First, a positive note: It…

First, a positive note: It is intently hoped that the new Chief Conservation Executive position and Ontario Provincial Conservation Authorities Agency (OPCAA) can be a new start and a long overdue reinvestment and good faith reengagement in the work of Ontario's conservation authorities by the provincial government. It is also hoped that this proposal will be refined and that local voices, municipal representatives and citizens will be listened to and heeded.

Now in their 80th year, Ontario's conservation authorities grew organically, community-by-community and watershed-by-watershed over more than a generation from the passage of the Act in 1946 to the early 1980's. Local initiative combined with the open hand of provincial partnership provided a thoughtful and democratic method to establish what are now 36 community and watershed-based local agencies.

95% of conservation authority funding is either self-generated or obtained through municipal levy. The province contributes a shameful 5% to all of the vital, and local, conservation work of Ontario's conservation authorities. Significant provincial fiscal support for conservation authorities ended a generation ago in 1995. Since that time, the province has been a very poor steward of its vital and successful conservation authorities.

It is true that budgets reveal both policy choices and values. For the past 30 years, the Government of Ontario has been making poor policy choices and value judgements when it comes to supporting locally administered and implemented conservation work under its Conservation Authorities Act. Sadly, the abundant success of Ontario's conservation authorities over the past generation has been despite the provincial government's actions not due to them.

Now, despite a 5% fiscal commitment to conservation authorities work, the ministry is proposing a top-down centrally-developed model of 7 conservation authorities for the existing geography served by the existing 36 local conservation authorities. Instead of a centrally developed model, a wiser course of action would be to incentivize local amalgamations (if amalgamations are found to be desirable through study) through fiscal support and evaluation of local conditions. Just as local communities were asked by the province to decide if they wished to form a local conservation authority, the province should seek local consent on amalgamations, given that local communities have been the near sole funder of these local organizations for the past 30 years.

The issue of amalgamations should be further studied and reflected upon by the new OPCAA as it is established prior to moving forward with the very aggressive proposed reduction to 7.

One key understanding should be that conservation authority staff require effective relationships with local watershed municipalities.

Since the current 36 conservation authorities are already organized on a regional watershed basis, most conservation authorities staff already have to deal with multiple different municipalities and departments. It has been noted in the consultation materials that many municipalities have more than one conservation authority watershed in their jurisdiction. Similarly, and even more so, as conservation authorities are regional entities, they each have many municipalities in their watershed. For example, see the Grand and Lake Simcoe Region watersheds for the multiplicity of municipal relationships that must be maintained by staff for effective work.

For front-line services, which are the majority of conservation authority services, such as the key services of land use planning and regulation, deep local knowledge of the geography, landowners, policy issues, and municipal departmental staff is a prerequisite. The number of municipal relationships that would be required on the basis of 7 conservation authorities across the province is not realistic and unworkable. With the exception of corporate-scale services, such as finance, human resources, accounting, information technology etc., the proposed boundaries would directly undermine the stated objectives of the reform.

Should the ministry proceed with a small number of super-regional conservation authorities, the following is recommended:

- Keep the existing local boards under their current composition and geography. The local board chair could serve on an executive board to govern the full Regional Conservation Authority.
- The local board should oversee all front-facing services such as land use planning and regulation services and make budget representations based on local needs and priorities as part of the regional CA budget making process.
- Front-line or citizen facing services should continue to be delivered locally in existing locations, which are already undertaken on a "regional" scale serving multiple municipal jurisdictions on a watershed basis.
- The existing regional watershed boundaries of the 36 conservation authorities could be organized as "Conservation Areas" or "Conservation Service Areas" under the regional CA.
- The regional CA board should oversee services that are corporate-level and which do not require a local front-facing staff. This could also include policy development and relationships with the provincial agency.
- The province should return to a strong 50-50 partnership for operating and capital budgets for the new CA structure reflecting the vital value of CA work and the need to further prepare for a rapidly changing climate.
- Changes in 2023 removing the ability of conservation authority staff to assist municipal planning staff with respect to natural heritage matters, which are inextricably linked to natural hazard matters, must be reversed, as these changes have slowed development review and have added unwelcome and unneeded complexity. Municipalities that wish to receive this service from the conservation authority should not be prevented from doing so. Ontario Regulation 596/22, "PRESCRIBED ACTS - SUBSECTIONS 21.1.1 (1.1) AND 21.1.2 (1.1) OF THE ACT", needs to be amended or revoked as soon as practicable.

Respectfully submitted with the hope that we are at the start of a new era in the good faith renewal of Ontario's vital and effective conservation authorities.