I am providing my comments…

I am providing my comments on the proposed amalgamation of the Ontario Conservation Authorities. In short, I believe that the current proposal is flawed and will not meet the intended objectives and will actually do the opposite.

First to support my qualifications to provide these comments: I have over 45 years of experience in the field of watershed management, in Ontario as well as the US, Europe and Australia. When I started in this field, Ontario was viewed as a leader in watershed management because of our Conservation Authority structure and we provided training to representatives in other countries. This provides a basis for what many other countries are doing today. In my career I have carried out this work in both the public and private sector providing training as well as developing watershed management plans. Through this I have carried out work for most of the Conservation Authorities across the province as well as for various provincial and federal agencies.

I recognize the concern with regard to the lack of consistency between the programs of the various Conservation Authorities and, through my experience, feel that this is the result of the following:

1. As the years have gone by the leadership and policy development of both the MNR and MOE has diminished. The original policy development on Hazard protection by MNR was very effective and provided a consistent approach across the province which is still followed today. However, there has been very little to modernize these policies. Watershed management guidelines were developed at one point and have been used by most across the province, providing consistency in that process as well. However, when these were to be updated a few years ago that was never completed. Conversely the most recent updates to master planning, asset management, and the CLI-ECA processes are good examples of the province providing consistent approaches for Ontario municipalities. Unfortunately, no guidance has been provided as to how the municipalities should work with conservation authorities in these new initiatives, regardless of the fact that the new PPS requires a watershed-based approach.

2. As you are aware, the conservation authority boards are primarily made up of municipal politicians. As a result, the approach taken by the conservation authorities in their day-to-day operations in driven by directives set by the boards. As a result, the actions on conservation authorities, as it is with individual municipalities, for the most part, reflect the wants and needs of the local municipality. This is a reflection of the similar lack of guidance and direction at the provincial level. In spite of this however, there is consistence in provincially mandated actions such as hazard protection.

3. There are differing challenges between conservation authorities across the province, based on local land use conditions, urban growth rates, and local watershed conditions. Over the years, I have developed watershed plans across most of the province, and one thing I have learned is that all watersheds have their own unique characteristics and that all need to have a plan that is tailored to these unique characteristics. So, the management approach to be taken on the Saugeen River needs to be different than that of the Nottawasaga, the Rouge River, and even the Grand River. Similarly, the political wants and needs in those watersheds differ as well, which will also drive the management approach to be taken.

4. As indicated above, much of the differences in the approach taken by conservation authorities is a result of political differences between municipalities. An extreme of this is when Niagara Region, at one point, decided that they could take over the much of the work of the NPCA, but after a short trial they realized that was not going to work. On the flip side, regional municipalities such as Waterloo, and Peel, as well as some others, have been very supportive of CA's in their regions and use them to support their work.

Based on the above, I do not see that amalgamation, as proposed, would work. The differing approach and direction of the municipal members would make it untenable for conservation boundaries as proposed.

That being said however, some amalgamation might be workable. I would suggest, perhaps amalgamating all CA's along the Lake Huron shoreline, CA's along the Lake Erie shoreline, and perhaps the north shore of Lake Ontario (west of Uxbridge), and maybe the Golden Triangle (to capture all of the fastest growing urban areas on the Lake Ontario shoreline). Those suggestions are just thoughts at this time and would take further detailed consideration. However, they are based on the concept of CA's that would be facing issues that are fairly similar and would have municipal members that are require consistent approaches as well.