Thank you for the…

Thank you for the opportunity to provide comment on this proposal. Though I appreciate the Province’s commitment to increase housing and development, I do believe that it is going about it in a way which is not optimal.

In my professional opinion, the proposed amalgamation and new borders for the 7 Regional Conservation Authorities was not presented with sufficient rational, reasoning, or science. Since this proposal has been posted on the ERO there have been hundreds of articles created and shared on this topic, which I believe makes it hard to deny that there is significant pushback on this proposal across the public, conservation authorities, legal bodies, municipalities, and various NGOs. I would like to highlight a few of my concerns, as well as provide suggestions on this proposal, as was strongly recommended by MECP staff.

1) Firstly, and most concerningly, the amalgamation of Conservation Authorities will lead to the loss of representation for smaller municipalities across the province.

This is undeniable. Depending on which new Region you are looking at, they will be meant to represent 50, 80, or even more municipalities. The dissolving of current Conservation Authority boards and Source Water Authorities to form new boards to represent larger areas with fewer people. Smaller municipalities, which will be expected to continue to pay for representation, will lose their voice.

The ERO and the Minster have stated that Conservation Authorities are “fragmented, inconsistent, and outdated”. The current scale at which CAs and Source Water Areas/Regions function are as such to provide regional representation and ensure that there is local expertise that fully understand the unique geography, geology, hydrology, and issues of each region. Different rules, tactics, programs, and projects across different CAs is not a “bug” or problem to be solved, it is a feature and representative of the original intent of CAs and Source Protection Areas and Regions.
Local representation must be maintained.

“Strengthening local partnerships” will also not be achieved with amalgamation. In fact, the opposite will be achieved with the eroding of relationships that have been built up over decades from local action and local communications.

2) Financial Concerns

Currently there has been no official estimate from the Province on the amalgamation process, however several independent estimates have placed it at one hundred to two hundred and fifty million dollars, at minimum. I am concerned that the Province has not taken into account all of the costs of amalgamation. For example, the dissolution of the existing CAs, the removal of charity statuses, name changes, logo changes, website changes, and more.

The Province has stated that shared resources across existing CAs is a large positive of the amalgamation. I agree that there are significant gaps across CAs. For example, hydro geologists are rarely on staff, GIS staff is strained, and Development staff is constantly understaffed (Especially since the Pandemic ramped up construction). The tax payer funds being used on amalgamation could instead be used to hire professionals and additional staff to maintain or even improve efficiencies (in particular in the Development Review departments, GIS, and hiring of hydro geologists.). This would go a very long way towards achieving the goals of the Province while reducing the load on Conservation Authorities, which in part is due to reduced funding from the Province over the past few decades.

Furthermore, “taxation without representation” is a sentiment being brought up by several of the smaller municipalities in relation to point #1 above. After 3 years, the cost of the new OPCA will be placed on the CAs and therefore the municipalities. They will be expected to pay the same amount to CAs (if not more) with less representation.

3) Efficiency

One of the main pushes of amalgamation is to increase efficiency, particularly in relation to building permits. However, they have provided no statistics to back that the current system is inefficient. In fact, in some CAs, the exact opposite is true. As an example, Cataraqui Conservation completes development applications within 5 days 99% of the time (over the past 2 years). In this case, there is no room for improvement and amalgamation will surely lower the success of this. Other CAs have similarly positive results, and those that do not could benefit from being supported in ways that they identify through collaboration.

In addition, to be frank, amalgamation would create a chaotic environment within CAs for several years as offices, staff, and policies are shuffled and shifted. The proposal alone has taken significant staff time away from regular tasks.

In an effort to provide constructive criticism to this plan, below are some suggestions on what can be done should the province decide to reject the advice of its municipal representatives, public, and professionals:

1) The existing Conservation Authority Boards and Source Water Authorities must remain as they are.

It is suggested that select Board and Authority members be placed on the regional board to maintain representation. Furthermore, related to this, it is strongly suggested that the Minister fulfill his duty in appointing Source Protection Committee chairs, as promised by MECP as far back as August. Though it is not the Minister’s intention, it does read as suspect that this unprecedented amount of Chair vacancies is occurring at the same time that a number of proposal critical to Source Water protected have been posted and passed.

2) The existing 19 Source Protection Areas and Regions should be the absolute minimum scale at which the new regions be created.

The 19 Source Protection Areas and Regions currently function on a manageable watershed scale and can not be scaled up further without losing efficiency and representation. 7 regions places housing, people, and property at risk. There is a limit to scale and 7 regional authorities far surpasses that.

3) Halt amalgamation as proposed and commit to a collaborative process.

When speaking with MECP staff and the few political figures who are in favour of this proposal, there was a confusion as to “what the rush is” and “why the resistance” to this proposal. Other than being informed by our experience and local expertise, the resistance comes from the fact that consultation with CAs and experts should have occurred before the proposal took place. Collaboration could have resulted in a much smoother process and a framework which would achieve the Province’s goals as well as the mandate of CAs.
Conservation Authorities and Drinking Water Source Protection were not created to oppose development and housing. CAs were put in place by a Conservative Government to protect property and people, to guide development in a fashion that would keep people save and their investments in land safe. Drinking Water Source Protection was put in place to protect sources of water and to avert disasters like that which occurred in Walkerton 25 years ago. I ask that the Province take this into consideration.

4) Work with CAs to effectively roll out a new, province-wide digital system for development permits.

I agree that this aspect of the proposed amalgamation would be beneficial. However, it must be developed in partnership with Conservation Authorities to draw on the expertise of those on the ground who complete this work day to day. This will be better for all parties involved.

Please note that the above suggestions are in no way endorsements of amalgamation, but instead bare minimum considerations if amalgamation is inevitable. I am strongly opposed to amalgamation as an Ontario native, as a current citizen, as a professional, and as someone who hopes to one day own a home. I urge the province to work with its people rather than against them for a long term, efficient, science-based solution.

Thank you