I do not support ERO-025…

I do not support ERO-025-1257 (proposed boundaries for the regional consolidation of Ontario’s conservation authorities) to consolidate Ontario’s 36 Conservation Authorities into 7 regional conservation authorities.

This regulation is proposing to create a new provincial government body, the Ontario Provincial Conservation Agency. You are creating a new government body in order to streamline the number of governing bodies?? Further, an overarching management body already exists – Conservation Ontario. If the true intention of this bill was to create more oversight and consistency across conservation authorities, why not just fund Conservation Ontario to have enough staff and a mandate to provide “centralized leadership, efficient governance, strategic direction, and oversight”? That is a far less expensive option than creating an entirely new provincial government body, and then undertaking what will be an expensive transition; with transition costs including human-resources integration, governance restructuring, IT migration and policy harmonization, all of which divert resources from front-line service delivery. Further, there is value in the 36 conservation authorities (and Conservation Ontario) being separate/independent from the provincial government so that they can continue their mandate of protecting and managing Ontario’s water resources through watershed-level planning, regardless of what the provincial government of the day wants to do with their own ministries. There is value in some level of redundancy between federal, provincial, and municipal levels of government so that if policy changes create gaps in service, they can be filled elsewhere.

Can you please cite the sources of information with statistics that show that conservation authorities are currently “creating uncertainty and delays for builders, landowners and farmers seeking permits” that is causing significant setback? I’m also skeptical that this merge would actually “reduce duplicative administrative costs” as there will still be situations where development straddles the border between two regional conservation authorities. This is true of municipalities, too, many of which have different policies of their own (look at street light specifications across GTA cities). This is an inevitability of having any subdivisional boundary. Also, how could this change result in “deliver[ing] faster services to municipalities and permit applicants”? Staff will be less familiar with any given locality where work is proposed, meaning they will have to spend more time understanding the development situation and how it relates to their regulations, and when site attendance is required, it will result in delays and added cost to travel across these new massive regional authorities.

The scale of these new seven regional authorities is ridiculous. They are way too large to be able to do anything meaningful, and some of them join together northern, rural, and/or fast-growing municipalities, all with different challenges. One of the many values of the current 36 conservation authorities is that they allow for incredible local knowledge of the watersheds, including temporal and spatial flood patterns, and the flora and fauna that reside there. That level of expertise is impossible to get at a larger scale of governance and will be one of the many reasons these new conglomerates fail. There will be an absence of local knowledge in decision making, meaning decisions may not reflect the ecological or social realities of the area. The ERO states: “[they] would continue to focus on managing natural hazards and watershed health, drawing on decades of local knowledge and partnerships”. It will only take a few years for those decades of local knowledge to disappear entirely because staff will not have the ability to be as familiar with their watershed. Further, operationally and logistically these areas are way too large. Surely a centralized office will be implemented in each region instead of localized offices, which means that travel throughout the new boundary to conduct work on the ground (i.e., surface and ground water quality monitoring, fish/mussel/invertebrate monitoring, outreach on best management practices to promote watershed health) will become prohibitive due to time constraints alone. Not only is the size of these new authorities out of line with the work they are meant to do, but the boundaries themselves are poorly thought out, especially the Huron-Superior regional authority boundary. Northern communities are already left out of so much provincial consideration (especially with this government), and to lump them in with western and central Ontario is going to be logistically challenging, and will fuel feelings of isolation and resentment towards the government for the focus on the Golden Horseshoe.

In southwestern Ontario, the Grand, Sydenham, and Thames rivers are the most biodiverse watersheds in Canada and face so many challenges related to intense agricultural land use. There will be a loss of local knowledge on populations by centralizing these areas, and it will become difficult to manage the land use and proportions of impervious surfaces relative to natural pervious surfaces, resulting in greater impacts of floods, which are already becoming more frequent and severe due to climate change, another issue being ignored by this government. Threats related to land use, and ultimately water quantity and quality are already negatively impacting species diversity, and this government has also taken steps to slash protections for species at risk.
In addition to the public benefiting from the local knowledge of staff, there is also benefit in actually knowing the staff personally. Relationship building is far easier at the community-level and this is evident in the work the current Conservation Authorities do. How could this proposed centralization possibly “strengthen local partnerships” when the public will be interacting with staff halfway across the province from them, represented by a board they didn’t get to choose? This might strengthen local partnerships with developers, but not with Ontarians.

This proposal is relying on the fact that most Ontarians don’t understand the logistics of doing the underlying work that allows Conservation Authorities to provide the services that they provide – the fact that the practical work related to flood forecasting, drinking water management, river health, outdoor recreational opportunities, etc., requires boots on the ground and in the stream every day. To do this effectively, staff need to live locally and know their watershed intimately at a scale that allows for it. There is no conceivable reality where this centralization will not result in worse service delivery in the short term, and ultimately more frequent and severe floods in the long term, with higher insurance premiums, and greater emergency response expenses. Doug Ford, please stop selling out short-term savings for long-term costs.