can disrupt NEC operations, delay inspections, and affect the physical condition of trails and infrastructure. These disruptions may increase maintenance needs or limit public access to the Niagara Escarpment. Mitigation Strategy:The NEC monitors seasonal and weather-related trends and adjusts work plans accordingly to reduce service interruptions. Where possible, the NEC integrates climate resilience considerations into its operational planning, site inspections, and maintenance scheduling to ensure continuity of core services. NEC staff are currently developing a formal Continuity of Operations Plan (COOP) as part of operational planning in 2025-26. 6. 8 Operational Risk: Program DeliveryRisk:Data and evidence gapsRating:MediumThe NEC depends on reliable data to make informed decisions and report on its performance. However, there are internal gaps in how data is collected, tracked, and reported—such as the number of permits issued, inquiries received, or enforcement actions taken. These gaps limit the NEC’s ability to assess workload, measure service levels, identify trends, and demonstrate impact. Mitigation Strategy:To address this, the NEC is working to improve internal tracking systems and standardize data collection practices. Efforts are also underway to ensure staff are trained in consistent data entry and reporting processes to enhance transparency, support decision-making, and meet accountability expectations. 7. Inventory of NEC’s Artificial Intelligence (AI) UseUse of Artificial Intelligence (AI) is widely recognized as an opportunity for time and process efficiencies; however, it is important to consider associated risks before using them. The OPS has several guidance documents, including theTrustworthy Artificial Intelligence (AI) Frameworkand thePrinciples for Ethical Use of AI, to support the consideration of risks and application of best practices in the field of AI. As an agency of the Government of Ontario, the NEC is committed to assessing opportunities and risks for the use of AI in alignment with all related government AI principles and practices. Current use of AI at the NEC is limited to supporting the development of internal communications, specifically as an editing tool for concise, plain language communications (see Use Case below). As OPS employees, NEC staff have access to Microsoft Co-Pilot. Over the next three years, the NEC intends to consider opportunities to integrate AI into the services it provides Ontarians, to find new efficiencies in service delivery and support NEC clients with plain language learning related to the NEPDA and NEP. 7. 1 AI Use CasesUse Summary:Use of AI as an editing tool for conciseness and plain language during the development of communications materials such as presentations, protocols and guidance, website content, etc. Problem Statement:The NEPDA, its associated regulations, and the NEP policies are written in a format that can be difficult to explain without using complex technical language. To promote better understanding of the NEPDA, its regulations and the NEP, communications need to be concise and use plain language. Associated Risks, Controls & Mitigation:Risk that confidential information or advice to the Commission or the ministry may be unintentionally shared via use of generative AI. Controls and mitigation include:All NEC staff will complete mandatory training related to responsible use of AI, so that they are aware of the risks related to using generative AI. NEC staff will only use the version of Microsoft Co-Pilot installed on OPS computers, which is contained within the OPS firewall, to ensure that internal information is not used for growth or advancement of generative AI. Risk that AI may generate information that is incorrect. Controls and mitigation include:NEC staff will conduct quality checks and proofread all materials for factualness and accuracy. Appendix 1 – Ongoing Legislative & Policy ComplianceThe Niagara Escarpment Commission (NEC) is required to meet a range of legislative and policy obligations that must always be achieved at 100%. These measures are tracked and reported internally to demonstrate accountability and compliance, but they are not treated as KPIs where improvement or targeting is expected. The following compliance requirements apply on an ongoing basis:Occupational Health & Safety Act complianceHuman Rights Code complianceAccessibility for Ontarians with Disabilities Act (AODA) complianceFrench Language Services Act complianceAgencies & Appointments Directive (AAD) complianceAppendix 2 – Municipalities within the NEP AreaNIAGARA REGION(Seven local municipalities)Town of GrimsbyTown of LincolnCity of Niagara FallsTown of Niagara-On-The-LakeTown of PelhamCity of St. CatharinesCity of ThoroldCITY OF HAMILTONHALTON REGION(Three local municipalities)City of BurlingtonTown of Halton HillsTown of MiltonREGION OF PEEL(One local municipality)Town of CaledonCOUNTY OF GREY(Six local municipalities)City of Owen SoundMunicipality of MeafordTownship of Georgian BluffsMunicipality of Grey HighlandsTownship of ChatsworthTown of The Blue MountainsCOUNTY OF SIMCOE(One local municipality)Township of ClearviewCOUNTY OF DUFFERIN(Two local municipalities)Town of MonoTownship of MulmurBRUCE COUNTY(Two local municipalities)Town of South Bruce PeninsulaMunicipality of Northern Bruce Peninsula