Re. ERO posting 025-1257:…

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

I am writing to express my opposition to the Province’s proposal to amalgamate conservation authorities (CAs). The proposal to amalgamate CAs is ill-conceived and would not support the Province’s goal of improving efficiency. CAs are entities administered by their local municipalities, and function on a watershed-based scale. Local knowledge and strong relationships with their local municipalities are critical to their mandate of watershed management and keeping communities safe from natural hazards.

There are actions that the Province could take to improve consistency across CAs. This does not require the creation of the Ontario Provincial Conservation Agency at the CA – and therefore municipal expense - as proposed. The Province could create technical resources to help implement the provincial legislation that is the Conservation Authorities Act (CA Act), to clearly communicate the intention of the legislation and provide CAs with the tools they require to be efficient and consistent.

The ERO points out that each conservation authority following different policies, standards, fees and levels of staffing and technical capabilities. One key reason for this is that CAs have not been provided sufficient direction from the Province on the implementation of the CA Act.

Specifically, the Province could:
1. Provide clear direction and clarification on the intent of the regulatory and statutory changes that were implemented in 2024. For example, on expectations regarding permitting development within wetlands. Clarification of several points is required, as well as administrative updates to the legislation to correct clerical errors.
2. Develop Technical Guidelines, particularly regarding development within wetlands, to facilitate development of policies, understanding and articulation of submission requirements.
3. Update Technical Guidelines (the “technical guides”) where these already exist.
4. Provide direction on the Province’s risk tolerance where development is proposed within a natural hazard. Define the term “least and acceptable risk” that is used in existing guidance documents.
5. Above the Technical Guidelines, develop additional technical resources regarding requirements for technical studies that are conducted by proponents in support of individual projects.
6. Consult with conservation authorities to understand the technical gaps which should be addressed.
7. Update Technical Guidelines and development of technical resources in consultation with CAs, and build on the resources that have already been developed by individual CAs.
8. Support implementation of a standardized permit platform. This could improve consistency among CA permit processes, and has the potential of reducing administrative burden on permitting staff and thereby improving permit review times. To facilitate development of this platform and ensure that it is useful to CAs the Province should not create a new platform, but rather review and chose from the platforms that are already in place among some CAs.

I trust that the Province will re-think consolidation of CAs, and rather invest that time and resources into providing CAs with the tools they require to continue to protect people and property from natural hazards, in a more efficient and consistent manner.