Re: ERO #025-1257 - Proposed…

Re: ERO #025-1257 - Proposed boundaries for the regional consolidation of Ontario’s conservation authorities

We are opposed to the scope and scale of the proposed boundary changes proposed for Ausable Bayfield and St. Clair Region Conservation Authorities, the two Conservation Authorities (CAs) that currently serve the community of Lambton Shores.

Our organization, the Lambton Shores Phragmites Community Group, located in Lambton Shores, along the Lake Huron shoreline in Lambton County, was formed in 2009 as a result of discovering invasive Phragmites australis on our beaches and in our wetlands. Within Lambton Shores, we have numerous ANSI sites, Areas of Natural and Scientific Interest, and areas designated as Provincially Significant and Globally Rare. They include Oak Savanah, Carolinian Core Forest, Coastal Meadow Marshes, and Coastal Dunes, as well as rare geological formations at Kettle Point and Rock Glen in Arkona. At the time our group was formed, not a lot was known about invasive Phragmites and the dangers associated with its spread, and it was viewed as a local problem with no one taking responsibility for managing it. But because they were local and intimately familiar with our unique watershed characteristics, we were able to quickly engage our CAs in what has become a 16-year campaign to restore sensitive habitat, a battle that we are winning. We fail to see how the proposed consolidation will speed up decision-making when the amalgamated authorities will need to serve dozens of municipalities with unique local needs and spanning watersheds with distinctly different environmental conditions. The proposed boundaries are far too sprawling to enable locally relevant decision-making.

CAs are a valued local presence that provide key stewardship, parks, trails and educational activities, in addition to flood management and regulatory functions, so essential to keeping our area safe.
A regional CA model will diminish the CA partnerships and local presence on the ground.
If, as the province asserts, this is about consistency and improved customer service across boundaries, there are many other options available that would be faster to implement and likely more cost effective, while supporting local needs. This level of disruption and distraction suggests that the province is seeking an excuse to dismantle a system that has been in place for almost 80 years rather than work with the parties affected to support their stated objective of faster housing development.
We do not think that there can be a successful amalgamation of that many conservation authorities. Some thoughtful and consultative options may benefit smaller or under resourced CAs but should be done with those CAs and their municipalities. The province should:

• Carry out intensive consultations with all parties before introducing a one-size-fits-all approach to this proposal
• Maintain local presence
• Maintain municipal appointments to the boards based on population
• Maintain local naming of parks and facilities
• Ensure municipal funds are allocated to their local watersheds
• Increase provincial funding to CAs to ensure that they can carry out the work the province requires of them.

Thank you for the opportunity to provide comments.

Respectfully,
Lambton Shores Phragmites Community Group
Bill MacDonald, Vice-Chair