On behalf of the Township of…

On behalf of the Township of Mulmur, I am writing this letter to voice our concerns about the regional consolidation of conservation authorities. We would not support the regional consolidation as is currently proposed.
We recognize the Province of Ontario’s vision to create more efficient, and consistent standards for conservation authorities. Regional consolidation of Ontario’s conservation authorities could result in several benefits such as improved procedural efficiencies, enhanced operating systems for mapping and information management, support consistency as well as catalyzing implementation of best practices province wide. However, we don’t share your view that the benefits of regional consolidation of Ontario’s conservation authorities will supersede the many concerns voiced by rural municipalities.
Under the new re-alignment, the Township of Mulmur would become part of the Huron Superior Regional Conservation Authority. Small rural Ontario municipalities like ours could experience reduced local responsiveness, diluted community representation, disruption of established partnerships, reduced influence, slower response times, service continuity. There are also issues related to funding model misalignment, lack of a watershed focus, centralizations risks, implementation complexity and pace of amalgamation. Here’s a summary of the key concerns:
• Funding model misalignment. Conservation authorities were created by municipalities to deliver watershed-based resource management, hazard protection and local environmental stewardship. From discussions with our local conservation authority, we have learned that municipalities provide between 25% and 50% of funding for conservation authorities while the province contributes approximately 3%. This funding model helps align conservation authorities with the conditions, needs and local priorities of the watersheds they serve while providing a strong support system for municipalities at a local level. Will the regional consolidation have the same funding model as we currently have?

• Loss of local voice: Smaller municipalities fear their unique needs may be overshadowed by larger centers within the new regional authorities. What mechanisms will be in place to hear the feedback of smaller municipalities?

• Lack of a watershed focus. The new proposed regional conservation authorities often cover multiple watersheds in several instances. Often watersheds will have differing priorities. How will these priorities be implemented and outcomes tracked particularly when municipalities have differing needs across diverse watersheds? Consideration should be given to grouping conservation authorities that service the same lake basin.

• Reduced influence: With fewer seats at the table, rural communities may have less say in conservation priorities and funding allocations. How will local boards be integrated into the regional boards? What will the transition look like?

• Disruption of established relationships: Long-standing partnerships between local conservation authorities and municipalities may be weakened or lost during consolidation. Building relationships at the local level has helped expedite decisions and benefited local area stakeholders.

• Slower response times: Centralized operations could delay permitting, flood forecasting, and emergency response in remote or rural areas. The Nottawasaga Conservation Authority has made significant improvements in response times over the past 18 months. What mechanisms will be implemented centrally to monitor response times and take corrective action should they not be trending in the right direction.

• Concerns about service continuity: Despite assurances, municipalities worry that local programs may be deprioritized. How will work planning be done?

• Uncertainty around cost-sharing: Municipalities may face new or increased financial obligations under a restructured governance model. Is there any indication that the funding model may be different with a smaller number of conservation authorities.

• Centralization risks: The creation of the Ontario Provincial Conservation Agency may shift oversight away from local governance, raising concerns about transparency and accountability. Local science and data will need to be a cornerstone for decision making. Has any consideration been given to how local governance will be integrated into the new centralized model?

• Mismatch of priorities: Watershed-based jurisdictions may not align neatly with municipal boundaries, complicating coordination and planning. What approach will be taken to ensure an alignment of priorities?

• Complexity in implementation: Transitioning to new boundaries and governance structures could create confusion and administrative burden. What communication measures and transition plans are being considered as this change moves forward?

• Pace of amalgamation. Consideration should be given to phasing in some of the changes over a longer period. Some of the efficiency improvements could be expedited across the province while more time is dedicated to revisiting the proposed regional boundaries.

Based on the points noted above, the Township of Mulmur strongly objects to the regional consolidation of Ontario’s conservation authorities. The dissolution of accountability could occur should the regional consolidation move forward, which would negatively impact communities and watersheds equally.
Please provide documentation on how the consolidation of conservation authorities will address the concerns raised by the Township of Mulmur.
We request to be notified of all updates to ERO #025-1257.
We look forward to your feedback on our submission.
Sincerely,

Township of Mulmur