Thank you for the…

Thank you for the opportunity to comment on this important matter. The government is right to want a conservation authority system that is more consistent, transparent and efficient, especially when it comes to supporting housing and economic growth. Standardizing certain aspects around fee structures, permitting, etc. are a great example of our government doing this.

I am in agreement with the comments about having the new agency streamline, modernize, and standardize many aspects of the CA world and encourage this to continue and believe that this alone would be sufficient to ensure that CA’s maintain the standards to ensure that municipalities that share CA’s will see a more streamlined process with less differences between them.

However, I am vehemently opposed to this proposed model of only 7 regional CA’s. There may be room for targeted, sensible consolidation in Ontario’s conservation system, but moving from thirty-six authorities to just seven would be a drastic shift. A merger of that scale could create a larger, more distant bureaucracy that is less responsive to local municipalities, developers and farmers — exactly the people who need timely service and value having a local municipal official or trusted member of staff they can call directly. The strength of the current model lies in local expertise: staff who understand their watershed and have the relationships to solve problems quickly. Losing that connection could slow approvals, create confusion and ultimately have the opposite effect of what the government intends.

I am concerned about the funding of this new agency. While Provincial funding will occur for some of it, there would be cost recovery from CA’s, which would be an additional cost to the CA’s which would increase their budgets, putting more pressure on taxpayers.

Additionally, there is talk of this new agency creating procurement policies and creating a VOR – however, CA’s are already able to participate in the Ontario VOR and therefore it shouldn’t be creating a new VOR but rather ensuring that the CA’s are participating in the Ontario on as they are currently allowed. This agency needs to review what CA’s are already doing and seeing the efficiencies already there before making sweeping changes without knowing what is occurring already.

I feel that while the goal of decreasing the number of CA’s that municipalities may have in their jurisdiction is admirable, the fact is that CA’s are watershed based and are each individual and unique in their features. This also takes away the ability for municipalities to have their voices heard for local priorities as there will be many more municipalities at the table and will blur the lines of individual watersheds and their importance.

Additionally, while the province does have legislation over CA’s, they do not provide for them financially. That is the municipalities with their levy and other revenue raised by CA’s. Therefore, I believe that it should be the municipalities making this decision through the current legislative ways detailed in the Conservation Authorities Act through the potential of amalgamation. Since this has not occurred, it means that municipalities do not feel that consolidation is necessary, relevant or required. In fact, earlier this year, there was some discussion about amalgamating the Nottawasaga Valley Conservation Authority with the Lake Simcoe Region Conservation Authority, but that idea was quickly and overwhelmingly opposed by most of the member municipalities.

Conservation authorities are largely funded by municipalities and their taxpayers, and locally accountable. If governance becomes more centralized under a provincial agency while local boards lose control, we could end up with a system where municipal dollars are being spent under provincial direction without municipal oversight. That would be a fundamental change to how Ontario’s watershed management system has operated for nearly seventy years — and not, in my view, a change for the better. I believe that this would also add additional costs to the taxpayers as they Province has already introduced this new agency with new employees that cost the taxpayer, along with knowing that since many CA’s are run very leanly (I do acknowledge that some of the larger CA’s may have some excess that could be trimmed – but you are talking about only a few out of the 36), that there would potentially more people needing to be hired. If not managed properly, this could add an additional layer of oversight and have costs grow astronomically.

Additionally, I also understand that there may be high overhead costs in some CA’s, for example, I know that the Toronto CA’s CAO makes over 300K annually, however, that is not the case for all CA’s where many of the CAO/GM’s make less than $100K annually. The majority of CA’s have had to be very fiscally responsible over the years, and I fear that creating larger ones, will only increase the costs and lose some of that fiscal responsibility they currently have.

I also have questions about governance under the proposed model. Conservation authorities are largely funded by municipalities and their taxpayers, and locally accountable. Under the current legislation, some CA’s have very large Boards. This will only increase the size of the Boards and make things more inefficient. Municipalities want a say, regardless of their size so under the current model, there could be over 100 people on the Board. Even changing the formula to something like 1 municipality, 1 Board member – would still mean very large Boards. These will result in more inefficiencies for this process.

While saying this, I understand that this is something that I am sure your government is going to go ahead with regardless of the above and would therefore like to submit an alternative solution. I believe that going to 7 regional CA’s is too drastic and would instead propose the below. I am not married to the names I have put; I just merged CA’s along with my rationale for some of them. My intent here was to maintain watershed boundaries, reduce the number of municipalities that have multiple CA’s while still ensuring that the boundaries are small enough to ensure local governance and priorities are still met.

1. Northern CA – Mattagami, Nickel District, North Bay/Mattawa, Sault St. Marie, Lakehead

This model makes more sense to include Lakehead CA then the current proposed model as North Bay/Mattawa is also on Lake Superior. It makes sense to keep the northern CA’s all together.

2. Northern St. Lawrence – Rideau, Mississippi

3. Southern St. Lawrence – Raisin, Catarqui, South Nation

4. Eastern Lake Ontario – Quinte, Crowe, Lower Trent

5. Central Lake Ontario – Ganaraska, Central Lake, Kawartha, Otonabee

6. Lake Simcoe – Lake Simcoe

Lake Simcoe is such a unique CA as it is the only CA with a specific act it has to follow and it would make it more confusing for it to be a part of another CA given these reasons. As such, and as it is the next most urbanized area, I would suggest that it is separate from other CA’s. However, if it were to be merged, I would suggest that it be merged with the Greater Toronto ones.

7. Georgian Bay – Nottawasaga, Grey Sauble

These 2 make sense together as they are part of Georgian Bay.

8. Lake Huron – Saugeen, Maitland, Ausable Bayfield

These are the ones on Lake Huron.

9. Greater Toronto – Toronto and Region, Credit Valley, Conservation Halton

Having the 3 combined into a greater Toronto model ensures that the municipalities within the greater Toronto area are not having multiple CA’s and keeps the 3 most urbanized CA’s together in a single model.

10. Western Lake Ontario – Hamilton, Niagara

11. Western Lake Erie – Essex, St. Clair

12. Thames River – Upper Thames, Lower Thames

Keeps the Thames River watersheds together.

13. Eastern Lake Erie – Grand River, Long Point, Kettle Creek, Catfish

Your questions with my answers – please note that these answers focus on my belief that the overall model for regional CA’s is not a good idea.

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

This is very challenging to answer when I have so many questions that I need answered before I can figure out any ideas on creating a successful transition or consolidation.

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

I don’t really believe there are any benefits – I believe this will only make things worse, less local and more overhead costs.

• 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?

That is a challenge without having an extremely large Board which would only add more chaos. Each municipality will and should have representatives and as it is, with the current model, there are some really large boards, and this would only make it worse if the intent is to keep local representation.

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

No – I believe that CA’s are doing it already.

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

I am not sure that they can – they will be too large, and the municipalities will lose their abilities to focus on local priorities.

Modernization does not require centralization. With strong local leadership, clear metrics and a customer-service mindset, we can achieve faster approvals, lower costs and better outcomes, all within the existing watershed framework. I believe it is best to modernize Ontario’s conservation authorities in a way that strengthens, rather than weakens, accountability and service to local communities.