I am writing to share my…

I am writing to share my concerns regarding the proposed changes to the Conservation Authorities Act under ERO #025-1257.

While I fully understand the government’s need to address the housing crisis and reduce administrative costs, I am concerned about the potential unintended consequences of this proposal.

The proposal mentions that the consolidation of CAs will lead to an improvement, but I am left wondering how? I have not seen enough or perhaps am just not made aware of evidence to demonstrate that consolidating Ontario’s 36 conservation authorities into 7 regional bodies will achieve the proposed cost savings or improve service delivery as intended or initially proposed. Has a risk-benefit analysis been conducted? If so, could this be shared publicly to help stakeholders better understand the basis for these proposed changes?

Without this transparency, it’s difficult to assess how the changes will address the stated goals without risking disruption to critical services like flood management, water quality monitoring, and the protection of natural resources.

The proposed boundaries appear to be based on natural hydrological lines, which is an important consideration for effective watershed management. However, I’m concerned that the way these boundaries have been drawn may not fully account for the diverse local contexts and priorities of each conservation authority. For example, some authorities serve urban areas with complex infrastructure needs, while others focus on rural or agricultural landscapes that have different environmental pressures.

Question: How were these specific boundaries determined, and were local conditions and needs taken into account? Is there room to adjust the boundaries based on specific challenges faced by certain regions, particularly where the hydrological boundaries may not align perfectly with existing conservation programs or municipal planning?

How are the boundary criteria ‘Maintaining and balancing and enhancing’?

Given the potential disruption and little to say it will actually improve, maintain or balance things, perhaps a phased or pilot approach could be considered. Consolidating in stages or testing the changes in select regions would allow for a more measured evaluation of the impact and provide the opportunity to adjust the approach if needed ( unless this is already a stated goal, in which case it would be helpful to state it as a pilot program etc)

Thank you for considering this feedback.