I am a drainage…

ERO number

025-1257

Comment ID

178264

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Individual

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Comment

I am a drainage superintendent for two municipalities in the proposed Lake Erie Regional Conservation Authority (LERCA). I am responsible to these municipalities for the implementation and administration of the Ontario Drainage Act. Through this work I work closely with two local conservation authorities (CAs) regularly.

I acknowledge the province’s continued recognition of the vital role that conservation authorities play in delivering watershed management across Ontario. The proposal to consolidate 36CA’s into 7 regional CA’s lacks sufficient detail or assurances on how local decision making, knowledge and community involvement will be maintained in a regional model. CAs were founded on a community-based framework with local municipal governance and watershed scale decision making. The amalgamations could fundamentally and permanently diminish local decision making and responsiveness to the community.

There has been no meaningful consultation with municipalities and stakeholders. There has been no specific evidence-based analysis that has been provided to justify a larger, regional conservation authority or the need for a provincial agency providing oversight that was historically the responsibility of a specific ministry. There has been no cost-benefit analysis provided on how the new model will be more efficient and less costly. There has been no clear transition/implementation plan provided. The risks associated with consolidation at the proposed scale outweigh the potential benefits.
Local governance will suffer from the limited information that has been provided by the province. The LERCA will be comprised of 81 municipalities, 12 of which include large cities plus many large towns. Under the current existing system local rural municipalities have a voice in the decision making of their local CAs. The province is proposing to appoint 5-12 members to the Ontario Provincial Conservation Agency (OPCA). Will these members be accountable to the local community or the province of Ontario who appointed them. From the very limited information provided by the province it seems that under the proposed system local governance will be very limited.

The two CAs that I work with in the proposed LERCA are meeting or exceeding provincial guidelines when it comes to supporting the drainage industry. A larger reginal CA may lead to a less responsive organization with:
1) Field staff having less authority to make decisions
2) less field staff resulting in slower response time
3) Loss of local expertise that is knowledgeable
4) Loss of local offices over time with requirement to report to a larger reginal office
5) more levels of management. Negatively affecting speed of reviews and approvals
6) more administration and policies
7) All of the above resulting in increased costs for municipalities and higher fees

I feel that an actual full consultation with all stakeholders should be conducted. I feel that it will be very important to maintain strong local voice and governance that is accountable to the residents of the watershed that are able to provide transparent and timely responses.