For nearly 80 years,…

ERO number

025-1257

Comment ID

177759

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Individual

Comment status

Comment approved More about comment statuses

Comment

For nearly 80 years, Conservation Authorities have delivered watershed-based services in partnership with Ontario municipalities. The watershed model was the correct approach in 1946 and still is today. Protecting people and property from natural hazards depends on specialized knowledge, governance, and management practices that are specific to individual watersheds.

This proposal would replace that model with seven large administrative regions. Amalgamation at this scale risks weakening local governance, diluting watershed-specific expertise, and reducing the operational efficiency that Conservation Authorities currently provide to their municipal partners.

The proposal also recommends establishing a new provincial entity, the Ontario Provincial Conservation Agency (OPCA), without any corresponding provincial funding commitment. While the stated intent is to provide centralized leadership and oversight, the practical effect would be to shift oversight away from municipalities while requiring municipal taxpayers to fund a new provincial structure. Conservation Authorities are currently funded by and accountable to municipalities, a governance arrangement that ensures services remain responsive to local needs.

From an administrative perspective, the proposal presents a significant risk of service disruption. No transition plan is provided, and the process of amalgamating multiple Conservation Authorities into single regional entities would introduce substantial administrative complexity. Staff time and resources would necessarily be redirected away from service delivery toward managing amalgamation, increasing costs while reducing capacity during the transition period.

This proposal refers to the current watershed-based approach as “fragmented” and claims that this has led to inefficiency in delivery of service. This isn’t the case for many Conservation Authorities, which regularly issue permits well within provincially mandated timelines. On the contrary, moving to a large regional model risks increasing administrative complexity, slowing decision-making, and reducing responsiveness to local needs.

It is acknowledged that some Conservation Authorities face operational challenges. These challenges are closely tied to the current funding model, which relies on municipal tax bases and can disadvantage smaller or more rural authorities. In 2019, the provincial government, which is still the current administration, implemented cuts to conservation authority funding that disproportionately affected these smaller Conservation Authorities. Where inefficiencies exist, they are more accurately understood as the outcome of funding constraints rather than shortcomings in governance or staff performance.

The proposal also contains factual inaccuracies. While some errors were corrected in the December 9, 2025 update, others remain. These include mismatches between written descriptions and mapped boundaries, references to river systems unrelated to the proposed regions (e.g., the Niagara River in areas draining the eastern end of Lake Ontario), and maps showing outdated Conservation Authority jurisdiction boundaries.

These are not minor oversights. They point to a lack of thorough review and meaningful consultation with municipalities and Conservation Authorities.

Modernization and improved efficiency are important goals, but they should be pursued through meaningful engagement with stakeholders who understand, benefit from, and fund Conservation Authorities. In its current form, the proposal lacks sufficient consultation and planning to achieve these objectives.