Remove the requirements for…

ERO number

013-5018

Comment ID

28682

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

Remove the requirements for individual Municipal Council budget agreement for watershed-based programs called “other programs and services”/ non- mandatory.

The creation of conservation authorities recognized that water does not stop flowing at political boundaries and that there are economies of scale through cost sharing. The provincial proposal in effect undermines the mandate, premise and value of the multi-municipality/watershed governance of conservation authorities.

It will certainly consume a far greater share of municipal and CA administrative and Council/Board time. It would also mean that the CA’s budget would only be approved at the pace of the “slowest” municipal approval. This could be months into the fiscal year.

This new administrative instrument appears cumbersome at best, red tape at its worst. It transfers components of budget decision making to municipal councils rather than with the Board of Directors. It is unclear why a government that wants to reduce red tape and improve efficiencies is creating such a complicated and time consuming process for watershed management programs and services CA Boards deem necessary to provide. The “humility of uncertainty” suggests it is possible that this is not a good idea.

The Province should continue to invest in the core mandatory programs and services to be delivered by conservation authorities and support CA eligibility for other provincial funding programs

There are currently provincial transfer payments to all CAs for natural hazards (Ministry of Natural Resources and Forestry) and source water protection (Ministry of Environment, Conservation and Parks). The Province’s ‘Made-in-Ontario Environment Plan’ recognizes how issues such as climate
change can impact and threaten Ontario’s economic prosperity and the well-being of its people; and states that addressing these challenges is a shared responsibility. However, the 2019 Ontario budget cut 50% of the natural hazards program funding to conservation authorities. This seems to be a contradiction to the Environment Plan particularly given the flooding that occurred right after the funding was cut.

Individual CAs are important on-the-ground delivery agents for numerous provincial programs through special contracts for example and it should be ensured that the eligibility of CAs for these other provincial funding opportunities is not negatively affected and in fact, is improved. This would include provincial funding programs such as the Trillium Fund and the Canada-Ontario Agreement for Great Lakes Water Quality.

Core mandatory programs be applied to municipal levy or could utilize other sources of revenue.

Given the instability of provincial transfer payments (a reminder, the flood control cut of 50% was to an amount that had not changed for roughly 20 years) and additional pressures on municipal budgets, the CA/municipal budget relationship should retain the CA Board’s ability to charge and use fee revenues. It is our request that these core mandatory programs may be applied to municipal levy or could utilize other sources of revenue. For example, CAs want the option of using self-generated revenue to support conservation (owned) land management, in addition to, or rather than, municipal levy.

The mandatory programs and services [proposed Section 21.1 (1)], to be prescribed in regulation, include the addition of: Conserving natural resources.

Conservation Authorities play a critical role as watershed and natural resource management agencies. As outlined in the Conservation Authorities Act (CAA), the objects of an authority are to “provide, in the area over which it has jurisdiction, programs and services designed to further the conservation, restoration, development and management of natural resources…” (Sec. 20(1)). Further, for the purposes of accomplishing its objects, an authority has the power to “study and investigate the watershed and to determine programs and services whereby the natural resources of the watershed may be conserved, restored, developed and managed” (Sec. 21(1)(a)). Watershed management has been the foundation for all CA programs and services since the inception of conservation authorities.

Being in nature restores people and helps them to stay active and healthy, reducing health care costs.

Including “conserving natural resources” as a mandatory program and eligible for municipal levy would recognize the important role that CAs play. This would be consistent with the “Made-in-Ontario Environment Plan.”

The scope of standards and requirements to be prescribed in regulations capture all key elements of the mandatory program and service area, be developed in consultation with conservation authorities, municipalities, and other stakeholders.

Of critical importance will be the development of standards and requirements for each of the core mandatory program areas and what constitutes eligible activities within each of the mandated areas.
The standards and requirements need to be framed to allow the specifics of each CA’s jurisdiction to dictate the relevance/applicability of each. For example, each CA has different natural hazards with different levels of risk based upon the specific geography of their jurisdiction and, as a further example, some CAs do not have flood and erosion control infrastructure (e.g. dams) to maintain or operate. This requires consultation with the municipalities within the watershed.