Dear Minister and Members of…

Dear Minister and Members of the Consultation Team,

I am writing to express strong concern regarding the proposal to consolidate Ontario’s 36 conservation authorities (CAs) into just 7 regional CAs, as described in the recent notice. While I recognize the imperative for efficiency and consistency, I respectfully urge the Government to reconsider amalgamating so many local organizations into very large regional bodies, and instead focus on a central agency and permit-platform approach to achieve the stated goals.

Key concerns

Loss of local knowledge and responsiveness:
The current system of 36 CAs is able to reflect watershed-specific, municipal-specific and community-specific circumstances. As the proposal states: “Conservation authorities deliver programs and services that further the conservation, restoration, and management of natural resources.”

By merging many distinct jurisdictions into large regional authorities, the unique local institutional memory, relationships with local municipalities, Indigenous communities, volunteer stewards, and watershed-specific expertise may be diluted or lost.

The proposed criteria include: “Maintaining watershed-based jurisdictions … Aligning with natural hydrological boundaries” but balancing that with very large jurisdictions may mean the local voice is overshadowed.

Risk of reduced local accountability and slower decision-making:
One of the benefits the proposal identifies is improved consistency and turnaround times. However, larger agencies often bring increased bureaucracy, and decision-making may become more distant from local stakeholders. Municipalities may find themselves dealing with a much larger body, with less ability to influence decisions specific to their area, and less flexibility to adapt to emergent local issues (e.g., small-scale flooding, shoreline changes, farm drainage) that differ from one part of the region to another.

Watersheds are diverse – one-size may not fit all
Ontario’s watersheds and ecological-landscape units span from highly urbanized (e.g., Greater Toronto Area) to rural agricultural to remote northern landscapes. The capacities, risks, hazards, staffing needs and permit-complexities differ significantly. Consolidation into large regional bodies may blunt the ability to tailor responses to those differences. The proposal itself acknowledges the diversity of hazards (flooding, erosion, etc.) across jurisdictions.

Cost and disruption of transition
Merging 36 organizations into 7 will require major reorganizations: governance structures, staff realignment, harmonizing policies, fees, standards, permit processes, technical systems, records, IT platforms, etc. The risk of service interruption, loss of institutional memory, and confusion for municipalities, permit applicants, landowners and Indigenous partners is significant. The notice states that “service continuity … ensuring uninterrupted delivery of local conservation authority programes” is a criterion. But large scale transitions have historically carried delays, cost overruns and stakeholder frustration.

Undermining municipal–CA partnerships
Many of the current CAs have strong partnerships with municipalities, local conservation groups and Indigenous communities. These collaborative relationships may be weakened if the governance moves further from the local level. The proposal identifies “Relationships between conservation authorities and municipalities – Reducing administrative duplication and overlap … to simplify accountability and strengthen local partnerships.” Yet reducing the number of authorities from 36 to 7 may inadvertently degrade the municipal partnership because the “conservation authority” for a municipality may no longer be locally oriented, but rather part of a larger regional bureaucracy.

Why a central agency + permit/standardisation platform is a better alternative

Rather than the wholesale consolidation into 7 large regional authorities, I propose the following model, which more directly addresses the cited concerns (fragmentation, inconsistent standards, uneven turnaround times) while preserving local accountability and expertise:

Establish a central provincial agency (as proposed) to provide oversight, coordination, shared services, data collection/sharing, policy guidance, technical standards, training and common IT infrastructure. This would improve consistency across all CAs without eliminating local bodies.

Create a unified permit/approval platform — a province-wide digital system for CA permitting, standardized fee schedules (or transparent fee-structures), consistent criteria and processing benchmarks, shared technical review resources, and a common customer interface. That allows municipalities, landowners, developers, farmers and CAs to use a single portal‐experience with clear timeline expectations.

Maintain the local CA footprint — Allow the 36 (or a somewhat adjusted number) CAs to retain their local governance, watershed focus, staff and municipal relationships. They would continue doing the “on-the-ground” work: site inspections, local hazard assessments, watershed restoration, tree planting, local education, volunteer programs, flood forecasting, etc.

Shared services — The central agency can provide back‐office functions (e.g., IT, human resources, purchasing), technical centres of excellence (e.g., modelling, GIS, hydrology), and a provincial data repository. Local CAs can draw on these for capacity, while still retaining local decision-making and relationships.

Performance benchmarks — Set province‐wide service targets (e.g., permit turnaround times, inspection rates, hazard mapping updates) and monitor/benchmark all CAs. Provide incentives for achieving targets, and central agency support for those that lag.

This hybrid model addresses the Government’s goal of “reducing duplicative administrative costs, freeing up resources for front-line conservation” (from the notice) — because duplication is reduced via shared services and standardization, but local relevance and responsiveness are preserved.

Suspend plans to amalgamate into 7 regional CAs until a full, independent cost-benefit analysis is produced covering: governance costs, transition disruption, loss of local expertise, impacts on permit turnaround time, municipal relationships, Indigenous partnerships, and long-term service delivery.

Pilot the central agency + unified permit platform approach in one region or for one class of permitting (e.g., development in floodplains) before committing to full consolidation.

Engage municipalities, Indigenous communities and local CAs in detailed design of the permit portal, standards, service targets and shared services model — ensuring local voices shape the new system.

Retain local CA governance and avoid blanket amalgamation; instead consider optional regional collaborations or shared service centres where appropriate (e.g., in sparsely populated northern areas) rather than a province-wide one-size merge.

Ensure transparency and local accountability — Require each CA to publish annual performance data (service levels, permit backlog, fees, staffing) so municipalities and the public can assess efficiency and responsiveness.

Protect front-line service delivery — Any structural change must guarantee that local flood-warning systems, watershed monitoring, site inspections, and permit processing continue without interruption, and ideally improve.

Concluding remarks

In summary, while I support the objectives of improving consistency, efficiency and frontline service delivery, the proposed move to consolidate 36 conservation authorities into only 7 regional ones is too drastic and risks undermining local responsiveness, accountability, municipal partnerships and watershed-specific expertise. A central agency plus province-wide permit/standardization platform without forced large-scale amalgamation presents a balanced, less disruptive and more locally grounded path to achieving the same goals.

I urge the Ministry to reconsider the consolidation plan, adopt the alternative model proposed, and ensure that any changes to the structure of conservation authorities maintain robust local service, local governance, and the trusted relationships that serve Ontario’s watersheds and municipalities.

Thank you for the opportunity to submit comments. I hope these reflections prove helpful in guiding a more nuanced and effective reform.