I am writing to express my…

I am writing to express my strong opposition to the proposed amalgamation of Ontario’s 36 Conservation Authorities (CAs) into seven regional entities, as outlined in Bill 68 and the accompanying Environmental Registry proposal.

While I support efforts to improve efficiency and consistency, the scale of the proposed restructuring is unnecessary and risks weakening the very strengths that have made Ontario’s CAs effective for decades. Conservation Authorities were created by municipalities to respond to local watershed conditions, and most have built more than 60 years of trusted, place-based expertise. Their value lies in their deep relationships with municipalities, landowners, and communities—relationships that cannot be replicated by large, regionalized bodies.

The Ministry’s concerns about inconsistent policies and service levels are not new and stem from decades of reduced provincial funding and guidance, not from flaws in the CA model. These issues can be addressed through targeted policy alignment, resource support, and collaboration, not by dismantling local organizations. In addition, housing delays that the Ministry attributes to CAs are not founded in real data, and when delays occur, they arise because proposed developments are located in unsafe or unsuitable areas. Maintaining public safety should not be compromised for administrative convenience.

In addition to these concerns, the proposal leaves significant uncertainty regarding the future of drinking water source protection under the Clean Water Act. Although the proposal states that new regional CAs will continue watershed-based management and deliver provincially mandated programs, it is unclear whether amalgamation will alter the boundaries of existing source protection areas and regions. As source protection areas are tied to conservation authority jurisdictions, the proposed newly amalgamated CAs could impact source protection authorities, the composition of source protection committees, and source protection plans and associated Assessment Reports. Changes to source protection areas, source protection regions and boards would lead to a significant administrative and technical burden for municipal and CA staff.

The geographic scale of the seven proposed conservation authority regions—with the Eastern Lake Ontario CA alone exceeding 25,000 km²—will make it extremely difficult for staff to maintain local presence, conduct fieldwork efficiently, or provide accessible public service. This will create new inefficiencies, increase travel time (including additional environmental impacts), and diminish the local stewardship that residents and municipalities rely on. Governance challenges are also significant, and effective representation and relationship-building would be nearly impossible under the proposed structure.

Conservation Authorities have already invested substantial time and resources in meeting recent legislative changes. Imposing a full structural overhaul now will divert funds away from core watershed management activities and from source water protection program delivery, without improving outcomes for residents, municipalities, or the Province. Proactive engagement and transparency from the Ministry on potential impacts—including cumulative effects—would enable stakeholders to comment more meaningfully and plan appropriately.

I urge the Ministry to pause the proposed amalgamation and instead pursue collaborative, evidence-based solutions such as targeted consolidations where appropriate, enhanced provincial support, and coordinated policy development. Ontario’s watershed management system needs partnership and stability, not a wholesale reorganization that risks undermining foundational programs like source water protection.

Thank you for considering these concerns. I respectfully request that the Ministry reconsider the amalgamation proposal in favour of a more balanced, locally responsive, and protective approach.