Comments: Overall • the…

Comments:
Overall
• the proposal IMO does not present itself as a feasibility study to justify the Amalgamations. The claims are not justified with evidence or proof of stated issues.
• The proposal does not recognize the importance of Provincial Wide delivery, that the same or similar issues exist outside of CAs that need to be addressed, it only favours CA’s and hence could widen the gap in capability in overall Provincial delivery, inside and outside of
• The proposal does not recognize the responsibilities of other Provincial Agencies like MNR which is by Order-in-council is the lead for emergencies such as and not limited to flood, including flood forecasting drought and dam failure. These are not responsibilities originating from the Conservation Authorities Act. Imp[acts on these programs needs to be evaluated
• The Province’s Strategy for flood has many recommendations for Conservation Authority Improvements, however, the Proposal does not seem to place value on those recommendations in making CA improvements as another justification for change. The flood strategy itself does not propose amalgamations for improvements. So it would appear the need for amalgamation is not science driven but solely for administrative purposes.
Proposal Background
“The current system of 36 separate conservation authorities is fragmented, with each conservation authority following different policies, standards, fees and levels of staffing and technical capabilities. This has led to unpredictable and inconsistent turnaround times for approvals across all conservation authorities, creating uncertainty and delays for builders, landowners and farmers seeking permits, and undermining conservation authorities’ ability to protect communities from floods and natural hazards.”
• These are unproven claims for the commentators, that should be provided based on evidence. As they stand is the expectation that the public will accept these claims based on blind faith?
Proposal Improving Conservation Authorities
These proposed improvements to the conservation authority system would reduce duplicative administrative costs, free-up resources for frontline conservation, and better align conservation authorities’ services with provincial priorities on housing, the economy, infrastructure and climate resilience.
• Once again these are unfounded claims which stand as speculations or opinion, the burden of proof rests with the proposing agency to prove there is an issue in order to support recommendations for improvement.
• If the intent is to make improvements then why isn’t Ontario’s recent flood strategy being used as a supporting document?
Proposal Agency Creation
• It would seem with the creation of an agency that the government wants to distance itself from Conservation Authorities, while at the same time the government is responsible for program delivery outside of conservations authorities, such as and not limited to flood forecasting and warning. It would seem then the Province is prejudiced in not looking at the issues holistically (Provincial scale), showing favoritism for Municipalities within CAS and ignoring those with the same issues, outside of CAs.
• The Emergency Management and Civil Protection Act and its associated Ontario Regulation establishes Ontario’s legal basis and framework for managing emergencies and assigns roles and responsibilities to several provincial ministries. The Ministry of Natural Resources would still need to be directly involved with Conservation Authorities as MNR has the Provincial mandate for Emergency response and preparedness for floods (including flood forecasting), dam failures, drought among others via Order In Council. In that manner the proposal neglects impact on MNR’s OIC mandates, and Provincial wide program delivery outside of Conservation Authorities.
References:
Protecting People and Property: Ontario’s Flooding Strategy