With respect to the Proposed…

With respect to the Proposed boundaries for the regional consolidation of Ontario’s conservation authorities ERO posting #025-1257 I must first and foremost say that I am disappointed that the wording of the feedback questions themselves indicates a ‘done deal’ and that more fulsome consultation with Ontario citizens and organizations was not more widespread before reaching this point.

I am further disappointed to note that the descriptive paragraph from the ERO introduction clearly fails to understand that the fragmentation and differences as articulated are one of the hallmarks of a system that was designed to respond to local needs and abilities. Watersheds and communities are not “consistent” across Ontario, why should the organizations created to manage and work within them be?

In responding to this posting and the questions articulated, it should be noted by the recipient(s) that doing so is very difficult when the scope and resourcing of the proposed Ontario Provincial Conservation Agency is unknown. One could be far more articulate and helpful in this process if this information was available. “…centralized leadership, efficient governance, strategic direction, and oversight of Ontario’s conservation authorities…” is pretty vague as an agency mandate for organizations that are truly unique in responding to their watershed community and member municipalities constituency.

That said I would hope that the Agency – if a bricks and mortar type of organization - would be located in proximity with other provincial offices, such as in Peterborough, where skills, knowledge, talent pools, and related GIS equipment and services are already located.

Provided that Ontario Provincial Conservation Agency has an operational component and is properly funded long-term, there are certain aspects that could be beneficial and more efficiently implemented at the provincial level, NOT regionally:

 develop, implement and maintain operation of a digital permitting system on behalf of the 36 Conservation Authorities. This would standardize service delivery and processes as well as fee structures at the user end.

 ensure continual and timely updating of, and easy access to, flood plain mapping on behalf of all CA’s (and municipalities not encompassed in authority areas) to an agreed on provincial standard. Less advantaged CAs will benefit from access to such expertise.

 remove any need for imposing a regional governance model by directing ‘provincial’ financial support to the Agency

 be the place where the province can make a difference by supporting the collective good of CA work to the province as a whole – recognize that provincial support used to amount to approximately 50% of CA operations, not the 3% it is now

In response to (reordered) questions posed in the ERO post:

• What opportunities or benefits may come from a regional conservation authority framework?

Quite frankly, I see very little benefit in, and am not in favour of, developing a NEW regional framework. It is not uncommon at all for neighbouring authorities, or those seeking specific guidance or information, to interact and share best practices. Many CA staff across the province know each other or are aware of who is doing what, and don’t hesitate to communicate regularly. In addition, annual gatherings like the Latornell Conference are hugely valuable for sharing. Municipal representatives likewise have opportunities to learn from each other at any number of workshops and conferences.

• Do you have suggestions for how governance could be structured at the regional conservation authority level, including suggestions around board size, make-up and the municipal representative appointment process?

No. From the outset the intent of Conservation Authorities was “Conservation By the People, For the People”. This suggestion that there be regional governance and oversight flies completely in the face of a system that has successfully allowed for LOCAL watershed governance, funding and input. The pride, investment and interest in local stewardship and protection are not something that would continue with any sort of removed governance, particularly when spending locally levied funding.

Board size and representation is clearly articulated in the Act to ensure that local voices are represented. How the proponent expects that people in the current Lakehead Region CA for example, would be well served by representation from a board member who resides in Newmarket or Harriston and has probably never heard of any of the waterbodies in that watershed is quite beyond me.
Will a board member from Thunder Bay have any interest at all, much less understand decisions made under the Lake Simcoe Act? How will the Townships of Mono and Uxbridge, both reporting to THREE of the proposed regional authorities be represented?

If the ERO posting itself had to be modified as recently as December 9 to exclude municipalities that were wrongly included, what confidence would anyone have in the ability of a ‘regional’ board to understand their local issues?

• What do you see as key factors to support a successful transition and outcome of regional conservation authority consolidation?

As noted above, this presumes the certainty of regional consolidation occurring. One would expect however that the transition and imposition of a regional structure would cost far, far more than the province’s current input of what I understand to be about 3% of CA operations. Don't feel that dumping those costs on local CAs will be taken lightly.

A regional model would require massive amounts of legal and visible name changing at great cost, and further confound municipal representatives and citizenry, for what gain? Where does the “corporation” reside in an amalgamated Authority? The amount of (who pays for it?) legal paperwork to dissolve the local corporation in order to have a regional oversight governance board with borrowing authorizations etc. etc. is staggering. To what end? Additionally, the many local Conservation Foundations with considerable funds and properties invested or in trust will by necessity have to update incorporations and other legal documents. Is the province, imposing regional structures prepared to reimburse these organizations and risk having supporters turn away?

If the province is determined to wrest away local control of Conservation Authorities, how are you going to answer to the local people who have for nearly seven decades devoted their local taxes, private donations of land and money, and volunteered time? This is NOT going to be an easy transition and for no foreseeable benefit, so don’t do it.

Amendments to the Conservation Authorities Act and Regulations are already complex and difficult for anyone to navigate and understand; parsing out select activities into another regional layer is not creating any efficiency in this regard.

• Do you have suggestions on how to maintain a transparent and consultative budgeting process across member municipalities within a regional conservation authority?

To the best of my knowledge authorities have continued to develop budgets and report, as required by the Act, to member municipalities, and the province, on their program spending and revenue sources. Municipalities with only a portion in any given authority have long since understood and accepted their proportional representation. Regionalizing activity across a broader region will not simplify formulas that are already complex but are established and understood.

As noted earlier, if provincial funding currently amounts to only 3% of the CA’s operations, then there is clearly a need for the province to be transparent about why any provincially appointed board at the regional level would be needed to oversee budgetary decisions when it is LOCAL funds being utilized.

I find it further disturbing to imagine (as a past fundraiser myself) how ‘regionalizing’ functions such as budgeting, fundraising, communications or educational activities will have any appeal for local citizens, organizations and donors. I can tell you from personal experience, that the closer-to-home a project or service is, the more engaged people will be, including with financial contributions. Regionalizing these and other activities, even data collection, will diminish their appeal, acceptance and any fundraising efforts.

• How can regional conservation authorities maintain and strengthen relationships with local communities and stakeholders?

Regional conservation authorities by their very nature would not have “local communities and stakeholders”. Current CAs remaining local, active and in the neighbourhood, delivering the programs and activities that suit the local area is key to these relationships. Support of the province for big-ticket items like the proposed digital permitting systems and updated floodplain mapping and the assurance that Conservation Authorities will continue to operate under the premise of “by the people, for the people” will be appreciated.

I have been in attendance at national gatherings when Ontario’s conservation authority approach was held up as world-class for being insightful, responsive to and lauded for, managing local watershed ecosystems. Created by municipalities, funded by and accountable to municipalities has been key to their longevity and successes. Citizens and supporters feel “at home” at the local level, less so in a regional one.

Bigger is not always better nor more responsive for operations and certainly not for governance.
Our CAs are not perfect in the eyes of some, but they are undeniably the catalyst through which countless individuals and landowners have come to understand and appreciate their role in Ontario’s local watershed ecosystems.

I take exception to and question statements in this posting;

“These proposed improvements to the conservation authority system would reduce duplicative administrative costs, free-up resources for frontline conservation, and better align conservation authorities’ services with provincial priorities on housing, the economy, infrastructure and climate resilience.”

What do you feel are the duplicative administrative costs? What resources will be freed-up? The CEO who is the face of the CA with each and every member municipality? Who then should that be, someone who doesn’t reside in the area at all? And the kicker for me; “align … with provincial priorities…” NO! CAs have their mandate and priorities, the province has its own. Housing? CAs should by no means be the scapegoat for provincial failures to address this portfolio. CAs ensure “safe homes” the province is the one to address housing on so many other fronts. Climate resilience? CAs were well on the way to significant contributions on that front with on the ground tree planting and conservation tilling programs from the get go – program areas that have recently been declared “non-essential”.

The “provincial” priorities are well and firmly entrenched in what CAs do, they just do it at the local level, with local support, buy in and credible input.

Not at the regional level further away from the people. Leave Conservation Authority boundaries where they are.