To the Ministry of the…

To the Ministry of the Environment, Conservation and Parks,

I oppose the proposed consolidation of Conservation Authorities under ERO 025-1257, particularly as it affects the Upper Thames River Conservation Authority (UTRCA), where annual flooding, rapid snow-melt events, and extreme precipitation are now routine.

1. Loss of Local Governance and Accountability
Conservation Authorities were created as locally governed watershed agencies. Consolidating 36 authorities into seven large regions will dilute municipal representation and weaken local decision-making that is essential for managing distinct watershed conditions.
2. Flood and Snow-melt Management Requires Local Expertise
UTRCA relies on localized hydrometric stations, snowpack monitoring, and land-use knowledge to issue timely flood advisories and operate reservoirs. These functions are tied directly to watershed-specific data that cannot be effectively managed from a distant regional authority.
3. Oversized Regions Reduce Responsiveness
The proposed “Lake Erie Regional Conservation Authority” would absorb eight existing authorities and 80+ municipalities. Managing watershed hazards across an area this large risks delays, inconsistent service, and reduced ability to respond quickly to localized flood events.
4. No Demonstrated Environmental or Operational Benefit
The proposal offers no evidence that consolidation improves watershed health, biodiversity protection, or natural hazard mitigation. There is also no analysis showing cost savings or improved efficiency.
5. Risk of Service Disruption During Transition
Large-scale restructuring diverts funding and staff time from core programs—flood forecasting, habitat restoration, permitting, monitoring—that are critical to protecting people, property, and species at risk.
6. Local Boards and Municipalities Have Already Raised Concerns
UTRCA and multiple municipal councils across the province have identified risks to governance, service delivery, and environmental protection under the proposed model.

I urge the Province to withdraw the consolidation proposal and instead strengthen Conservation Authorities by supporting local capacity, stable funding, and watershed-specific expertise.