RE: Proposed boundaries for…

RE: Proposed boundaries for the regional consolidation of Ontario’s conservation authorities
ERO number: 025-1257

When the “Proposed Boundaries for the Regional Consolidation of Ontario’s Conservation Authorities” was first announced, my immediate reaction was, “Wait, what?” How could the Ontario Government move to consolidate Ontario’s 36 Conservation Authorities without meaningful consultation with the people of Ontario—First Nations, Métis and other Indigenous communities, municipalities, and residents/taxpayers? Changes of this magnitude come with real costs in time and money, and they risk disrupting services through rebranding, staffing changes, organizational restructuring, marketing, and all of the other shifts that accompany a merger.

Instead of imposing a top‑down restructuring, why not start with genuine consultations to identify deficiencies and clarify where each Conservation Authority needs improvement? What, exactly, will be gained by consolidation—and at what cost? As a taxpayer, the question is simple: how much will this actually cost me? These changes also appear to ignore the significant efforts toward Truth and Reconciliation underway across Canada, including Ontario. Local municipalities and First Nations, who have spent decades working with multiple Conservation Authorities, would have valuable insights to offer on how to improve the existing system.

In any relationship, when there is a problem or a perceived wrong, the most constructive first step is to go directly to the people involved to seek resolution. The issue is rarely resolved by talking to outsiders or spreading incomplete or misleading information. Why can’t the province explore changes to policies, standards, and coordination without redrawing the watershed boundaries themselves? A series of meetings with individual Conservation Authorities and Conservation Ontario could examine the potential benefits of standardizing planning, permitting, and human‑resources policies—without dismantling locally grounded governance structures.

Conservation Authorities have been managing watersheds in Ontario for nearly 80 years. A watershed is an area of land that drains into a particular body of water, and Conservation Authorities are organized around these natural boundaries rather than political ones. That is one of their greatest strengths. For eight decades, they have worked for the people of Ontario, including previous generations, within this watershed‑based framework. Why should 36 established organizations with deep local roots lose their say in how this work continues? Ending these long‑standing, trust‑based relationships between local Conservation Authorities, watershed residents, and municipalities feels blindsiding and underhanded.

Living within the jurisdiction of the Upper Thames River Conservation Authority (UTRCA), there is firsthand experience of how effective a locally focused authority can be. UTRCA is transparent and authentic, has the science and technical expertise needed, and staff are readily available by phone to respond to complaints, suggestions, or information requests. They have the staffing levels and technical capacity to meet the needs of their watershed. Where the Government of Ontario might see “fragmentation,” many residents see a system that is appropriately tailored and locally focused. UTRCA, like all Conservation Authorities, operates under the policies and standards mandated by the Conservation Authorities Act, which is defined by the provincial government.

Concerns about “inconsistency” and “uncertainty” are often linked to the time required to review and apply the Conservation Authorities Act. However, staff within each Conservation Authority provide consistency precisely because they work within a specific watershed context, with stable teams, a clear local focus, and deep knowledge of their landscapes. To maintain and strengthen community connections, it is critical to keep local offices, staff, and programs in place and to continue honouring agreements related to multi‑year initiatives, donations, and ongoing projects. Fees are regularly compared with neighbouring Conservation Authorities to ensure they remain fair for the communities they serve, avoiding both gouging and under‑charging.

Just as housing prices vary across Ontario for many legitimate reasons, it is reasonable that fee structures differ between watersheds. Residents in one region, such as Toronto, generally expect to pay different rates than those in smaller centres. The funding structure of a Conservation Authority is set out by the Ontario Government and is based on the number of tax‑paying residents within the jurisdiction of a given watershed. Larger development projects inevitably require more staff time and are assessed under the Conservation Authorities Act. That framework should not change. Thorough review of development proposals, including mitigation measures where needed, is essential to protecting people, property, and ecosystems.

Most core funding goes toward permitting and regulatory responsibilities. Additional programs and services are supported through user fees or grants, which are only pursued when a clear need is identified. Conservation Authorities are widely recognized for their ability to stretch funding and maximize the impact of every dollar. Under a large consolidated model, what will happen to these additional, locally tailored programs and services? It is reasonable to fear that many will disappear. If Conservation Authorities are no longer considered arm’s‑length or non‑governmental organizations, they may become ineligible for certain grants due to closer association with the provincial government. This would directly jeopardize many valued programs.

The proposed changes risk introducing chaos, confusion, and instability into a system that currently provides crucial stability for local ecosystems and watersheds. In a time of rapid climate change, with water as one of the most powerful forces shaping land and human life, weakening watershed‑based management undermines overall climate resilience. Managing mitigation and adaptation at the watershed scale is both logical and effective. Organizations such as Partners for Action already struggle to get flood‑risk information to communities across Canada, while within the 36 Conservation Authority jurisdictions, this kind of outreach is part of their core mandate. Without strong local watershed governance, residents may be left without clear guidance on flood risks, preparedness, and resilience planning. https://conservationontario.ca/policy-priorities/climate-change/mitigat…

Insurance is another critical concern. Many homeowners across Canada already struggle to obtain flood insurance or face exclusions in their policies, especially where there is no strong governance preventing development in floodplains. In Ontario, the presence of 36 watershed‑based authorities helps ensure responsible planning and regulation, so that many communities experience fewer insurance problems and reduced flood risk. If these authorities are consolidated into large regional bodies that are no longer closely tied to specific watersheds, the locally focused information, relationships, and sense of responsibility that currently exist will be diluted or lost. https://uwaterloo.ca/partners-for-action/our-research/flood-insurance

The proposed new regional boundaries do not appear to align with existing Conservation Authority jurisdictions. In the newly proposed Lake Erie Regional Conservation Authority, for example, the area covered is vast, spanning southwestern Ontario watersheds draining into Lake Erie, including the Thames, Grand, and Sydenham systems. Yet Perth County, which is a headwaters area for many systems, does not naturally drain toward Lake Erie. From Stratford, for instance, water flows toward Lake St. Clair. Consolidation would also dramatically expand board representation—from something like 17 municipal directors to more than 80 municipalities—making individual representation and meaningful municipal voice impractical.

Each Conservation Authority currently has a board of directors, largely composed of municipal officials from within the watershed. This structure ensures that local municipalities have a direct voice in governance and decision‑making. Under a large regional authority, how will any single municipality ensure its concerns are heard among so many others? Smaller, watershed‑aligned boundaries actually improve accountability, reduce overall costs, and support timely processing of permits. Bigger is not always better—especially when the issues are technical, place‑based, and tied to long‑standing relationships and local knowledge.

Another important question is why the Ontario Government needs to create a new Ontario Provincial Conservation Agency when Conservation Authorities already have a representative body: Conservation Ontario. Conservation Ontario provides centralized leadership and strategic direction, communicates policy changes, and offers training and program support to local Conservation Authorities. It is a small organization, but highly effective in its role. In addition, neighbouring Conservation Authorities already have formal partnerships and agreements that allow them to deliver consistent, efficient, and transparent programs and services across boundaries where needed.

The current system is more like a carefully assembled watershed puzzle than a scattered collection of unrelated pieces. Taking that puzzle apart, tossing the pieces into the air, and hoping they land in a better arrangement is not a responsible way to manage water, land, and communities. The same is true for dismantling watershed‑based Conservation Authorities and assuming a new, larger structure will somehow produce better outcomes. Thoughtful, locally informed refinement of the existing system would serve Ontarians far better than a disruptive, top‑down consolidation that risks weakening the very protections people and ecosystems now rely on.