Comment Re: Proposed…

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

I am very concerned by the Ontario government’s plan to amalgamate the 36 Conservation Authorities (CAs) into 7 Conservation Authority Regions. No science-based evidence has been provided to support this policy. It creates risks for water quality, soil degradation, climate threat and ultimately higher costs for residents of Ontario.

I do understand the frustrations with inconsistencies in the permitting process. These can be effectively addressed through amendments to Policies, procedures and regulations already available under the CAA and by providing the digital tools and resources that are part of the proposal. Amendments that would simplify the process for municipalities to manage functions related to multiple Conservation Authorities (i.e. multiple watersheds within the municipal boundaries) are welcome.

However, there is no evidence to demonstrate that consolidation of existing CAs is necessary or would contribute to this effort. In fact, increasing the number of municipalities in the decision-making process of diverse watersheds (especially where there is no physical link between a watershed decision and some of the municipalities) would likely confound efforts towards more effective and streamlined management. For example, urbanized watersheds with a high proportion of impermeable surfaces face very different challenges than those with predominantly agricultural drainage inputs or shoreline erosion. Decisions are likely to favour larger population centres over smaller rural ones, regardless of the local impact.

There may be benefits to aligning some CA boundaries with the current Source Water Protection Region/Area boundaries, in particular where smaller CAs don’t have the resources they need to be effective and would benefit from joining with a larger neighbour. Disrupting the current Source Water Protection Regions, as the proposed amalgamation would do, requires supporting science-based evidence that protection of drinking water would be better served by the change. Any consolidation has to be supported by analysis of resulting risks, costs and benefits to managing the flow of water (surface and groundwater) and impacts on soil. I am very concerned about the fiscal impacts of amalgamation on the ability of CAs to deliver services, as well as the financial implications to all Ontarians of poor risk management.

In the 1930's and 1940’s Ontario experienced significant flooding, erosion and soil loss as a result of unsustainable land development (loss of forests and wetlands) leading to the establishment of Conservation Authorities to manage land clearing and water management activities. (supporting links below) Following the devastation of Hurricane Hazel the authority to designate land as unsuitable for development was strengthened. We must remember what CAs do for us and avoid creating another Walkerton-level crisis in efforts to remove guardrails on development. All major projects proposed to boost the economy make sense only if they are done well, based on good science and engineering to protect future generations. Increased risk due to climate change will cost us all through insurance and the cost of producing food, even if we are not directly affected by flood and fire.

Finally, as a citizen of my community, I must emphasize that CAs provide more than science-based permitting. They have a very close connection to the community through educational outreach, citizen science initiatives, Indigenous reconciliation and youth-based activities. As a member of my local Lions Club I have participated in tree-planting initiatives coordinated by the local CA to stabilize stream banks. Our local Scout group is located on CA property and a major Scout Camp has partnered with the CA through educational outreach opportunities such as participating in invasive species removal, streamline protection and water quality protection. The Indigenous reconciliation event that I help organize (10th year this year) has been supported by the CA that hosts us at two campgrounds on the Grand River each year. Further removing the management of CAs from their local community and volunteers will weaken those links. I cannot support that.

I have not responded specifically to the proposed questions, as they are better oriented towards regulations that implement the proposed consolidation which I do not agree with and which does not yet have the agreement of the Legislature.

Conservation Authorities were a unique Ontario response to environmental threats in the 1930s-1950’s that have not gone away. The CAs have transformed our landscape over the past 70 years and help us prepare future generations to continue to protect it. We can support the building of new homes without jeopardizing those gains.