In Environmental Registry …

In Environmental Registry (ERO) posting #025-1257 posting, the province is seeking feedback on five questions.

Bruce County’s responses to each of these questions are provided below, along with additional recommendations for consideration:

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

In pursuing a regional conservation authority approach, the following key factors could serve to support a successful transition and outcome for Conservation Authorities (CAs):

• Completion of a comprehensive systems-based assessment of the appropriate scale and cost-benefit analysis of local CA amalgamations, ensuring local service standards are maintained or improved.
• Consider increasing the number of Regional Conservation Authorities to reflect similar watershed and development characteristics (e.g. group rural and agricultural communities dominated by small to mid-size urban settlements).
• Consider creating a Northern Ontario Regional Conservation Authority rather than grouping the Lakehead Region watersheds with the Huron CAs.
• Ensure all CAs have equal access to investment in technology, data and mapping to ensure consistency in service delivery.
• Establish governance structures that guarantee equitable representation for rural municipalities and ensure a strong voice for agriculture.
• Consider the retention of local emergency management capacity to ensure timely and effective response.
• Ensure transitional costs are provincially funded, not borne by municipalities, and provide municipalities with clear funding models and budget impacts by mid-2026 prior to a 2027 implementation.
• Provincially fund the Provincial Conservation Agency.
• Consider a framework that preserves local agreements, charitable partnerships, and volunteer contributions.
• Ensure CAs can maintain and grow partnerships with municipalities on climate adaptation projects and source water protection.
• Take proactive steps to retain local expertise to inform permitting and planning functions through amalgamation.
• Maintain a local presence across the Regional Conservation Authority jurisdiction.
• Develop and execute a timely and comprehensive communication plan to proactively share information about the proposed changes to ensure complete information is available to municipal leaders, staff, communities, and stakeholders.
The province may wish to consider a phased or transitionary approach to amalgamations where cost-benefit analysis indicates value for amalgamations. There may be an opportunity for CAs to independently explore amalgamations to achieve service enhancements and address challenges and opportunities through greater regionalization.

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

Smaller and rural CAs are generally less funded – and may have difficulty maintaining up-to-date mapping, specialized staff positions (e.g. hydrogeologist or water resource engineer), and sufficient staffing levels to support service delivery standards that align with provincial and municipal priorities. Freezing permit review fees at CAs has setback many CAs from being able to modernize their processes and have fallen out of sync with many of the municipalities they serve. In a regional model, if appropriately funded, with an infusion of provincial investment, there could be some level of equalization which allows for the more rural areas covered by smaller CAs to have better access to resources and staffing levels beyond what they currently have. Whereas currently some CAs may not be able to employ a hydrogeologist or undertake two-zone flood plain studies, under the new Regional Conservation Authority model, the business case may support extension of such experts to more areas.

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?

The Huron-Superior Regional CA includes 80 lower-tier or single-tier municipalities in each. While Board sizes will not be able to accommodate representation from each municipality, there needs to be a transparent and equitable approach to governance to ensure fair representation for the unique needs of smaller rural and agricultural communities.

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

With Huron-Superior CA containing 80+ lower-tier or single-tier municipalities, it will be difficult to coordinate a Regional Conservation Authority budget process. Municipalities need input into the process, but there needs to be a budget process that aligns with the timing of when local budgets are being developed, such that budgets can still get passed in a timely way. Specific consultation between municipal and provincial finance staff in the development of the process could serve to reduce unintended consequences and reduce the potential administrative burden.

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

Significant commitment and investment of resources will be required by Regional Conservation Authorities to maintain municipal engagement, ensure local compliance, support emergency readiness, and ensure that there is equitable distribution of resources.

Regional structures must support, not replace, the partnerships that keep rural conservation programs going; agricultural groups, donors, volunteers, and local employers are less inclined to engage with a distant regional office. Relationships are likely to be strengthened with a Regional Conservation Authority organization that ensures maintaining and programing conservation authority lands is responsive to and allows for continued public access for recreational use.

Additional Recommendations for Provincial Consideration

Bruce County understands and supports the province in its efforts to modernize, identify efficiencies and support consistent, effective, high quality service delivery that meets the needs of communities and delivers on provincial priorities.

These outcomes may also be achieved through regulatory, funding and policy changes.
Some measures that may be of value to explore include:
• Technical Guidance – providing updated province-wide technical guidance to CAs to support modern, consistent decision making and service delivery.
• Consistent Policy Framework at a regional level – build on the singular regulation already implemented to support consistent policies, perhaps on eco-district levels.
• Establish service standards to support provincial priorities.
• Online Permitting and Data Tracking System – support implementation of a province-wide system for planning and permitting using digital platforms, that can dovetail with municipal online permitting systems. Continue to support residents who do not have access to digital/on-line platforms (e.g. Mennonite and Amish communities).
• Establish a regional or province-wide fee structure with updated fees to reflect the cost of delivering services. Fee for service – or alternate funding from the province could fund cost recovery for planning and permitting services delivered by a CA.
• Consideration of smaller regional CAs (for example, along the Lake Huron Shoreline) that could support amalgamation where similar local conditions and characteristics exist, and where they serve adjacent watersheds should there be a cost and efficiency benefit.