I appreciate the opportunity…

I appreciate the opportunity to provide feedback on the proposed consolidation of Ontario’s 36 conservation authorities into seven regional entities and the creation of a provincial oversight agency.

I recognize the government’s stated goals of improving consistency, reducing administrative duplication, and accelerating permitting timelines. However, as proposed, the consolidation raises serious concerns regarding environmental protection, local accountability, and adherence to watershed-based management principles, particularly in the context of climate change and increasing natural hazard risk.

1. Loss of Local Expertise and Accountability

Conservation authorities have historically been effective because they are grounded in local hydrology, land use history, and community relationships. Merging authorities into very large regional bodies risks distancing decision-makers from the specific flood dynamics, erosion patterns, and ecological conditions of individual watersheds.

While local knowledge is referenced as being retained, the proposal lacks clarity on how local technical expertise will be preserved in decision-making authority rather than limited to advisory roles, how smaller or rural municipalities will maintain meaningful influence within large regional boards, and how accountability to local communities will be ensured when governance and oversight are increasingly centralized.

Without explicit safeguards, consolidation may weaken rather than strengthen responsiveness to local flood risk and land use pressures.

2. Risks to Science-Based, Watershed-Led Management

The Conservation Authorities Act is grounded in the principle that watersheds, not administrative convenience, should guide environmental governance. Several of the proposed regional boundaries appear to combine hydrologically distinct systems, which risks undermining integrated watershed management.

This concern is heightened by increasing frequency and severity of flooding due to climate change, the cumulative impacts of development across watersheds, and the need for fine-grained, place-specific data in hazard mitigation and source water protection. Efficiency gains should not come at the expense of hydrological integrity or scientific rigor.

3. Lack of Evidence Supporting Efficiency Claims

The proposal repeatedly references improved efficiency, consistency, and reduced duplication, yet provides little publicly available evidence demonstrating expected cost savings versus transition and long-term operating costs, how technical harmonization would occur across vastly different watersheds, or whether permitting delays are primarily structural, staffing-related, or policy-driven.

Without transparent data, it is difficult to assess whether consolidation is the most effective or proportionate solution to the challenges identified.

4. Governance, Transparency, and Public Trust

The creation of a provincial board-governed agency overseeing conservation authorities raises concerns about reduced municipal and community influence, perceived prioritization of development objectives over environmental protection, and public confidence in the independence of conservation authority decisions.

If consolidation proceeds, strong governance safeguards are essential. These should include guaranteed local and Indigenous representation on regional boards, clear conflict-of-interest protections, transparent and consultative budgeting processes across member municipalities, and public reporting on environmental outcomes rather than solely on permitting timelines.

5. Recommendations for a More Responsible Path Forward

To support a successful transition, if consolidation proceeds at all, I recommend re-evaluating proposed boundaries to ensure strict alignment with hydrological systems, piloting shared services or technical support models before full structural consolidation, publishing detailed cost-benefit and risk analyses, ensuring meaningful public and municipal consultation before legislative changes are finalized, and embedding climate resilience and environmental protection as explicit and enforceable priorities.

Conclusion

Ontario’s conservation authorities exist to protect people, property, and ecosystems from natural hazards, not to facilitate development at the expense of long-term resilience. Any restructuring must strengthen, not dilute, their ability to deliver science-based, locally responsive watershed management.

As currently proposed, the consolidation risks eroding public trust, weakening environmental protections, and compromising the very outcomes conservation authorities were created to achieve. I urge the government to pause, provide greater transparency, and meaningfully incorporate expert, municipal, Indigenous, and public input before proceeding further.