My key concerns regarding…

My key concerns regarding the proposed amalgamation are listed below:

Conservation authorities were not consulted about the amalgamation before it was announced, and were not consulted on proposed boundaries. Lumping small CAs in with very large/more populated areas will work against the idea of regional/local community work/projects/relationships with the organizations, businesses, municipal and community partners. Knowing the watershed is a VERY important aspect of commenting on planning applications, doing floodplain mapping, building management plans, and other CA projects and programs.

Lack of demonstrated need for restructuring: Conservation authorities have not been provided with any assessments or analyses demonstrating that Ontario’s current watershed-based conservation authority model requires structural change to improve efficiency or service delivery.

Most conservation authorities currently meets provincial permitting timelines and continues to coordinate effectively with municipal partners and developers. Evidence-based guidance and clear modernization goals would be more beneficial than restructuring the system.

As an example, the scale and complexity of the proposed Western Lake Ontario RCA: The proposed RCA would span approximately 490,000 hectares across nearly two million residents and 28 municipalities. Reducing local representation from a combined 53 current board members to a smaller consolidated board risks losing diverse voices and weakening connections with local communities, partners, and long-standing watershed relationships built over 66 years. The complexity and costs of merging four independent conservation authorities: Each conservation authority within the proposed RCA is its own corporate entity with its own budgets, assets, landholdings, infrastructure, reserves, and charitable foundation. Consolidating these structures would require extensive legal and financial review, result in substantial transition costs, and divert funding and staff resources away from critical watershed programs.

Risk of increased costs: The proposed Ontario Provincial Conservation Agency (OPCA) model includes the ability of the Agency to charge back fees to RCAs and collect operating costs. Without a cost-benefit analysis confirming no net cost increase to municipalities or conservation authorities, I am concerned about budget impacts (to tax payers, municipalities) and limits on the ability to generate additional revenues. In Niagara, residents benefit from free access at most conservation areas in their watershed while other conservation authorities charge for access to each property. I would be concerned about the loss of free access to greenspace when science has proven the strong links between access to greenspace and the benefits of mental and physical well-being.

Potential impacts on staff capacity and service delivery: Larger regional boards, increased administrative oversight, and complex budgeting processes may reduce the capacity of expert staff to deliver the same level of watershed programming communities rely on. I recommend exploring legislative and regulatory tools that could achieve modernization goals without restructuring. There may be a loss of staff expertise as staff not wishing to amalgamate may seek other employment opportunities. Additionally, some conservation authorities, including Niagara, Grand River and others have unionized staff.
Importance of local accountability: Municipal levies currently support a significant portion of most CA operating budgets, compared to a very small percentage in annual provincial transfer payments. Any future restructuring must ensure that municipal dollars, self-generated revenues, and regional assets remain dedicated to local communities.

For landholdings - many properties were donated to specific conservation authorities for local conservation efforts. If all land holdings are transferred up to the province this could have impacts on community trust, future land donations, and efforts to secure local environmentally significant areas. Each conservation authority has dozens if not hundreds of individual parcels of land, transferring all those lands to the province or RCA would pose significant legal and financial burdens, not to mention the staff resources required to see this through.

Conservation authorities started from grassroots, local-level advocacy and this proposed amalgamation goes against the long history and proven track record of local conservation efforts. Most staff that work at CAs work there because above all else they care about conservation, especially the local communities they serve.

One of the three fundamental principles that were embodied in the Conservation Authorities Act, 1946:
Local initiative
A Conservation Authority in any area could only be formed when the desires of the residents reached the point where they were willing to request the government of Ontario to form an authority. In making the request, the local people had to face up to the responsibility of contributing financially to the work of the Authority and also agree to assume the burden of running the corporate body known as the Conservation Authority. This latter task involved burdens and responsibilities similar to the running of a municipality. The local initiative requirement meant that people living close to the problems were required to recognize and solve them. It also meant that solutions would not be imposed from above and an authority would only undertake those plans which it could face economically, culturally and democratically.

Each Conservation Authority’s watershed management programs are geared to specific needs and are scoped according to the resources available.

CAs have been continually dealing with changes to the CA act, to Planning Policy and other requests from the province and yet there continues to be this removal of layers of programs and services despite CAs playing by the provincial rules and doing what is asked of them.