On behalf of the Region of…

On behalf of the Region of Waterloo, thank you for the opportunity to provide comments on the province’s proposal to modernize Ontario’s Conservation Authorities system, including the introduction of Bill 68 and the creation of the Ontario Provincial Conservation Agency (OPCA). We recognize and support the province’s objectives to enhance consistency, improve permitting processes, modernize technical standards, and strengthen coordination across Ontario. These goals align with our shared commitment to effective watershed management.

A regional conservation authority framework offers several potential benefits. Standardized permitting and processes across regions could reduce complexity for municipalities and developers, while improved access to technical resources would help smaller municipalities address watershed management challenges more effectively.

While we appreciate the intent behind these proposed changes, concerns regarding the restructuring remain. Under the current proposal, the Grand River Conservation Authority (GRCA) would become part of the Lake Erie Regional Conservation Authority, encompassing approximately 25,000 km² and 81 municipalities, a minority of which are supplied by groundwater, with most others having access to lake water. The proposed changes risk weakening local accountability and watershed-specific focus that have historically underpinned Ontario’s success in managing natural hazards, housing-enabling infrastructure planning, source water protection and watershed health.

The GRCA delivers essential, cost-effective watershed programs that directly support the Region of Waterloo’s groundwater supply, drinking water protection, and wastewater compliance. The Region of Waterloo serves approximately 700,000 residents and represents one of Ontario’s largest groundwater-based communities, with roughly 80% of its drinking water sourced from wells across a wide geographic area. Treated wastewater is discharged to the Grand River and its tributaries, which also serve as a drinking water source for the Region and downstream communities. This unique hydrogeologic context requires programs beyond those typically associated with watersheds serving lake-based communities. GRCA’s programs are calibrated to balance:

• Flood management through reservoir and dam operations,
• Source water protection for municipal wells and surface water withdrawals,
• Wastewater assimilative capacity and phosphorus management, and
• Stakeholder coordination across rural and urban areas.

Any changes must preserve strong, formalized local representation for the Grand River watershed and maintain GRCA’s tailored programs and technical capacity. Transition planning must prioritize staff retention and continuity of service to avoid delays in approvals and risk to environmental performance particularly considering Bill 56 changes to source water protection approval authorities.
To maintain local engagement, strengthen community relationships, and improve efficiency, adoption of a proven model such as Source Protection Regions – one that aligns with watershed boundaries, leverages shared resources, and keeps decisions locally informed - will better meet community needs while achieving provincial objectives.

Attached are the Region of Waterloo’s responses to the discussion questions posed by the Ministry of the Environment, Conservation and Parks (MECP) through ERO posting 025-1257. Thank you for considering these comments. The Region of Waterloo looks forward to continued collaboration with the Province to ensure that modernization efforts enhance efficiency while maintaining local accountability and watershed-based decision-making.

Sincerely,

Rod Regier
Commissioner, Planning, Development and Legislative Services