My feedback in response to…

My feedback in response to the proposed boundaries and criteria applied to inform the boundaries for the regional consolidation of Ontario’s conservation authorities is as follows: the boundaries, and criteria used to inform these boundaries, are not logical, not science-based and not transparent, and the consolidation of current CAs into the proposed regional conservation authorities will not result in the stated goals of improved operational efficiency, improved transparency, improved resources or tools to frontline staff, or decisions based on sound science, nor will they result in improved infrastructure, housing and especially not in improved climate resilience.

In fact, it will do the opposite.

This proposed consolidation to regional CAs and their new boundaries, as well as the creation of the Ontario Provincial Conservation Agency – a new layer of provincial bureaucracy with a high potential of being disconnected from, and uninformed by, the landscapes and watersheds it administers - will result in reduced transparency, reduced watershed management effectiveness, reduced science-based watershed-specific decision-making, and increased monetary and health costs to Ontarians caused by greater risk of flooding and to drinking water quality and quantity due to increased and inappropriate development in wetlands, floodplains and shorelines.

Comments on Select RCA Boundaries:

Lake Erie RCA
The watersheds in this huge RCA are dramatically different and range from landscapes with many large cities heavily reliant on large rivers and groundwater for drinking water within a rolling, erosion-prone landscape with lots of livestock, to flat clay plains where small rural communities, cash crops and vegetable crops are drained by small tributaries directly into Lake Erie. There are already 5 large unique CAs (Grand River, Upper Thames Valley, Lower Thames River, Essex Region and St. Clair Region) that administer much of this region. Consolidation of smaller adjacent CAs with similar physiographic characteristics (i.e., similar geology, soil, landscape, ecology, hydrology etc.) like Catfish Creek and Kettle Creek into a medium-sized CA makes much more sense than to try to administer the entire Lake Erie basin as one unwieldy RCA.

Huron-Superior RCA
The proposed boundary of this RCA defies logic. How will merging the Lakehead Region CA with CAs for Lake Huron and Georgian Bay make any improvements to the administration or operation of any of these CAs? The Lakehead Region CA is over 1500 km away from the Lake Huron/Georgian Bay CAs and is in a completely different Great Lake, with different ecology, physiography, climate and economic and developmental pressures. Even without Lakehead Region, merging the Huron/Georgian Bay CAs make no sense -the landscapes, population pressures and agricultural realities are significantly different. For example, the rich farmland that drains into Lake Simcoe supports high value vegetable crops that feed Ontarians but is at risk of loss to development due to its proximity to the GTA. Contrast this with the fertile loamy soil of Ausauble-Bayfield and Maitland CAs that support high-value dairy and hog production which contribute to algal blooms on Lake Huron’s high-value beach shorelines.

Comments on Criteria Applied to Determine RCA Boundaries

Criterion 1) Maintaining watershed-based jurisdictions – aligning with natural hydrological boundaries to support effective flood and water management, consistent with drinking water Source Protection Areas and Regions

Response:
This criterion was not met for many of the proposed RCA boundaries. Many certainly do not follow natural hydrological boundaries – within an RCA, watersheds discharge a) to different Great Lakes (e.g., Huron-Superior), or b) to different basins or subwatersheds of a Great Lake that have significantly different management needs (e.g., Huron-Superior, Lake Erie, Eastern Lake Ontario, St. Lawrence Regional, North Eastern Ontario).

Criterion 2) Relationships between conservation authorities and municipalities – reducing administrative duplication and overlap for municipalities and conservation authorities to simplify accountability and strengthen local partnerships.

Response:
The province has not provided specifics of what they mean by “relationships between CAs and municipalities” or how these “relationships” were applied against each CA and its associated municipalities to come up with the resulting RCA boundaries. There is no transparency in the application of this criterion.

Furthermore, how does this criterion reconcile its stated goal with the fact that local partnerships and relationships between municipalities and CAs have been greatly weakened under the recently passed Ontario Bill 23 that prohibits CAs from partnering with municipalities and providing their expertise with regard to planning applications?

Logic and my lived experience suggest that merging CAs will reduce local partnerships and reduce accountability as local partners will be consolidated into a larger organization, which will be inherently less efficient and transparent. Evidence of this can be found following municipal amalgamation in Ontario in 2001 where smaller, local municipalities lost representative power and financial and operational accountability.

Criterion 3) balancing expertise and capacity across conservation authorities – enhancing technical skills and resources across conservation authorities to improve service and program delivery.

Response:
How was criterion this used to defined RCA boundaries? There is no explanation as to how this criterion was applied. Certainly, there is an uneven distribution of expertise and capacity across existing CAs; however, consolidating them and adding an extra layer of centralized bureaucracy will not fix this problem. Instead of consolidating CAs, the structure and boundaries of the existing CAs should be maintained while provincial funding to develop/hire expertise and capacity – to specific CAs, not for a new agency – is provided where there is a lack thereof. Province-wide CA standards for expertise and capacity (and operations) can be created by the CAs through the existing Conservation Ontario umbrella, supported by existing policy and standards development staff from the Ontario MECP and MNR.

Criterion 4) service continuity – ensuring uninterrupted delivery of local conservation authority programs – including flood forecasting and warning, permitting, and source water protection – through and after consolidation

Response:
Why is the province proposing to fix something that isn’t broken? There already exists uninterrupted delivery of local CA programs including flood forecasting and warning, permitting etc. Also, how was this “criterion” used to define RCA boundaries? As stated, this it is not a criterion; it is a statement of reassurance that what is already working well won’t be degraded following the CA consolidation.

Summary:
I have worked for years directly with many experienced, dedicated and expert staff from numerous CAs literally on the ground as research and watershed management partners. I have also worked with them as a private citizen where their passion and expertise support my individual watershed stewardship efforts. I have also enjoyed the many services that CAs provide to Ontarians as part of their stewardship of Conservation Areas.

Please listen to the people of Ontario who do not support this proposal. Please also listen to the experts from the Conservation Authorities who are doing tremendously valuable work at the local level so effectively and efficiently with farmers, landowners, stakeholders and others for the care of the future of Ontario and its people. I agree with the ERO submission of the Conservation Authorities that are local to me, both the Grand River Conservation Authority and the Hamilton Conservation Authority. I also agree with the ERO comments from CAs throughout Ontario who are in opposition to the proposed consolidation.