I am highly concerned by …

I am highly concerned by (and entirely opposed to) this proposal to amalgamate 36 unique conservation authorities, that represent 36 geographically & ecologically unique regions, into just 7 giant authorities.

The current "watershed-based" delineation of our 37 Conservation Authorities allows for a locally-tailored approach to the unique needs of each region, allows even the smallest municipalities to have a voice at the table and to provide input on decisions made, by having a seat on the Authority Board, and allows for Conservation Authority staff to develop meaningful, mutually beneficial relationships with the landowners and residents of their region, as well as members of local environmental organizations & members of local government/councils. I do not see any way in which a regional conservation authority will help to maintain or strength relationships with *local* communities and stakeholders -- and the municipalities within my local region (Cataraqui Conservation) have all voiced their own concerns with this proposal, as evidenced by the minutes of the recent December 3rd board meeting. They are highly concerned that they will not continue to be represented on the board of this proposed "St Lawrence Region Conservation Authority." They are similarly concerned about the immense costs that will be incurred in order to amalgamate the existing Authorities (rebranding, new signs, changing ownership/title of properties, etc.) -- as well as the possibility that they may eventually need to pay for the cost of the overseeing agency, through levy dollars.

By and large, the alleged "reason" for this proposed change is to improve the permitting process (which is just one small part of the role that Conservation Authorities play in the province). I fail to comprehend how a giant, regional Conservation Authority will result in faster turn-around times for permits. At Cataraqui Conservation (a Conservation Authority with a very small, bare-bones staffing complement), the average turn-around time is 5 days -- less than half the provincial average of 12 days. The planning team consistently meets the targets set out by the province -- more than 90% of the time. Will Cataraqui's current planners continue to work out of their local office in order to visit local sites in a timely manner? Will this giant, regional model not result in more delays, as staff are asked to deal with permits for an area 5x the previous size? Indeed, when have consolidations such as this, ever resulted in more streamlined, effective service? I wholeheartedly believe that Cataraqui Conservation will be able to meet the objectives, and address the concerns voiced by the province, without amalgamating with five other, vastly different, Authorities. This could be achieved (and far more cheaply) by providing common Development Review/Permitting software to be used by all of the Conservation Authorities, combined with more standardized Development Review/Permitting policies (with some allowance for local nuance).

Importantly, it is clear that for a regional Authority to function, there will continue to be a need for a local offices, in order for operations staff to continue to maintain existing conservation properties for public use, as well as for permitting/planning staff, watershed monitoring staff, and forestry staff, to continue to conduct site visits (without travelling 6+ hours round-trip). In light of this, and knowing that at least 5 separate offices will continue to need to be maintained, the amalgamation of the current Authorities makes very little sense. Quite frankly, it seems a crude and costly response to a problem that could be solved with a little finesse.

II also want to draw the attention of the province to the matter of the Source Protection Authorities. Cataraqui Conservation (for example) is also the Cataraqui Source Protection Authority. The areas of the province's Source Protection Regions are based on the current Conservation Authorities. Changes to the current Authorities' boundaries will also require changes to the Safe Drinking Water Act and the Clean Water Act in order to amend these Source Protection Regions. It appears obvious to me that the province has not considered this. It also appears obvious to me, that the province has not considered how vastly different the threats to local drinking water are, between each current Source Protection Region. The Cataraqui region is comprised of a highly vulnerable karst region -- but to our east, in South Nation and Raisin Region Conservation Authorities' regions, the landscape, and thereby the threats to groundwater sources, are entirely different. These Source Protection Authorities were created in response to the Walkerton public health disaster from 2000, and are a critical part of how our provinces works to protect the lives and health of its residents.

Finally, I would like it on record that I highly value Cataraqui Conservation's local educational programs (offered through the Little Cataraqui Creek and Mac Johnson Conservation Areas). I value the opportunity to visit the office in person, when needing to ask questions about a potential building plan or related issue. I value seeing Cataraqui Conservation staff presence at local events (Loyalist Township Family Fishing Day, Napanee Garden Expo, Lyndhurst Turkey Fair, South Frontenac Lakes and Trails Day, etc.). I value the fact that all municipalities in our region have a seat at the Full Authority Board, so that all communities and their varying needs/objectives/priorities are represented. I value the relative low cost of Cataraqui's permits, as compared with other Authorities, as well as the rapid turnaround time maintain by Cataraqui's Development Review Team. I deeply value the locally-informed knowledge held by the current staff of Cataraqui Conservation, and their nuanced understanding of the issues that impact our region.

Thank you for your consideration of this comment.