Please see the attached…

Please see the attached letter including resolution of the City of Owen Sound Council, staff report CS-25-123, and attachments as the City's response to Bill 68 and the Environmental Registry of Ontario posting 025-1257.
In Summary:
Resolution No. S-251215-002 as follows:
"THAT in consideration of Staff Report CS-25-123 respecting Proposed Changes to the Conservation Authorities Act, City Council directs staff to:
1. Send this resolution, report and its attachments to the Province of Ontario as the City’s response to Bill 68 and the Environmental Registry of Ontario posting 025-1257; and
2. Forward this report to Paul Vickers, MPP for Bruce-Grey-Owen Sound, the Premier of Ontario, the Minister of the Environment, Conservation and Parks, the Minister of Natural Resources, the Minister of
Municipal Affairs and Housing, Grey Sauble Conservation Authority Board of Directors, all municipalities that are currently served by the Grey Sauble Conservation Authority, Conservation Ontario, and AMO."
Highlights:
Bill 68 is in effect, establishing the Ontario Provincial Conservation Agency to oversee Conservation Authorities and transition to a regional watershed-based framework.
Conservation Authorities were established at the request of municipalities, yet municipalities were not consulted on this change.
Owen Sound is proposed to be 1 of 80 municipalities within the jurisdiction of the Huron-Superior Regional Conservation Authority.
The province is seeking input on the proposed boundaries, transition, budget, and governance. Staff have significant concerns about:
o Maintaining voice as one of 80;
o Impact on budget;
o Erosion of relationship and responsiveness; and
o Loss of local knowledge.
The province has not undertaken a cost-benefit analysis or provided
proposed approaches for consideration.
Municipalities currently provide approximately 44% of total Grey
Sauble Conservation Authority funding, while the Province of
Ontario provides approximately 7%.
GSCA provides a variety of programs and services across a jurisdiction of 3,191 sq. km, by a team of 28 staff (plus seasonal), for $4.25 million. 49% of this budget is self-generated (not from levy or provincial funding).
Provincial funding has remained stagnant since 2019, and the province has frozen Conservation Authority fees for development review at 2022 levels. Conservation Authorities are left to assume or pass on to municipalities a larger share of annual operating costs attributed to development.
There was no ERO posting for Bill 68 and it was passed less than 30 days after the time of first reading.
AMO has not yet provided a full response to the province’s posting on these changes but states on their website: “The government is making changes but it is not providing any new, ongoing provincial funding to run conservation authorities effectively, while simultaneously creating a new provincial oversight agency and weakening local municipal leaders’ control over conservation and environmental protections.”
All CAs now operate under the same O.Reg. 41/24.
Hazardous lands, hazardous sites, flooding and different types of hazards are defined in the PPS, and these definitions apply across the province.
The province has the authority to standardize policies and procedures for Conservation Authorities without creating an additional level of bureaucracy or consolidating boundaries.
O.Reg. 41/24 includes Schedule 1 which stipulates the applicable flood standards for each CA in the province.
The standards applied should be those that best serve to protect the health, safety and property of Ontarians in their individual watersheds.
The province has the authority to mandate fees without creating a new Agency or regional CAs. Ensuring CAs have the necessary funding to undertake development review is a step the province could take immediately to speed up development review.
An entirely new overseeing agency and regional model is not necessary to overcome different staff and technical capabilities.
Considerations for Owen Sound
Conservation Authorities were created at the request of municipalities to respond to local conditions and have built long standing relationships with the communities they serve. They are substantially funded by the communities served. Conservation Authorities play a critical role in protecting people and property in Ontario from the impacts of erosion or flooding. Owen Sound relies on the expert local knowledge and ongoing relationships with GSCA staff to support many activities, including development review and permitting.
Conservation Authorities collectively own and manage thousands of hectares of land, much of which was donated or sold by local residents and entrusted to Conservation Authorities as a personal legacy for long-term protection, stewardship, and the public good, with the expectation that such lands would be cared for by locally governed Conservation Authorities.
Owen Sound residents benefit from GSCA lands within and close to the City and benefit from many programs and services they offer. The City has several properties owned jointly (e.g. West Rocks) and leased from GSCA (e.g. Bayshore).
Owen Sound and the other member municipalities have governed GSCA for decades, tailoring programs and services to local watershed needs, maintaining accountable service standards, and ensuring fair and predictable costs for ratepayers.
Bill 68 (Schedule 3) has legislated the creation of the Ontario Provincial Conservation Agency whose objects include overseeing Conservation Authorities and the transition to a regional watershed-based framework for Conservation Authorities in Ontario with municipal cost contribution yet to be defined.
Under this proposal, the GSCA would be consolidated into a new “Huron-Superior Regional Conservation Authority” that is over 23,000 square kilometers in size and consists of 80 municipalities.
The City of Owen Sound has had a record year of residential building permits (553 new residential units as of September 2025).
Owen Sound has a strong working relationship with GSCA which has resulted in a defensible policy framework to protect people and property from natural hazards with shared responsibility for implementation. GSCA works closely with City staff to ensure these homes and other buildings are appropriately located for long term return on investment.
Despite ongoing changes to the legislative framework, downloading of responsibility, and continually reduced funding (or funding that does not keep pace with inflation) both municipalities and Conservation Authorities strive to fulfill our legislated mandates and provide value added services to our ratepaying communities.
The province has proposed substantial changes to a system that has been working for decades without reasonable consultation with Conservation Authority Boards and municipalities that fund the system.
The province has provided no cost-benefit analysis to demonstrate how these changes will benefit municipalities and Ontario residents or achieve the stated intents. The province has not provided an estimate of the costs of the new Ontario Provincial Conservation Agency or regional conservation authority structure, shared how local interests would be represented at the regional level or how input will be considered, nor demonstrated an openness to local input in recent legislative changes.
For Owen Sound, this could mean:
- Significant loss of representation.
- Limited control of budgets and levies.
-No guarantee that local levies or fees will be invested locally.
-Merging of assets including land and reserves to a regional authority.
-Potential revisiting of existing legal agreements (lease, maintenance, etc.).
-Updates to land use policy to address legislated and operational changes.
-Reduced prioritization of local issues and priorities.
-Potential substantial transition costs related to rebranding, human resources, IT, and financial merging.
-Longer wait times for review of development applications. Given the provincial emphasis on timely decision making this is a significant concern. Owen Sound and GSCA have a well-established system for timely review and commenting on planning applications.
-Higher costs for permits and technical review as GSCA fees are less than other CAs.
- The creation of regional Conservation Authorities will create uncertainty for developers, stakeholders, and community organizations. This could lead to hesitancy in investing in development, hesitancy to enter into shared maintenance and land use agreements, or hesitancy to donate to ongoing conservation programs or new properties.
-Owen Sound has been calling on the province to provide more equitable, reliable, and sustainable means of funding Conservation Authorities since 2015. Instead, fees have been frozen limiting the ability of CAs to respond to increased development applications with increased staff.
Recommendations:
Owen Sound calls on the Government of Ontario to maintain local, independent, municipally governed, watershed-based Conservation Authorities to ensure strong local representation in decisions related to municipal levies, community-focused service delivery, and the protection and management of conservation lands.
Owen Sound does not support the proposed “Huron-Superior Regional Conservation Authority” boundary configuration outlined in Environmental Registry Notice 025-1257 as the proposal lacks sufficient justification, would significantly diminish local governance, and fails to recognize the effectiveness and efficiencies already achieved within existing watershed-based models. The existing watershed-based boundaries should be maintained.
Owen Sound affirms that large-scale regional consolidation is unnecessary, would introduce substantial transition costs, and would divert resources away from frontline watershed programs. The Council further asserts that restructuring at this scale would erode local decision-making, weaken municipal accountability, and disrupt long-standing community partnerships that are central to delivering responsive watershed management.
While Owen Sound supports provincial goals for consistent permit approval processes, shared services, and digital modernization, imposing a new topdown approach structure without strong local accountability and governance risks creating unnecessary cost, red-tape, and bureaucracy, thereby undermining efficiency and responsiveness to local community needs.
Owen Sound urges the Province to strengthen centralized standards, resources, and tools rather than undertaking broad structural amalgamation and to provide sustainable, predictable provincial funding across Conservation Authorities to enable local CAs to advance ongoing digitization and systemization work that has already resulted in improved efficiency and consistency in recent years.
Owen Sound calls on the province to undertake a cost-benefit analysis (including a workforce and geographical analysis) of the current system of Conservation Authorities against the proposed Regional system. Regionalization should only proceed if there are known performance indicator outcomes (KPIs) that will be improved by such a system.
Owen Sound requests that the Ministry engage meaningfully and collaboratively with affected municipalities, Conservation Authorities, and local Indigenous leaders and agencies before advancing any consolidation, to ensure that any changes reflect both local needs and the practical realities of implementation. Local solutions to local problems, as was originally intended by the Conservation Authorities Act.
Owen Sound cautions the province on implementing a new permitting portal without significant consultation with municipalities and potential users. Not all residents of Ontario have access to broadband internet, and not all residents of Ontario use digital tools even where they are available. Existing ministerial portals do not satisfactorily follow phases of development process and have added to application processing times for municipal staff. Should a new online permitting portal be implemented, that work can be undertaken within the existing conservation authority framework without requiring structural amalgamation.
Owen Sound supports the Lakehead Region Conservation Authority’s (LRCA) recommendation that would see LRCA remain a stand-alone Conservation Authority under any new regional model as they are the only Conservation Authority in northwestern Ontario.
With respect to speeding up development processes, Owen Sound reminds the province of the Minister’s message respecting the More Homes Built Faster Act:
“In some areas with upper- and lower-tier municipalities (for example, the City of Mississauga which is a part of the Region of Peel), both levels of government have input into development approvals. We’re proposing to focus responsibility for land use policies and approvals in the local, lower-tier municipality. This would give the public more influence over decisions, clarify responsibilities and improve efficiency.”
Local communities should retain influence over decisions that impact them directly and that they are paying for.