Kawartha Conservation ERO …

Kawartha Conservation ERO #025-1257 Submission Comments
(December 19, 2025):

The following submission outlines Kawartha Conservation’s comments in response to Environmental Registry of Ontario Posting #025-1257, which seeks input on the proposed regional consolidation of conservation authorities. These comments are informed by discussions of the Kawartha Conservation Board of Directors and reflect both governance oversight and operational experience delivering conservation authority programs and services at the watershed scale.

Kawartha Conservation recognizes the Province’s objectives of improving consistency, efficiency, and modernization across the conservation authorities. The comments below are intended to be constructive and informed by local accountability and operational experience, to assist the Province in evaluating transition models that achieve these objectives while maintaining effective governance, accountable service delivery, fiscal prudence, and strong municipal partnerships.

The responses that follow are structured to directly address the questions posed in the ERO posting and focus on practical considerations related to the proposed transition of the conservation authority framework.

What do you see as key factors to support a successful transition and outcome of regional conservation authority consolidation?

Evidence-based decision-making before implementation

• The Province’s objectives related to consistency, efficiency, and speed of service can be advanced immediately within the existing 36 conservation authority framework through provincially led standards, shared tools, staff collaboration, and digital permitting systems. These measures should be implemented and evaluated first, allowing for work processes to be aligned, performance to be determined and testing of the assumption that efficiencies are to be gained through consolidation.

• Decisions regarding any potential structural change must be informed by a rigorous cost-benefit analysis (transition and steady-state), consistent with standard public-sector business practice. This analysis must meaningfully involve municipalities and conservation authorities, who understand both the operational realities and local service impacts. Structural change should not proceed where substantive, demonstrable gains cannot be clearly established.

• Where challenges or inefficiencies are identified, alternative approaches—such as shared services, regional collaboration agreements, or targeted functional integration—should be explored and exhausted before any consideration of consolidation.
 
Stable provincial transition funding and clear “who pays” rules

• Any provincially directed modernization initiatives must be accompanied by stable, multi-year provincial funding to avoid cost pressures being downloaded onto municipalities and ratepayers.

• Clear and transparent rules regarding “who pays” are essential. New provincial initiatives, including those associated with the Ontario Provincial Conservation Agency (OPCA), should not introduce additional financial burdens during periods of transition or change.
Service-continuity

• Protecting uninterrupted delivery of natural hazard management, permitting, planning, and environmental services must be a foundational consideration. Demonstrated service improvements through the implementation of standards and standardization objects of the OPCA should precede any structural change.

• The uncertainty associated with major structural reform presents a significant risk to workforce stability, recruitment, and retention. Disruption to experienced staff undermines the Province’s objectives related to efficiency, timeliness, and service quality.

• Any change initiative must explicitly prioritize continuity of service, institutional knowledge, and organizational capacity.

A “local by design” operating model

• Municipal support and confidence are critical to success in the conservation authority model. Without strong municipal buy-in, risks include fiscal uncertainty, reduced effectiveness, and erosion of accountability. Maintaining strong local governance relationships is critical to the success of conservation authorities.

• Ontario’s watersheds and conservation authority jurisdictions are geographically large and diverse. Effective service delivery requires local offices, local staff, and locally informed decision-making. Centralized models are not well-suited to regions that require extensive travel and have variable watershed conditions.

• It is imperative to have local offices and local people to facilitate effective programs and services. This is key for the delivery of natural hazard programming, permitting and planning for the community as well as other services provided, where people can physically interact with local staff who know the area and can provide informed answers.

• Preserving place-based knowledge through local watershed teams and advisory structures with real influence is essential to maintaining service quality and public trust.

• Meaningful engagement with communities, municipalities and conservation authorities should occur at the watershed scale to ensure local conditions, risks, and priorities are understood and reflected in any provincial initiatives.

Standards first, consolidation second

• If consistency and performance improvement are the primary objectives, the Province should first finalize, fund, and implement provincial service standards, consistent policies, shared digital platforms, and performance metrics.

• The direction-making authorities outlined in Bill 68—covering standards, IT, procurement, training, asset management, and strategic planning—provide ample tools to achieve consistency without requiring consolidation.

• Only after these measures are fully implemented and evaluated should any further structural changes be contemplated, and only where clear, incremental value can be demonstrated.

What opportunities or benefits may come from a regional conservation authority framework?

Potential benefits of partnering and sharing staff between conservation authorities include:

• Improved access to specialized expertise (e.g., hydrogeology, geomorphology, legal and complex planning files) through shared service arrangements and voluntary staff mobilization during peak demand periods such as floods, major development cycles or significant weather events impacting properties.

• Efficiencies through shared corporate services (IT licensing, fleet, insurance, purchasing).

• Enhanced regional-scale scientific collaboration for broader watershed analysis, climate resilience planning, and cumulative effects assessment—while recognizing the importance of strong local-scale science and community-specific knowledge.

It is important to note that many of these benefits already occur today through voluntary inter-authority collaboration. We have shared staff historically with other authorities related to specialized IT, engineering and ecology on a long-term basis, and partner with other conservation authorities on a variety of geographically scalable projects (regional to local community) where it makes demonstrable sense to do so (e.g. planning, engineering, hydrogeological, IT and Risk Management Official expertise).
The sharing of staff would be made easier though templated agreements. Any proposed changes must therefore demonstrate clear net new benefits beyond what can already be achieved through shared services and supported standards.

 
Do you have suggestions for how governance could be structured at the regional conservation authority level, including suggestions around board size, make-up and the municipal representative appointment process?

Any governance framework must:
• preserve strong local representation for municipalities and taxpayers,
• remain strategically effective, and
• maintain equitable representation

Models that significantly dilute local voice or create excessively large, symbolic boards risk being cumbersome and ineffective. Governance approaches should prioritize clarity of roles, accountability, and meaningful municipal participation.

Where broader coordination is required, networked governance models—retaining strong local boards with defined roles while enabling strategic coordination—may offer a more balanced and effective approach than full consolidation.

Consideration should be given to Indigenous participation in governance structures.

Do you have suggestions on how to maintain a transparent and consultative budgeting process across member municipalities within a regional conservation authority?

Clear, standardized budget reporting
• Annual budget documents should continue to clearly identify program and service costs, capital needs, asset management requirements, and service outcomes in a consistent and comparable format.

Separation of funding streams
• The budget presentation should clearly distinguish:
o provincially-directed costs (Agency directions)
o provincial supports for programs and services
o municipal supports for programs and services
o locally delivered programs and capital works.

Guardrails to protect local priorities
• Policies must ensure that locally funded priorities and assets cannot be reallocated without municipal agreement, protecting investments made by municipalities in their own communities.
 
Predictable and local consultation
• Budget consultation processes must be structured, timely, and aligned with municipal budget cycles, including multi-year forecasts (e.g. 3 or 5 year) to support municipal financial planning and stability.

How can regional conservation authorities maintain and strengthen relationships with local communities and stakeholders?

Keep local presence real
• Maintain local offices, local staff, and local contact points for programs and services. These points of contact are essential to effective service delivery and community trust.

Protect watershed identity and place-based knowledge
• Through consistency measures, a “one system, many watersheds” model will emerge with the OPCA efforts for standardization. A tangible sense of place must be identifiable to a community or municipality, with actions or plans tied to that same space.
• While standardization allows for greater consistency, flexibility must remain to address local conditions and support positive innovations for specific contexts. It is this creativity and customer service-oriented outlook that conservation authorities are known and appreciated for.
Strengthen transparency and accountability locally
• Communications, reporting, and performance measures should be clearly tied to local communities and watersheds, enabling municipalities and residents to understand outcomes that affect them directly

Additional Comments:

Support tied to Guidance
At this time, the principal gap in direction relates to the timely identification, interpretation, and resourcing of common provincial standards. Many of the Province’s stated objectives—such as uniformity, improved service delivery, and consistent application of standards—can be meaningfully advanced within the existing conservation authority framework, provided that these standards are finalized, clearly articulated, and adequately supported for administration by the Agency.

While significant legislative changes have been introduced in recent years, provincial guidance and implementation support would assist conservation authorities in achieving consistent interpretation and application across jurisdictions. Strengthened communication, transitional guidance, and shared tools would reduce variability in processes and outcomes, addressing many of the challenges put forward.

Focusing the OPCA’s first term on common tools, standards, and guidelines would deliver the greatest gains toward the Province’s objectives of consistency and housing delivery. Allowing conservation authorities time to implement these measures and meet defined targets is more effective than undertaking structural change simultaneously. A 3-year focus on these efforts, aligned with the OPCA’s first term, would support effective implementation and evidence-based assessment.

Development of Guidelines, Policies and other Resource materials
To ensure that provincially developed policies, guidelines, and implementation tools remain scientifically sound and locally relevant, their development would benefit from structured consultation with conservation authorities, municipalities and other stakeholders that possess detailed, place-based knowledge of these systems. Early and ongoing engagement in the determination of such materials would help ensure that provincial direction is practical, evidence-based, and responsive to local hydrologic, geomorphic, and land-use conditions, thereby supporting consistent application while avoiding unintended regional or community-level impacts.

Boundary Alignment Considerations
It is recommended that conservation authority boundaries be aligned, to the greatest extent possible, with the best science available for delineating watershed boundaries to avoid duplicative administrative layers. Advancements in technology have enabled more defensible watershed-based frameworks and would help reduce administrative duplication, support coherent watershed management, and enhance consistency in planning, implementation, and oversight.

Governmental Transparency
The OPCA should be accountable to the public as well as to stakeholders that are responsible for funding their operation. Transparency measures identified in the Conservation Authorities Act for current conservation authority governance should be mirrored by the OPCA (public meetings, agendas, minutes, membership, etc.). Similarly, financial transparency to conservation authorities as a financial stakeholder in the OPCA is needed, tied to annual reporting on outcomes of the levy support. Representation on the OPCA board, particularly if apportionment provisions are enacted would represent an open, transparent and accountable governance model.