November 27, 2025 RE: ERO…

November 27, 2025

RE: ERO posting 025-1257 Ontario and Conservation Authorities Merger Proposal

I recognize the provinces proposal to merge numerous regionally and spatially affiliated watershed conservation authorities in southern Ontario. The Ontario government is proposing to create a province-wide Ontario Provincial Conservation Agency (OPCA) which will effectively be another bureaucratic level with the aim to improving the province’s conservation authority system. The Province’s goals in amalgamating conservation authorities is too simplistic considering the broad range, depth and detailed work mandated by the Province bestowed upon the regional conservation authorities and is not completely valid.

As a Thunder Bay resident, I have always recognized that the Lakehead Regional Conservation Authority (LRCA) is unique in both its location and the region that it serves and therefore should not be amalgamated with conservation authorities with no watershed or municipal connection. The LRCA indicates they have over 70 years of detailed experience representing the local watershed, and we as citizens are confident in its ability to continue to serve our regions watershed under the direction of the new OPCA.

But, I am very opposed to the Province’s attempt to propose “Huron-Superior Regional Conservation Authority” boundary configuration as outlined in Environmental Registry Notice 025-1257, which proposes to consolidate the LRCA into another region located 1,500 kilometres south of the Lakehead Watershed with 72 other southern Ontario municipalities. This re-alignment is not logical and does not make any sense. There are so very few similarities between the northern and southern reflection. At the most basic level, the physiography namely the geography, geology (Canadian Shield “hard rock” vs. the Paleozoic limestone “soft rock”), climate (low risk vs. high risk of hurricane influence - i.e. Hazel stimulus for the original need for localized CA coverage), ecology (coniferous Boreal vs. deciduous Carolinian forests), and even the water (soft vs. hard) and watershed basins (Superior vs. Huron-Georgian Bay) of either CA are so different and do not complement either the northern or southern areas of interest within either CA. They are so incredibly different. In this proposed amalgamation, even the distances, culture and economy (resource-based vs. agricultural/manufacturing) of the northern region is disregarded between these very different regions.

As a precedent, the Province does recognize the unique northern and southern perspectives, the uniqueness, and regionally-distinct parts of the province, separated at the French River.
The LRCA is recommending the development of a stand-alone, independent Regional Conservation Authority, as the “Northwestern Ontario Regional Conservation Authority” to ensure that the interests of Northwestern Ontario are equitably represented. Additionally, the LRCA Board is also requesting that the Ministry engage directly with affected municipalities of the LRCA before finalizing any consolidation boundaries.

The Lakehead Regional Conservation Authority as do all the other CA undertake a broad range of programs, including flood forecasting and warning; development regulations; plan review; water monitoring; floodplain management; erosion mitigation; Source Water Protection; conservation lands; stewardship; and environmental education.

The LRCA currently oversees 2,719 km2 (23%) of the Lakehead watershed 11,526 km2 and provides these programs to the urban environment of the City of Thunder Bay (comprising 2 twps.), and the rural environments of the Municipalities of Neebing (5 twps.), Oliver-Paipoonge (2 twps.), and Shuniah (2 twps.), and to the Townships of Conmee (1 twp.), Dorion (1 twp.), Gillies (1 twp.), and O’Conner (1 twp.). Total population is estimated at 122,669 persons. Stats Can (2021 - Updated on: November 15, 2023).

The Province should also recognize the different types of Conservation Authorities in the north.
Therefore, I strongly urge the Province to amend their amalgamation of CA based upon regional differences into a Northwestern Ontario, Northeastern Ontario and Southern (collective) CA’s.

Respectfully submitted