ERO Submission: Response to…

ERO Submission: Response to Posting #025-1257
Proposed Boundaries for the Regional Consolidation of Ontario’s Conservation Authorities

As a concerned citizen, I do appreciate the Government's request for opinions on a structural change for Conservation Authorities. Any time a legislative change which will affect ( by your own numbers) 14 Million Ontarians and 250 Municipalities, the Government should reach out for comments. However, while the Government has set out an ERO posting, the short window to comment is an insult to the general public. This process gives the appearance that the Government has already made up its mind on the final outcome. IE The Government announcing there will be 7 Regions.

While there are issues of a lack of modernization, consistency, and capacity within some CA’s. That is not the case with each and every CA. Some of these challenges could be resolved with changes made to the Conservation Authorities Act, R.S.O. 1990, c. C.27 and changes to financial support from the Province.

There are also jurisdictional issues which are faced by some Municipalities. In these cases, where a Municipality falls under several CA jurisdictions, a business case study should be undertaken of the aligning CA’s to ensure the outcome of amalgamation will result in the goals of the Government for improved modernization, increased capacity and reduction of overall cost to the Member Municipalities.

In areas where no multiple CA boundaries adjoin a Municipality, amalgamation of those Authorities into other CAs serves no purpose, except to limit budget input by the funding Municipalities. Or to be blunt, Taxation without Representation. I am sure this was not the intent of MECP when the decision to move forward on modernization was made, yet this appears to be the outcome if the Government moves ahead with the forced amalgamations without fact based evidence behind those amalgamations.

The Government has stated one of the goals is to insure a consistent permit fee and application process for the issuance of permitting across as regions. Which if successfully implemented would be a worthy outcome. This brings up a question though; Will the Government then move on to Municipalities, align the process and fees for Building Permits, Severances, Minor Variances, Plan of Subdivisions etc?

When one does look deeper, the idea of streamlining and aligning permit fees looks and sounds good. Yet there are reasons for the differences, one only needs to look at Ontario's 444 municipalities and how each of the previously mentioned Municipal permits, application process and fees are not the same.

RE: ERO Submission: Response to Posting #025-1257

Proposed Boundaries for the Regional Consolidation of Ontario’s Conservation Authorities

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

Government funding is provided to cover all costs associated with consolidation. Including rebranding, as well as all Legal and HR costs arising from amalgamation. Any other costs which may be incurred in the future as a result of unknowns in the amalgamation process. This should not be a “build it, as it goes”process.

Adequate time is allocated to deal with all legal, banking, human resources, etc. requirements.

Preservation of local decision-making is incorporated into the amalgamations.

All existing Conservation Authority owned lands remain owned by the municipalities that acquired them, not becoming a part of a larger Region. This needs to be written into the new Act.

Existing reserve and deferred funds are allocated to the existing uses of the Conservation Authority that generated the funds, not merged into one collective regional fund. This too needs to be legislated. Simply claiming that the new Regional board can pass a By-law to ensure the Reserve and Allocated funds remains the same, admits that not passing a By-Law means the funds can be allocated wherever the new Board decides.

Satellite offices are maintained for each existing Conservation Authority.

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

Opportunities and benefits from a regional conservation authority framework include:
Potential for sharing expertise within and between regions.

A municipality will only have to deal with one Conservation Authority (in most cases).
One fee schedule and permit process applicable to each region.

Standardized policies.

Sharing of resources.

Bulk purchasing.

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?

Preference should be that each member municipality have at least one member on each regional Board; however, in regions with 80 municipalities this will not be possible.

If each member municipality will not have a member on the Board, then municipalities within a region should be grouped and have a rotation, where every municipal term each municipality has a year (or other time period) on the Board, and then they rotate out to the next municipality in their grouping. This model is undertaken in other Governance Boards such Health Units, Social Service (DSSAB and CMSMs).
Alternatively, each region has a Board and advisory committees, where every municipality has a seat on either the Board or a committee. For Budget approval it is suggested each member municipality is allowed voting (by proxy if needed) following the current Levy weight procedure.

Board appointments should remain with the member municipality.

Municipalities should continue to have the ability to appoint citizens, if so desired.

Regions with many member municipalities will result in a loss of “pay for say”. “taxation without representation” which will in turn result in a disconnect between Conservation Authorities municipalities and citizens.

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

Budgeting should be developed annually at each individual satellite office (i.e., existing Conservation Authority) as part of an overall regional budget, allowing for local prioritization of issues and allocation of resources within each locality.

Overall administrative costs will require apportionment that is fairly applied to each satellite office.

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

Satellite offices (i.e., each current Conservation Authority) will need the ability to connect via social media, newsletters, annual reports on programs and work in their local area. Regional only messaging will not resonate at the local level for large regions.

Maintaining local leadership at each satellite office that remains engaged and accessible to the local municipalities, community and stakeholders will be key in maintaining support and trust from the local community.

The ability for each satellite office to continue to provide programming at the local level in each watershed within a region will maintain connections.

Further to the above, the Government's process of amalgamation has to be defendable to the general public and supporters of CA’s. Stewardship fundraising as well as land donations will be negatively affected if the process does not appear to be made using evidentiary based reasons. The loss of this funding and public buy-in will be the direct result of a flawed MECP amalgamation process.