Comment
Thank you for the opportunity to voice my strong opposition to the proposed changes the Conservation Authorities Act. These changes are akin to using a sledge hammer to drive in a thumb tack. I provide below, both general feedback and question-specific feedback.
My general feedback on these changes is:
1. It is not necessary to create a new agency (i.e. Ontario Provincial Conservation Agency) to oversee the Conservation Authorities (CAs). This would be a duplication of effort, would be costly and would be a waste of taxpayer money. As subject matter experts, our Conservation Authorities understand their mandated role and know what needs to be done to fulfill their role. They are already serving the provincial priorities. CAs work very effectively at multiple levels with their local communities, with their municipal and regional partners, with other agencies and groups and across the individual CAs.
2. If the provincial government has specific products or services they see as lacking or needing improvement, the province would be most effective if they restored the funding of the CAs to a level that allows the CAs to provide those services/products. The reduction in provincial support to the CAs over the last 10 years has been the cause of any perceived lapses in their productivity, not any unwillingness on the part of the CAs. Restoring CA funding would be far more fiscally responsible than creating a new agency of provincial appointees (which is hopefully a lesson learned from the fiasco of the agency set up to manage the Species at Risk Conservation Fund).
3. Despite the provincial government's fanciful predictions as to the benefits of a new CA oversight agency nor to consolidation of the CAs, there is NO concrete evidence to support those claims.
4. CAs fill a vital role in engaging the public at a local level to maintain and restore a healthy environment. This role is ONLY filled by our CAs. Government agencies and ministries do not operate at a local level nor do they have specialized knowledge of local issues or needs. Local citizens see value in what their CAs do and they feel that their voices are being heard by the CAs. This local connection will be lost if the CAs are consolidated into larger, homogeneous regional authorities. The loss in public support on environmental issues, and all the engagement and stewardship that comes from it will be significant.
5. Under the large umbrella of a consolidated regional authority,members of the public will come to feel that their voices are not heard, their local issues are not dealt with and that other parts of the region are being favoured with attention and resources over their own. Regional authorities will create a discontented, disconnected public. Think about how Ontarians view Alberta as receiving more than their fair share of attention and resources federally. Another example is to recall how the 3 municipalities in the Region of Peel debated disproportionate distribution of resources within the region (triggered by the government's efforts to dissolve the Region of Peel). Consolidation is NOT the answer because it destroys local support and connection, which is precious.
My more specific feedback on the questions posed in the EBR posting is:
A. Key factors to support a successful transition and outcome to consolidated CAs:
- Do NOT consolidate. Simply lumping current CAs on a map doesn't solve any issues and instead creates new issues (see my points 4 and 5 above). Allowing the current CAs to respond their local needs is critical and should be retained. The public actually likes to be treated as special, as an individual, and does not like being dealt with as being the same as everywhere else.
- Watersheds should be kept intact and wholly included in the CA.
- To improve sharing of practices, knowledge and resources, the current CAs should be better funded to allow more cross-CA sharing. This is already occurring but could be increased. Funding for knowledge transfer and dialogue across CAs should be provided as part of their core provincial mandate.
B. What opportunities or benefits may come from a regional framework:
- To make this assessment fairly, both benefits and losses must be considered.
- Most significant will be the loss of local connections with the public from consolidation (see point 4 above). Combine this with an increase in public discontent and an increased view of disproportionate distribution of regional resources/attention caused by consolidation (see point 5 above).
- Recognition of the need for greater cross-(current)Ca dialogue and sharing could be a benefit of the exercise of CONSIDERING current versus consolidated CAs. But addressing this need is best done with the current CA model. The benefit of improved sharing would be outweighed by the loss of lost public connections if consolidation occurs.
C. Suggestions for how governance could be structured at the regional authority level:
- It is a given that the consolidation of the governance of CAs will result in the dilution of local voices and a narrowing of viewpoints (diversity broadens perspective). Regional governance will also cost more as board members will have greater distances to travel to meetings.
- The solution is NOT to consolidate. Instead, the boards of all current CAs should come together to identify common, high-level values and principles that will guide governance across all current CAs. This will allow the boards of the current CAs to operate with integrity yet still be flexible to local needs. This will retain public connections to the individual CA governance structures and retain board accountability to their constituents.
D. Suggestions on how to maintain a transparent and consultative budgeting process across member municipalities of a regional authority:
- I believe the current CAs already to transparent and highly consultative budgeting in collaboration with their municipalities. I also see many examples of municipalities (upper and lower tier) collaborating on projects. It appears to be very effective.
- Leaving the CAs as they currently exist (i.e. not consolidating them) will be the best way to keep this successful. Consolidating to form regional authorities will make this painful, as new municipal-CA relationships would need to be built and balanced with the added issues of disproportionality and envy being added.
- I see no benefits and only losses in this regard under a regional authority model. If the province perceives issues between municipalities and current CAs, then funding for increased dialogue among CAs to share lessons learned and successful practices would be most effective (including being most cost-effective).
E. How can regional authorities maintain and strengthen relationships with local communities:
- Regional authorities cannot "maintain" relationships with local communities because they don't have any at present. Regional authorities are not and WILL NOT BE THE SAME as current CAs, and their relationships with local communities will de facto, not be the same as when current CAs enjoy with their local communities. Local relationships are not transferable, they need to be built from the ground up. This is something the current CAs know and have done over many years.
- Regional authorities cannot do better local relationships than the current CAs are doing, because regional authorities are not local entities. Consolidation will cause the loss of relationships as local communities become disenfranchised.
- The only way to preserve local connections is to NOT consolidate the current CAs. This is one of the greatest strengths of the current CAs. It is much too important to throw away.
Submitted December 21, 2025 7:50 PM
Comment on
Proposed boundaries for the regional consolidation of Ontario’s conservation authorities
ERO number
025-1257
Comment ID
177916
Commenting on behalf of
Comment status