GSCA Submission to ERO…

GSCA Submission to ERO Posting 025-1257

 December 22, 2025  Via Environmental Registry of Ontario 

Subject:  Comments on ERO Posting No. 025-1257 – Proposed Boundaries for Regional Consolidation of Ontario’s Conservation Authorities 

To Whom It May Concern: 

Grey Sauble Conservation Authority (GSCA) appreciates the opportunity to comment on the proposed consolidation of Ontario’s conservation authorities. We share the Province’s objectives of improving efficiency, consistency, and modernization in service delivery. GSCA has already implemented significant improvements, including digital permitting, streamlined processes and enhanced customer service, and we remain committed to advancing these objectives. 

However, GSCA does not support the proposed consolidation into the Huron–Superior Regional Conservation Authority. This model would create a geographically vast entity (over 23,500 km² and 80 municipalities) combining watersheds with little shared hydrology, climate, or economic alignment.  

Such a structure risks: 

Loss of Local Accountability and Rural Voice: GSCA currently operates with strong municipal representation and local decision-making. Under the proposed model, local priorities could be overshadowed by urban centres hundreds of kilometers away. 

Increased Costs and Bureaucracy: No cost-benefit analysis or feasibility assessment has been provided. Transition costs (IT integration, HR harmonization, rebranding) and additional layers of governance will likely increase municipal cost apportionment and offer little in the way of savings to GSCA’s member municipalities. 

Reduced Responsiveness: Larger administrative structures often slow processes, contrary to the Province’s stated goal of streamlining approvals. 

Disruption of Community Partnerships: GSCA manages 29,000 acres of land, much of it donated by local residents with the expectation of local stewardship. GSCA also works with a network of dedicated volunteers and partners. Consolidation into a vast regional conservation authorities risks eroding these relationships and the trust that has been built locally. 

GSCA supports modernization without amalgamation, through: 

Province-wide standards and policies for permitting. 

Provincially developed and updated technical guidelines. 

Refined Key Performance Indicators (KPIs) to ensure that Provincial objectives are being met. 

Shared digital platforms and tools. 

Sustainable provincial funding to enable modernization and service delivery. 
 

Responses to ERO Consultation Questions 

1. Key factors for a successful transition and outcome of regional consolidation: 
 
GSCA does not support the proposed regional consolidation of conservation authorities and is firmly of the opinion that the Government’s objectives would be better served without adding red-tape and bureaucracy. However, if consolidation proceeds, success depends on: 

Pausing the current consolidation proposal to allow the Ontario Provincial Conservation Agency time to develop a well thought out business plan, including cost-benefit analysis and feasibility assessments. 

Clear provincial leadership and phased implementation to avoid service disruption. 

Retention of local knowledge and staff expertise, which is critical for ongoing program management. 

Retention of local offices and staff, including management, to provide continuance of local partnership, accessibility and front-line service. 

Continuation of locally prioritized and tailored programming to reflect local community needs. 

Transparent governance frameworks that preserve municipal influence and watershed identity.  

Dedicated provincial funding for all transition costs. 

Robust communication strategies to keep municipalities, stakeholders, and the public informed and engaged throughout the process. 

2. Opportunities or benefits of a regional conservation authority framework 
 
GSCA is of the opinion that these benefits can be achieved through collaboration, shared systems and voluntary service agreements without the cost and complexity of consolidation. The potential benefits of such service agreements could include: 

Shared technical expertise and modern tools across multiple watersheds. 

Consistent permitting standards and digital platforms that improve predictability for applicants. These should be provided by the Province regardless of consolidation. 

Opportunities for joint procurement and shared services to reduce duplication. 
   

3. Suggestions for governance structure at the regional level 

The current governance structure provides the most representative and accountable system by offering each funding partner a meaningful voice at the governance table. GSCA has eight (8) participating municipalities represented by eleven (11) Board Directors appointed from each of the participating municipalities. This system provides a well-balanced structure that allow the participating municipalities the opportunity to design programs and policies that align with local municipal priorities, align with local municipal budgets, and represent the needs of the local community. If the Province proceeds with consolidation, the following governance structure may provide the next best option: 

A streamlined board (10–20 members) with representation grouped by upper-tier municipalities or counties to maintain fairness and efficiency. 

Utilizing the existing Upper Tier and Single Tier frameworks for local governance and apportionment to provide a more manageable option. That is, members of the Regional CA Board would be appointed from local upper tier or single tier municipalities within the Region’s jurisdiction.  

In this model, it is recommended that apportionment would also move to the Upper Tier / Single Tier level. 

Clear protocols for communication between regional boards and municipalities. 

The creation of Regional Boards provides an opportunity to include other community groups within the Board structure, including local Indigenous representation and local industry representation. If this option is considered, it is recommended that the additional representatives would be excluded from budget votes. 

4. Maintaining a transparent and consultative budgeting process 

The current budget process provides for the most transparent, accountable, accessible and consultative budgeting process as each participating municipality is afforded the opportunity to review draft budgets and representation at the Board table is such that individual municipal input is factored into budget decisions. This will be lost by the proposed consolidation model. 

If consolidation moves forward, the following process should be utilized: 

A standardized regional budget framework with clear timelines and assumptions. 

Locally developed operating and capital budgets for each local office that are factored into the regional budget framework. These budgets can be reviewed and presented to sub-regional (local) budget advisory committees to ensure local priorities are considered. 

Publicly accessible budget documents and early consultation aligned with municipal budget cycles. 

Transparent levy apportionment formulas and regular financial reporting to all member municipalities. 
 

5. Maintaining and strengthening relationships with local communities and stakeholders 

Relationships with local communities and stakeholders have been developed over years or decades. Unless local offices, staff and leadership are maintained, not only will relationships weaken, they are at risk of disappearing altogether. 

Retain local offices and staff presence to ensure accessibility and responsiveness. 

Maintain clear communication channels and decision-making processes for local issues. 

Preserve local branding and identity to sustain trust and engagement. 

Closing Statement 

GSCA urges the Province to prioritize modernization through shared standards, tools, and funding rather than large-scale structural amalgamation. We remain committed to working collaboratively to achieve efficiency and consistency while preserving the watershed-based governance model that has served Ontario effectively for decades. 

Submitted by: 
Grey Sauble Conservation Authority 
www.greysauble.on.ca