To: Minister of the…

To: Minister of the Environment, Conservation and Parks

From: Corporate Strategy and Government Relations, Town of Oakville
Date: December 17, 2025
Subject: ERO Response Re: Proposed boundaries for the regional consolidation of Ontario’s conservation authorities

The Town of Oakville offers the following comments in response to the Province’s request through ERO 025-1257 for input on the proposed boundaries and criteria for consolidating Ontario’s 36 conservation authorities into seven regional authorities. This proposal follows the Minister of the Environment, Conservation and Parks announcement of the Proposed Boundaries for the Regional Consolidation of Ontario’s Conservation Authorities that were introduced on November 6, 2025, as part of Bill 68, A Plan to Protect Ontario Act, to amend the Conservation Authorities Act to establish the Ontario Provincial Conservation Agency (OPCA) for centralized governance and to reduce the number of existing conservation authorities through regional consolidation.

The Town of Oakville appreciates the intent of improving consistency and efficiency across Ontario’s Conservation Authorities (CAs). However, based on our experience working directly with local conservation partners on land-use planning, flood management, and climate adaptation, the Town has significant concerns regarding the proposed consolidation’s implications for local service delivery, municipal finances, staff capacity, and the progress to meet climate action outcomes.

Comments to the Province

The Province’s proposed changes to the Conservation Authority Act have a meaningful impact on municipalities.

Governance Shift Toward Provincial Oversight
According to the Province, the proposed changes to conservation authorities aim to modernize environmental approvals, improve consistency across jurisdictions, and enhance permitting efficiency. These changes build on recent amendments under O. Reg. 41/24, which have already reduced the authorities’ powers—such as removing their ability to comment on stormwater management and natural heritage planning, while moving toward centralized control. The amendments expand ministerial oversight, allowing the Minister to override decisions, set standards and policies, and streamline approvals to support housing development.
The creation of the Ontario Provincial Conservation Agency introduces a top-down governance model that may weaken local responsiveness and community engagement. Centralization risks prioritizing provincial growth objectives over watershed-specific environmental needs, and reduced autonomy for regional authorities could lead to misalignment between municipal climate priorities and provincial direction.

Recommendation: The Town encourages maintaining local governance authority and requiring municipal co-development of regional priorities to ensure alignment with climate and growth planning frameworks.

Lack of Municipal Representation in Governance Structure
The proposed reduction from 36 conservation authority boards to 7 regional boards would significantly diminish Oakville’s representation and weaken local accountability in watershed governance. With fewer board seats, mid-sized municipalities like Oakville risk losing their role in the decision-making process that directly impacts local flooding, erosion control, and habitat protection. Governance could become dominated by larger urban centres or provincial priorities, reducing transparency and responsiveness to Oakville’s needs. Consolidation also threatens to erode local knowledge and expertise such as hydrogeologists, water resource engineers and biodiversity biologists which are critical for managing watershed-specific issues such as Sixteen Mile Creek flood mitigation and Bronte Creek habitat restoration. Larger regional boards may be slower to respond to localized challenges, and the diversity of interests, particularly those of smaller communities, could be overlooked. This shift risks weakening long-standing partnerships among Oakville, Conservation Halton, Credit Valley Conservation and other interested parties on climate adaptation, stormwater management, and natural heritage planning.

Recommendation: Oakville encourages the province to guarantee equitable municipal representation within each regional conservation authority, ensuring inclusion of urban, rural, and upper- and lower-tier municipalities. Representation should reflect the diversity of watershed communities to maintain accountability, preserve local expertise, and support integrated watershed management.

Impacts on Climate Action Capacity and Broader Municipal Climate Implications
The proposed consolidation framework does not adequately address climate adaptation or mitigation impacts and risks reducing the effectiveness of Oakville’s climate action efforts. Regionalized authorities may prioritize standardized regulatory functions over place-based resilience and adaptation projects, undermining the flexibility needed to respond to local challenges such as Sixteen Mile Creek flood risk and Bronte Creek habitat restoration. Oakville’s climate team relies heavily on Conservation Halton for floodplain mapping, watershed modeling, and ecosystem restoration—resources that could become stretched across larger regions. Redirecting staff time toward administrative restructuring will delay on-the-ground climate projects and weaken coordination with local effort on climate action.

More broadly, Conservation Halton is a core delivery partner in Ontario’s climate resilience strategy. A shift toward centralized, development-focused governance will inevitably reduce municipal capacity to deliver measurable outcomes in adaptation, biodiversity protection, and carbon sequestration. Without sustained local collaboration, Ontario risks slowing implementation of critical initiatives such as:

• Natural asset management programs
• Flood mitigation and stormwater resilience projects
• Urban forest and green infrastructure expansion
• Wetland and watershed restoration initiatives
• Integrated climate and land-use planning

Recommendation: The town urges the Province to ensure regional conservation authorities maintain capacity for local climate action. This includes dedicated resources for floodplain mapping, watershed modeling, and ecosystem restoration within Oakville, and alignment with municipal plans. Safeguarding these functions will prevent delays and protect progress on natural asset management, stormwater resilience, and urban forest expansion.

Impacts on Municipal and Land-Use Planning and Greenspaces
For the Town of Oakville, the proposed consolidation of conservation authorities presents significant challenges to both municipal planning and the stewardship of our parks and natural heritage systems. The town’s planning staff relies on conservation authorities’ local expertise to navigate complex watershed conditions, floodplain management, spill hazards and ecological sensitivities—knowledge that cannot be easily replicated under a regionalized model. Centralizing governance risks slower response times, transitional uncertainty, and a shift toward political rather than science-based decision-making, which could compromise the integrity of planning outcomes. At the same time, Oakville’s greenspaces, such as Bronte Creek, Sixteen Mile Creek, and the extensive trail network are vital ecological corridors and community assets that require ongoing, locally informed care and maintenance. Moving to a larger regional structure will weaken partnerships with the conservation authorities, volunteers and schools, reduce investment in restoration and maintenance, and increase municipal costs to fill service gaps. At a time when climate resilience and public access to nature are more important than ever, these changes will undermine decades of progress in environmental protection and community engagement.

Recommendation: The province should implement a phased approach to consolidation that safeguards local expertise and service delivery. For Oakville, this means maintaining regional advisory panels that include former Conservation Authority staff and municipal representatives to ensure site-specific knowledge informs planning and greenspace management. The province should also provide transition funding to offset municipal costs for system integration, staff training, and potential service gaps. Finally, a formal review within two years should assess the impacts on planning timelines, environmental protection, and greenspace stewardship, with adjustments made to preserve community priorities.
Financial Risks of Consolidation
The proposed consolidation of 36 conservation authorities into 7 regional bodies presents significant and unaccounted-for transition costs. These include system integration, data harmonization, and governance restructuring—expenses that are typically underestimated. Without clear long-term provincial funding commitments, a clear cost-benefit analysis or guaranteed long-term savings, these changes risk creating a more expensive and less responsive system.

Recommendation: The Province must fully fund all transition costs to minimize financial impacts on municipalities and prevent diversion of resources from critical climate and infrastructure priorities.

Risk to Local Program Continuity and Relationships
The proposed consolidation threatens the continuity of Oakville’s local stewardship, restoration, and community education programs—initiatives that are central to the Town’s climate action and biodiversity strategies. These programs rely on strong, place-based partnerships among Credit Valley Conservation, Conservation Halton, the Town of Oakville, and local interest groups. Any lapse in delivery during the transition will disrupt ongoing collaborations, erode decades of trust, and weaken public confidence in environmental governance.

Conservation authority staff possess deep knowledge of Oakville’s watersheds, municipal infrastructure, and community priorities. Consolidation into larger regional bodies risks weakening these critical working relationships and reducing the effectiveness of watershed management. Regional authorities may lead to reduced accessibility for Oakville residents and staff, slowing approvals and impairing on-the-ground implementation of climate adaptation and restoration projects. Larger, centralized structures may also struggle to address site-specific issues promptly, impacting flood mitigation along creeks like Sixteen Mile and Bronte, habitat restoration in sensitive areas, and climate resilience efforts that Oakville has prioritized.

Recommendation: The town expects that interim continuity agreements be maintained to ensure uninterrupted delivery of existing programs during the transition period. Additionally, preserve local liaison offices and staffing within each watershed to maintain service continuity, safeguard collaborative relationships, and ensure timely, community-informed decision-making.

ERO Discussion Questions:

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

For Oakville, we are requesting reconsideration of regional conservation authority consolidation for CH and CVC. The transition to a centralized governance model under the OPCA must prioritize:

-continuity of local service delivery;
-climate resilience initiatives;
-equitable municipal and Indigenous representation;
-retention of local expertise; and
-preservation of long-standing partnerships between the Town, CH, CVC, and community stakeholders.

A transparent transition framework incorporating the above with clear timelines and accountability measures is essential to maintain public confidence and prevent service gaps.

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

Transitioning to centralized governance under the OPCA offers potential for improved collaboration, resource sharing, and consistent regulatory processes without immediate boundary changes. Benefits could include streamlined permitting, access to shared specialized expertise, and efficiencies in data collection and watershed modelling while maintaining existing CA boundaries.

3. 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?

Governance at the regional conservation authority level should be designed to balance efficiency with strong local accountability, especially for municipalities like Oakville. The board size should be sufficient to represent the diversity of municipalities within each watershed region, including rural, urban, and upper- and lower-tier municipalities. Equitable representation is critical to prevent governance from being dominated by large urban centres or provincial priorities. The appointment process should ensure transparency and fairness, with municipalities nominating representatives based on expertise in environmental planning, watershed management, and climate resilience. Consideration should also be given to including non-municipal stakeholders, such as Indigenous communities and conservation partners, to maintain inclusive decision-making. A governance model that combines regional coordination with local input will help protect natural spaces while enabling authorities to provide expert knowledge and scrutinize development proposals effectively. With 28 municipalities proposed for the Western Lake Ontario RCA, effective local governance is unlikely. Oakville recommends retaining CH and CVC boundaries through OPCA transition to preserve accountability and watershed specific expertise.

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

To maintain a transparent and consultative budgeting process across member municipalities within a regional conservation authority, the Province should require a standardized framework that emphasizes openness, equity, and collaboration. Annual budgets should be developed through a clear, multi-step process that includes early engagement with all member municipalities, public disclosure of draft budgets, and opportunities for feedback before final approval. Appropriate representation must be guaranteed in budget deliberations to ensure diverse priorities are reflected. Additionally, detailed reporting on levy calculations, cost-sharing formulas, and program allocations should be published in accessible formats to build trust and accountability. Consideration should also be given to establishing joint municipal advisory committees to review budgets and monitor financial performance throughout the year. These measures will help ensure that fiscal decisions remain transparent, equitable, and aligned with both provincial objectives and local environmental priorities.

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

The Town is concerned that the size of and number of member municipalities for the proposed RCAs will not be conducive to maintaining and strengthening relationships with local communities and stakeholders.

If RCAs proceed, embed strong local engagement practices:
Ensure dedicated CA staff remain accessible within local branches that mirror original CA boundaries
Maintain advisory committees, workshops, and joint planning sessions
Provide transparent reporting on projects affecting Sixteen Mile Creek, Bronte Creek and other sensitive areas
Continue collaboration at current levels on climate action and natural heritage initiatives to sustain trust and effective governance.