Submission on the Proposed…

Submission on the Proposed Regional Consolidation of Ontario’s Conservation Authorities
Environmental Registry of Ontario, ERO #025-1257
December 21, 2025

Thank you for the opportunity to comment on ERO #025-1257 outlining the Province’s proposal to consolidate Ontario’s 36 Conservation Authorities (CAs) into seven large regional entities. The Environment Council for Clear, Ston(e)y and White Lakes (EC) and Shoreline Conservation: Peterborough County (SCPC) have a number of concerns regarding the planned consolidation. Complicating our assessment of the benefits and costs is the lack of detail on the implementation, and subsequent governance, operation and financing of the proposed regional conservation authorities. We therefore urge the Province to slow its overhaul of the current CA structure to develop solutions and adjustments to the consolidation plan to better meet the needs of affected stakeholders. A sample of our concerns is summarized below.

The Environment Council for Clear, Ston(e)y and White Lakes, is a volunteer, not-for-profit
multi-stakeholder organization dedicated to protecting the health of its member lakes and the
surrounding natural environment. Shoreline Conservation: Peterborough County (SCPC), founded by the EC in 2021 and now its partner, focuses on enhancing the health of Peterborough County’s lakes by promoting the preservation and restoration of natural shorelines. Both organizations network with ratepayer/lake associations; advance natural heritage protection with the County’s five northern Townships; and monitor lake health, shoreline research and provincial/municipal policy developments.

We acknowledge the possible benefits of some of the related CA changes, such as the future
research potential of the suggested Ontario Provincial Conservation Agency. With respect to
the CA consolidation, however, the sheer scale of the new regional authorities could in fact
hinder the administrative efficiencies and procedural alignment that the Province seeks. Other
solutions, such as shared services, could be investigated.

The specific questions for feedback in the ERO #025-1257 posting delve into some of the
thorniest issues. The suggested “Eastern Lake Ontario Conservation Authority”, for instance,
spans over 28,000 sq km, incorporating seven existing CAs and 48 large and small
municipalities. Representation of each local municipality on this new regional CA board, a
hallmark of the present CA structure, will be virtually impossible. Key functions could be
cumbersome, such as gaining approval for a consolidated CA’s annual budget from each
municipality paying fees. One solution to monitoring and managing the increased ecological
diversity in the new “Eastern Lake Ontario Conservation Authority” might be the creation of
sub-watershed committees, but this adds another layer of administration and expense.

The extent and delegation of the financial costs during and after the consolidation receive little
discussion. Yet for many municipalities, particularly smaller rural governments where resources
already are overstretched, these are critical issues. Moreover, the transition to the consolidated
authorities inevitably risks service disruptions and a loss of data and “corporate memory”.

Looking back, Conservation Authorities were created after Hurricane Hazel, at a local
watershed level and with accountability to local stakeholders, to implement conservation
initiatives and regulate development that could negatively impact local ecosystems. Recent
stresses, such as climate change, escalate the importance of overseeing the distinctly different
environmental conditions occurring across local watersheds. Pausing the Conservation
Authority consolidation plans is strongly urged to address the multiple challenges inherent in
the current proposal.

Thank you again for the opportunity to provide input on the proposed Conservation Authority
consolidation. The Environment Council of Clear, Ston(e)y and White Lakes and Shoreline
Conservation: Peterborough County are happy to answer any queries arising from this
submission.

Respectfully,

Environment Council for Clear, Ston(e)y and White Lakes
Shoreline Conservation: Peterborough County