Comment
I am writing to express serious concern about the proposed regional consolidation of Ontario’s conservation authorities, particularly the manner in which this proposal has been developed and communicated, and the significant implications it has for conservation authority staff across the province.
Conservation authorities are built on the expertise, dedication, and institutional knowledge of their staff. Many employees have devoted decades of service to protecting communities from flooding, managing watershed health, delivering Species at Risk recovery, and supporting municipalities, landowners, and Indigenous partners. Advancing a major structural reorganization without early, meaningful consultation with these professionals demonstrates a profound lack of respect for their experience and their role in delivering provincially mandated services.
This proposal appears to have been developed and announced through a top-down process, with staff learning of potential consolidation only after boundaries and governance directions were largely defined. Such an approach creates uncertainty, erodes morale, and undermines trust in public institutions. Staff are left to question the security of their positions, reporting relationships, workplace location, seniority, and future working conditions, all while being expected to continue delivering critical public safety and environmental services.
In addition to the human impacts, the proposal raises serious and unresolved labour relations questions. Some conservation authorities are unionized, while others are not. Consolidating multiple authorities into regional entities introduces significant legal and operational complexity related to collective agreements, bargaining units, job classifications, pay equity, benefits, seniority, and grievance processes. The proposal does not explain how these issues would be addressed, nor whether consolidation could trigger labour disputes, legal challenges, or unintended pressure on non-unionized authorities to unionize in order to protect staff rights and working conditions.
Without clear answers, there is a risk that consolidation could destabilize the workforce at a time when conservation authorities are already facing increasing demands from climate change, development pressure, and emergency response. Loss of experienced staff through retirement, resignation, or prolonged uncertainty would directly affect flood forecasting, permitting timelines, data continuity, and public safety.
It is also unclear whether the province has assessed the legal and financial risks associated with merging unionized and non-unionized organizations, including potential liabilities, transition costs, and long-term impacts on operating budgets. These risks, if not adequately planned for and funded, will ultimately be borne by municipalities and local ratepayers.
Respect for public servants requires more than assurances after decisions are made. It requires early engagement, transparency, and genuine collaboration. Staff are not administrative overhead; they are the core capacity that allows conservation authorities to function. Any reform that disregards their knowledge, contributions, and working conditions risks weakening the very system the province claims it is trying to improve.
I urge the province to pause this proposal and undertake meaningful consultation with conservation authority staff and their representatives before advancing structural or legislative changes. Clear information is needed on labour relations impacts, legal implications, staff protections, and transition supports. Without this, the proposed consolidation risks causing lasting damage to workforce stability, service delivery, and public trust.
Thank you for the opportunity to comment.
Submitted December 19, 2025 12:11 PM
Comment on
Proposed boundaries for the regional consolidation of Ontario’s conservation authorities
ERO number
025-1257
Comment ID
177028
Commenting on behalf of
Comment status