ERO 025-1257: Comments on…

Thank you for the opportunity to provide input on the proposed boundaries for the regional consolidation of conservation authorities (CAs).

CAs were created sixty plus years ago in response to significant watershed degradation and the devastating consequences of poorly planned development and land management, most visibly demonstrated by catastrophic floods. At the time, local watersheds were deliberately chosen as the appropriate scale for decision making, recognizing the interrelationships of hydrology and hydrogeology, flood and erosion risk, and ecosystem functions that do not align with municipal boundaries. Equally important was the establishment of a local governance structure that ensured decisions were reflective of local conditions, risks, and community priorities and needs.

Ontario’s CAs have a six decade plus track record of excellence in watershed-based work at the local level to safeguard public health and safety from natural hazards such as flooding and erosion, protect the environment, conserve natural resources, and provide recreation opportunities. The Province’s proposal to consolidate CAs is framed around the need to address inefficiencies, inconsistencies, and administrative duplication. However, no evidence has been presented that supports the need to achieve the Province’s stated objectives through large scale organizational restructuring; in fact, these could very likely be achieved within the existing CA framework through strengthened provincial standards and policy amendments.

The proposal to consolidate CAs into very large organizations will have the dramatic effect of removing local decision making that is responsive to local flood hazards, erosion risks, and community priorities with a more distant governance structure that no longer can address local needs. The proposed regional CAs will dilute municipal influence and local accountability. Local watershed-based governance works precisely because it is local, place-based and accountable to the community. This is a core strength, not an inefficiency.

Structural consolidation also introduces significant operational risk of disruption to existing CA programs and services, and transition costs that have neither been acknowledged nor assessed. From information technology systems, human resources and labour agreements, changing governance processes and financial reconciliation, to resolutions of contractual obligations across multiple organizations, large scale amalgamation results in real and significant costs, not to mention rebranding and changes to physical assets such as signage and public facing materials. It is unclear what those costs may be and who would be paying them. Wouldn’t it be better to invest these resources into improvements within the current governance structure that will actually advance the Province’s objectives?

Further, the proposed consolidation would create significant financial accountability challenges. With some proposed regional CAs encompassing up to 80 or more municipalities, each individual municipality’s financial contribution would now need to serve broader regional interests rather than being invested in local priorities. This dilution will lead to residents having less accountability and less connection to their CA. This is further exacerbated by the centralization of powers at the new Ontario Provincial Conservation Agency. Of additional concern is the proposal that municipal ratepayers will be financing an Ontario Crown Agency over which they have no governance or accountability mechanism.

The current proposal may also result in significant impacts on the provincial drinking water source protection program. Currently, the source protection program is closely tied to the governance of CAs, e.g., CAs act as source protection authorities under the Clean Water Act. The source protection program has been designed to be watershed-based, locally driven, and the success of the program to a large degree is a result of recognizing the close connection between land uses and activities in local watersheds, the local impacts on sources of drinking water, and the local policy solutions of the source protection planning process. Local accountability is imperative to ensure local input and adoption of measures for clean, safe, drinking water sources and to safeguard public health.

If regionalization is pursued, Source Protection Regions established under the Clean Water Act may provide a more logical structure than the seven proposed regional CAs. Source Protection Regions align with natural hydrologic systems and reflect long-standing municipal and CA relationships, as well as existing water management and protection functions already core to CAs.

For the reasons above, I urge the Province to not pursue the consolidation of CAs as proposed. Ontario already has the institutional capacity and legislative tools to strengthen standards, invest in shared tools, and support under-resourced CAs. Achieving the Province’s objectives does not need to dismantle the current watershed-based governance. I recommend the Province work with municipalities, conservation authorities, and local watershed communities to develop meaningful and more targeted solutions to enhance effective watershed management that maintain local independence and accountability that is crucial to protecting people, property, and ecosystems across Ontario.