Thank you for the…

Thank you for the opportunity to comment on this proposal on behalf of the Anglican Diocese of Toronto. As Anglicans, our baptismal covenant calls us to strive to safeguard the integrity of creation, as a commitment to our mutual home and our place within our ecosystems. Our care for our neighbour extends not only to our current human neighbour, but to our ecological neighbourhood as represented by our watershed, as well as a promise to future generations. We see this as a part of our faith commitment to the common good of all Ontarians and to all our neighbours.

Likewise, recognizing our colonial history, and our work as a Church towards reconciliation, we understand that true reconciliation calls us to protect the integrity of the land and waters throughout our Diocese and the Province as a whole. The Dish with One Spoon Treaty reminds us of our duties to share and care for the land, waters, and our neighbours, so that we might preserve the resources around the Great Lakes for future generations.

The provincial government is planning to consolidate the province’s 36 conservation authorities into seven regional conservation authorities. The government’s stated goals include streamlining administrative costs and aligning conservation authorities’ services with provincial priorities on housing, the economy, infrastructure and climate resilience.”

The existing conservation authorities follow local watershed boundaries and play a vital role in protecting communities from natural hazards like floods. Each watershed has its own specific features and challenges. With climate change already leading to more frequent and severe weather events across Ontario, local knowledge and timely response are all the more crucial to protect Ontario communities and their surrounding watersheds.

The current legislation represents a significant shift that reduces the local capacity to understand and meet the particular needs of the watersheds and the communities that surround them.

While we share the goal of increased coordination and making public dollars go farther, we are concerned that this proposal may reduce environmental protections in the province to the lowest common denominator. Already this government has sought to open up protected lands to development, despite the dangers of building on floodplains.

Further, we reject the assumption that reducing or streamlining conservation authority protections is required to achieve Ontario’s housing targets. A report released in early 2023 found that there is more than enough land already designated within urban boundaries in the Greater Golden Horseshoe to meet housing needs for decades . While recognizing the need for adequate housing, we call on this government to make use of the lands that are currently available, and care for the natural resources, watersheds, and ecoregions of our province. These are not mutually exclusive aims and can be done in a way that ensures care for both.

The proposal for consolidation of Ontario’s existing conservation authorities risks disrupting the robust protections of watersheds and downstream communities, reducing local knowledge and representation, and requiring a complex transition process that could cost as much as it saves, without clear evidence of benefit. We urge the government to consider enhancing opportunities for coordination between conservation authorities, rather than amalgamation.

Thank you for the opportunity to comment on this proposal.