I am against the Ontario…

I am against the Ontario government consolidating 36 Conservation Authorities (CA) into 7.
In doing this, the government further undermines the Conservation Authorities’ power for permitting, and allows for more unsafe development in flood zones and ecologically important wetlands. The province's proposed consolidated approach to watershed management is not rooted in science, evidence, best practices globally, and adaptive management principles. This is a land grab.

Historically, the Ontario Conservation Authorities (CAs) began to be established by municipalities and the province in the 1940s in response to severe flooding and erosion problems in Ontario. Each CA is legislated under the Conservation Authorities Act, 1946. Each Conservation Authority has its own Board of Directors comprised of members appointed by local municipalities and most are elected municipal officials. Because of the devastating effects of Hurricane Hazel in 1954, the Ontario government amended the Conservation Authorities Act so that Ontario’s watersheds would be managed on a regional basis and to enable CAs to acquire lands for recreation and conservation purposes, and to regulate that land for the safety of the community. There are currently 36 CAs in Ontario. Following is the typical breakdown for funding of CAs:
Municipal levies – 53%
Self-generated revenue – 35%
Provincial grants & Special Projects – 8%
Federal Grants or Contracts – 4%
For over 80 years, Conservation Authorities have operated on a local watershed-based model because water and ecosystems do not follow municipal boundaries. This approach ensures that flooding, erosion, and water quality are managed where they occur — locally.

The current CA structure exists because of historical disasters and need. Why is the Ontario government ignoring previous historic need that created the current Conservation Authority structure? Considering the level of funding provided by the municipaliites, why have they not been included in such a drastic change? It is each municipality that will be impacted should this new CA structure fail to deliver what it is promising.

The Environmental Registry of Ontario # 025-1257 is proposing changes to the Conservation Authorities Act to create a new Ontario Provincial Conservation Agency (OPCA) that will be a provincial board-governed agency. It also will amalgamate the current 36 CAs into 7 CAs. Centralizing governance could erode local accountability, reduce rural representation, and even result in local funds leaving the area. This shift would fundamentally change the relationship between municipalities and their Conservation Authority, weakening the ability to make decisions that reflect local priorities. The point of the current CA structure is to have local expertise on flood prevention and protection of water resources. This new CA structure puts the experts very far away from their local communities.
The usefulness of the CA model is that they have people on staff who are knowledgeable about their own communities and the specific needs of their own watersheds. These are organizations that have built almost a hundred years of institutional knowledge, and none of that will be carried forward. This sort of amalgamation will devastate the ability of CAs to manage flood risk, let alone environmental risk in their specific areas.

The new OPCA will introduce significant cost and complexity. No cost-benefit analysis, feasibility assessment, or proposed governance structure has been provided, leaving municipalities and residents without clarity on how these changes would improve outcomes.

The ERO states that these changes will “Better align conservation authorities’ services with provincial priorities on housing, the economy, infrastructure and climate resilience.” In my opinion, this is the key to why the CA changes are being proposed. It’s to centralize CA oversight into the hands of the province to more easily bypass municipal and environmental considerations so that developers/builders can build wherever/whatever they want. It’s to reduce the number of people who will be informed on what is really happening. This will reduce transparency. This is not based on sound science. It’s a land grab.

In 2024, Ontario Regulation 686/21 came into effect and Section 10 of the regulation required all Conservation Authorities to prepare a plan for all lands owned or controlled by the Conservation Authorities. The government was given the list of all lands owned by all Conservation Authorities. Why would the province require a full list of these lands? Why does this ERO not make any mention of conserving existing CA lands as is? What will be the impact on CAs lands? Many CA properties were donated or sold by residents with the expectation of continual local stewardship. Transferring these lands to a distant regional body could undermine donor trust, municipal agreements, and the long-term care of these properties. These lands represent a legacy of community commitment, and losing local oversight would jeopardize that trust and stewardship.

It’s laughable that climate resilience is even mentioned in this proposal. Climate change is the last thing this province is concerned with. I can’t name one thing Ontario has done to fight climate change. In fact, the Ford government continuously undermines climate change policies. Proof of that is in the dismantling of climate change strategies, cancelling carbon pricing, the weakening of municipal green standards with Bill 17, undermining environmental protections and conservation authorities with Bill 29 and Bill 229, the Greenbelt scandal, taxpayer money funding lawsuits against the carbon tax, enabling the demise of beer bottle returns.

The reasoning for the proposed changes are misleading.
The ERO states “With better tools and more resources for front-line staff, the regional conservation authorities would operate with greater consistency and transparency, deliver faster services to municipalities and permit applicants, while ensuring decisions continue to be based on sound science.” CAs currently must follow the provincial standards, guidelines and timelines set out in the Ontario Conservation Authorities Act primarily defined by Ontario Regulation 686/21 (Mandatory Programs and Services) and the Class Environmental Assessments (Class EA). These standards set out by the Ontario government ensure consistent watershed protection and hazard management across Ontario. So consistency is already mandated by the province, meaning this mandate is already being fulfilled, so the new OPCA will not deliver anything new. Based on Conservation Ontario’s statistics for all the Conservation Authorities, 96% of all complete permits are completed in the provincially outlined timelines. So CAs already deliver services to municipalities and permit applicants in required provincial timelines. Yet another of the new OPCA goals that is already being met.

As for ‘greater’ transparency, currently:
- All permitting requirements are posted as separate required policies (as dictated by the Province) and Section 28 is posted on all CA websites.
- All Conservation Authorities are audited annually, have their audited financial statements posted, have budget meetings with the municipal Board members, have quarterly financial statements brought to Board meetings, and are clear about which special levy projects are going forward.
- Conservation Authority budgets are decided by and voted on by the Board of Directors which are elected municipal councilors and mayors.
- All Conservation Authorities also clearly post their fees for any service they provide.
- Conservation Authorities are also subject to Freedom of Information requests.
It is misleading that this proposal infers that the CAs don’t operate with transparency..

The ERO states “ With better tools and more resources for front-line staff…”. Better tools and resources can be provided to front-line staff now. A new OPCA and CA regional amalgamation is not required to do this. Why has this province not provided better tools and resources?

The ERO states “drawing on decades of local knowledge and partnerships…” How exactly will the decades of knowledge and partnerships be preserved? In my opinion there will be loss of local knowledge, municipal partnerships will be eroded, local voices will not be heard.

This ERO states that the new OPCA will provide ‘greater transparency’. What more does the Ontario government want from the CAs as regards greater transparency? Why has the Ontario government not requested this by means of a change to the Conservation Authorities Act?

This proposal creates a new OPCA, yet provides no details on how it will work:
- Where will the new OPCA be located? Decisions about lands and resources should stay close to the communities that use and care for them.
- How many employees will there be? What jobs/roles are required? What are the requirements for these roles? Who decides how these roles will be filled? Will priority be given to employees of the current CAs who have the expert knowledge of their areas? Will jobs be assigned to experts, or will they be appointed by the Ontario government?
- What is the anticipated yearly budget for the OPCA? Who is providing the funding? Are municipalities expected to provide funding? (Why should they when the new Agency is a provincial decision.) What will be the funding provided by the province?
- Who will be on the board that oversees this new OPCA? What is the breakdown of the members on the board? Is it going to be mostly provincially appointed members? Will there be municipal representation? Which municipalities get to be on the board? How will that be decided? Will it be partisan appointments? Do Ontarians have a say?
- How do municipalities provide their requirements/feedback? The proposed new Lake Erie Regional Conservation Authority comprises 81 municipalities. 81 municipalities will have varying levels of need and requirements and this new regional structure seems too unwieldy to work. This change will dilute local accountability and municipal partnership. Municipalities have governed their respective conservation authorities for decades, tailoring programs and services to local watershed needs, maintaining accountable service standards, and ensuring fair and predictable costs for ratepayers. Flooding is expensive, disruptive, and time-consuming, with costs borne by municipalities and local taxpayers through emergency response, infrastructure repair, and long-term recovery. Strong, locally informed watershed management is far more effective and less costly than reacting after damage occurs.
- How will these new Regional Conservation Authorities be structured? Do employees from the old CAs get absorbed into the Regional Authority? How is the OPCA going to retain the employees with the years of expertise? The loss of local expertise is by far the greatest risk.

On October 31, 2025, Environment Minister Todd McCarthy announced the changes being proposed in this ERO. He also indicated that there would be no job losses, though a redeployment would be required. I’ll take him at his word, but it brings up other questions. Is the new OPCA redeploying employees and paying them the same salary? Where are the existing subject matter experts within the CA going to work? Are they going to be forced to work in the new regional offices? If yes, what is the cost of expanding the new regional offices? Or are the existing CA employees going to continue working from their current offices so they can monitor locally to make informed decisions? Are they going to be able to work from home? Why have these details not been provided by the Ontario government ahead of this announcement as a means of retaining local CA experts? Or is this a backhanded way to reduce the existing work force through attrition and yet affirm that employees were not let go? CA employees live in various communities, and not all of them will be able to uproot their lives. If all the existing CAs currently have 200 Conservation Officers, then I am assuming at least that many will still be required. Where will their offices be?

Who is creating the single permit platform? Who is defining the requirements? When will that be done? What equipment is needed for this new platform? How much will this new platform cost? When will the new platform be designed? When will the new platform be completed? I’ve worked in IT, this is not something that can be designed, built, tested within a year. Who is paying for all this work? What will the transition look like so as to minimize disruption? In fact, how can there not be disruption?

This Ontario government has made no attempt to modify the existing Conservation Authority Act to address what it says are issues. The province wants faster delivery, then adjust the required timelines for permits. The province wants to provide better tools and more resources to enable front line workers to make them more efficient, then why has the province not already done so? Instead, the Ontario province chooses a nuclear option that reduces CAs from 36 to 7, and does so without a plan. This drastic change is risky. That the province has not considered a pilot to test the feasibility of these changes, to smooth out the hiccups, solve the pain points and uncover unanticipated problems does not instill confidence in this restructure. This change will generate substantial transition costs — including human-resources integration, governance restructuring, IT migration and policy harmonization — that would divert resources from front-line service delivery and delay measurable outcomes. Who is paying for all this?

I urge the province to reverse their decision.
Conservation Authorities play a critical role in protecting wetlands, floodplains, and open space, providing essential services such as erosion control, climate resilience, flood forecasting and warnings, flood mitigation, watershed monitoring, guiding development away from natural hazards, and safeguarding municipal drinking water sources. The CAs promote environmental stewardship through tree planting, sustainable forest management, and funding for agricultural landowners to support best management practices. Education is a priority, with initiatives that inspire residents of all ages to learn about and connect with the local environment and beyond. The current CAs manage thousands of acres of land, providing recreational opportunities while preserving these natural spaces for future generations. Decisions about land, water, and public safety must remain locally informed, transparent, and accountable to the taxpayers who fund them and live with their outcomes. How can the new Structure do this effectively?

The Ontario government must take their stewardship responsibilities seriously. They should be making changes that make sense for current Ontarians AND for future generations.