ERO-025-1257 Submission I am…

ERO-025-1257 Submission

I am submitting this comment in opposition to ERO-025-1257 due to the significant risks it poses to farmland protection, watershed-based planning, and the long-term public interest.

The proposed consolidation of Ontario’s Conservation Authorities from 36 locally governed, watershed-based authorities to 7 large regional bodies represents a fundamental departure from the principles that underpin effective land-use planning and environmental protection. These changes weaken the very systems relied upon to protect prime agricultural land, manage flood risk, and safeguard water resources.

Provincial Policy Statement Obligations

The Provincial Policy Statement (PPS) is explicit that:

• Prime agricultural areas shall be protected for long-term agricultural use
• Land use planning shall minimize negative impacts on agriculture, including fragmentation and premature conversion
• Development and site alteration shall not be permitted in a manner that would compromise ecological or hydrological functions
• Cumulative impacts must be considered, particularly where incremental change leads to long-term loss of resources

These policy directions rely on strong, locally informed oversight — particularly where agriculture, water, and land-use pressures intersect.

Farmland and Watershed Protection Are Inseparable

Prime agricultural land depends on stable hydrological conditions, effective floodplain management, and detailed local knowledge of soils, drainage, and watershed function. Aggregate extraction and other forms of land conversion permanently alter soil structure and water movement. Once disturbed, agricultural land cannot be meaningfully restored to its former productivity.

Local Conservation Authorities have decades of experience managing these interconnections at a watershed scale. As noted by long-standing watershed organizations, Conservation Authorities are deeply familiar with the unique characteristics, risks, and cumulative pressures within their watersheds, knowledge that cannot be replicated through broad regionalization.

Loss of Local Expertise and Accountability

The proposed amalgamation would create Conservation Authorities serving dozens of municipalities across vast and ecologically distinct regions, undermining locally responsive decision-making. For example, proposed regions would combine watersheds with entirely different hydrology, soils, climates, and land-use pressures — a structure that is ill-suited to protecting farmland or managing flood risk effectively.

The joint submission from environmental, agricultural, and community organizations emphasizes that Conservation Authorities were intentionally designed to embody local governance and local expertise, following devastating flood events such as Hurricane Hazel. Centralizing authority at the provincial level contradicts this founding principle and weakens environmental outcomes.

Cumulative Impacts and Flood Risk

Farmland loss and flood vulnerability rarely result from a single decision. They arise through incremental approvals, weakened safeguards, and policy changes that fail to account for cumulative effects. The PPS requires that these cumulative impacts be considered, yet the proposed consolidation distances decision-makers from the very landscapes where those impacts occur.

Flooding is already Ontario’s costliest natural hazard and is expected to intensify with climate change. Conservation Authorities play a critical role in protecting agricultural lands and downstream communities from flooding and erosion. Weakening their independence and local presence increases risk rather than reducing it.

Governance, Transparency, and Public Confidence

The enabling changes associated with ERO-025-1257 and Bill 68 grant the Minister expanded authority over Conservation Authority governance, programs, and services. This concentration of power, combined with reduced local representation, undermines transparency and meaningful public participation.

Notably, the ERO does not clearly disclose the full legislative implications of these changes, limiting the public’s ability to comment meaningfully — a concern raised directly in the joint submission as inconsistent with the intent of the Environmental Bill of Rights.

Conclusion and Request

I respectfully urge the Ministry to withdraw ERO-025-1257.

The proposed consolidation of Conservation Authorities weakens farmland protection, undermines watershed-based planning, and conflicts with the long-term principles embedded in the Provincial Policy Statement. Ontario’s agricultural lands are a finite public resource, essential to food security, rural economies, and climate resilience. Once lost, they cannot be replaced.

Provincial policy must continue to support local expertise, cumulative impact assessment, and watershed-scale governance to ensure that short-term administrative or extraction interests do not compromise the long-term public interest.