Comment
As a concerned citizen residing in Brantford, Ontario, I do not support consolidation as proposed. There is potential for consolidation to improve some of processes that Conservation Authorities (CAs) are responsible for, but not as it as been proposed. The boundaries suggested will introduce
significant governance, financial, operational, and service-delivery risks for CAs.
By joining CAs into regional groups, local municipal
representation will be diluted, particularly for smaller and rural communities. The ability for local priorities to be funded by particular municipalities will be reduced, especially considering that Bill 68 grants the OPCA broad directive-making authority across governance,
strategy, budget, and operations. Without safeguards, these directives could
supersede municipal oversight and centralize decision-making.
In terms of funding, merging municipally governed organizations into regional groups will incur substantial costs to ensure IT, data, and HR integration, rebranding, assest and liability assessments, etc. Expecting municipalities to fund these costs while simultaneously reducing their
influence is completely unreasonable.
MECP has indicated that land title would reside with the proposed
RCA and not the province. Municipalities rely on CAs to secure and manage
greenspace. Transferring ownership from current CA’s to the new RCA’s risks legal
complexity, reduced access, and long-term impacts on ecological integrity and
community use.
The proposed boundaries fragment several municipalities within CVC’s jurisdiction
and do not align with the CTC Source Protection Region. Boundary inconsistencies
will complicate planning, permitting, emergency management, and municipal
collaboration.
Consolidation risks weakening well-functioning systems through administrative
complexity and diluted oversight. Consolidation as proposed carries significant risks that
outweigh potential benefits without:
• Strong provincial funding
• Clear governance and municipal representation
• Preservation of local decision-making
• Protection of CA lands
• Alignment with other provincial reforms
• Respect for the performance and capacity of existing high-functioning CAs.
I encourage the province to fully assess governance, financial, operational, and
land-related implications and to evaluate whether modernization goals can be met
through the OPCA and enhanced coordination rather than regional consolidation.
Submitted December 21, 2025 3:19 PM
Comment on
Proposed boundaries for the regional consolidation of Ontario’s conservation authorities
ERO number
025-1257
Comment ID
177809
Commenting on behalf of
Comment status