I am opposed to the scope…

I am opposed to the scope and scale of the proposed boundary changes via amalgamations being proposed for Conservation Authorities across Ontario. As a professional, environmental, land use planner, I have over 40 years worked experience employed by governments at all levels (provincial, county, city, municipal) as well as in private consulting and for conservation authorities. I know the value of watersheds and watershed planning which have been the main focus of my work. Integrated watershed planning is required to safely locate residential development and protect natural heritage systems. CA's are instrumental in this work and their local connections to the communities and to the land, is essential. This proposal risks that situation and may put people and property in increased danger due to more frequent and severe extreme weather impacts.

Conservation Authorities (CAs) are a valued local presence that provide key stewardship, ecosystem protection, parks & trails and environmental educational activities, in addition to flood management and regulatory functions, so essential to keeping people and property safe. This work is even more relevant now due to the existing and future climate adaptation needs of our communities.

A regional CA model will diminish the CA partnerships and local presence on the ground.
If, as the province asserts, this is about consistency and improved customer service across boundaries, there are many other options available that would be faster to implement and likely more cost effective, while supporting local needs. This level of disruption and distraction suggests that the province is seeking an excuse to dismantle a system that has been in place for almost 80 years rather than work with the parties affected to support their stated objective of faster housing development. The creation of CA's originally used a 50% / 50% funding model with the province providing half the funds. That provincial contribution has shrunk to less than 5% in most watersheds and is a testament to how the CA's have effectively pivoted and continue to do the incredible work managing watersheds.

The proposed amalgamation is poorly researched and flawed as evidenced by the original inclusion of areas not even currently contained within CA boundaries (e.g., Tiny, Tay and Severn municipalities). Even using the broader watersheds of the Great Lakes which could have formed the basis of the grouping, is inconsistent with Thunder Bay and Lake Superior being grouped with Bayfield on Lake Huron and adjacent Lake Huron watersheds. Shoreline management using Great Lakes littoral cells would be an approach to proposed amalgamations that could be partly justified. But in the absence of any explanation for the groupings proposed, I am left to speculate on the basis for amalgamation.

I do not think that there can be a successful amalgamation of this many conservation authorities. Some thoughtful and consultative options may benefit smaller or under resourced CAs (e.g., Kettle Ck., Catfish Ck.) but should be done WITH those CAs and their municipalities. I suggest that the province should:
• Pause all changes to the CA's boundaries and changes to their operations
• Carry out intensive consultations with all parties before introducing a one-size-fits-all approach to this proposal
• Maintain the local presence of management decisions
• Maintain municipal appointments to the boards based on population and consider re-establishing local provincial appointees to the boards as was done prior to 1996 if more provincial control is desired.
• Ensure adaquate municipal funds are allocated to their local watersheds and to Conservation Ontario
• Increase provincial funding to CAs to ensure that they can carry out the work the province requires of them especially in the face of climate change.

The province does not need to create another level of bureaucracy; instead utilize the existing umbrella organization called Conservation Ontario and provide proper funding to empower them. Do not encumber municipalities with more tasks and downloaded requirements without proper funding.

Thank you for the opportunity to provide comments on this ill conceived proposal.