December 22, 2025 Ministry…

December 22, 2025
Ministry of the Environment, Conservation and Parks
Conservation and Source Protection Branch
300 Water Street North Tower 5th Floor
Peterborough, ON
K9J 3C7

National Farmers Union – Ontario (NFU-O) Local 312 (London-Middlesex) Submission to ERO 025-1257 Consultation on Proposed boundaries for the regional consolidation of Ontario’s conservation authorities.
NFU-O Local 312 represents farmers in London and Middlesex County, aiming to promote farmers’ economic and social goals, and advocate and develop policy for the benefit of farmers and rural communities.
Conservation Authorities have generated positive impacts in both rural communities and on farms. We have accessed the knowledge, funding, and staffing assistance provided by the Conservation Authorities to protect the watersheds which we farm within, while protecting our livelihoods and feeding our communities.
Members of NFU-O Local 312 know that Conservation Authorities work best when program and service delivery are done by local staff who have built trusted relationships with the farmers and rural communities that they are serving. We also believe that decisions about land-use, conservation, and water management must be made at the local level to be effective and to be responsive to the needs of rural communities. Conservation Authorities provide social, economic, and environmental value to Ontario farms. For these reasons, we are opposed to the proposal to amalgamate the existing 36 watershed-based Conservation Authorities into seven regionally-based Conservation Authorities.
The existing boundaries for Conservation Authorities are logical, science-based, and follow international norms for watershed-based governance. We believe that administrative efficiencies are not the guidelines for making decisions about how we manage our environment, resources, and community safety effectively.
Loss of local service delivery and trusted relationships
NFU-O Local 312 members are concerned that the amalgamation of Conservation Authorities would create a disconnect between local needs and local service delivery, and sever the trusted relationships that Conservation Authority staff have developed with landowners and communities. Conservation Authorities provide important assistance and funding for tree-planting, stewardship programs, local permitting support and community-based flood mitigation.
An NFU-O Local 312 member who farms on the Ausable River recently completed a project with the assistance of the Ausable Bayfield Conservation Authority, commented that:
We worked closely with the Ausable Bayfield Conservation Authority to develop a large-scale water erosion and management project on our farm. The project involved capturing surface water runoff, slowing its flow, and filtering it through a constructed wetland before it entered the Ausable River.
Throughout the process, the Authority’s staff and administration were efficient, knowledgeable, and highly effective. Ausable Bayfield Conservation Authority staff coordinated local funding partners and contractors, ensuring the project was completed successfully. The fact that the Authority is locally governed was essential in building trust with our farm team. We were confident in their understanding of local conditions and appreciated their clear communication about how the project would be monitored and supported over the coming decade.
It is concerning to hear that the Ausable Bayfield Conservation Authority may be amalgamated at the regional level. We fear that such a move would diminish the local relationships, accountability, and decision-making that made this project possible. Losing that local connection could undermine the effectiveness of conservation work and discourage landowners from participating in future initiatives.
Conservation Authorities offer critical assistance to farmers who are looking to complete stewardship projects on their farms to protect local environments and drinking water. It is not just service delivery, but local knowledge that is important too, as a member who farms on the Thames River commented that:
I am a farmer, land steward, and conservationist who works closely with the Lower Thames Conservation Authority (LTCA). I depend on its staff, its local knowledge, and its relationships with farmers, municipalities, volunteers, and Indigenous neighbours. I believe deeply in better governance, not bigger governance—and in organizing our conservation efforts around watersheds.
NFU-O believes that uniformity is not the same as effectiveness. Watersheds differ dramatically, and shifting to a regional approach where watersheds and needs are treated uniformly across a diverse geography is not necessarily effective. What is feasible in one region may be ecologically, economically, or culturally inappropriate in another. Watershed-based Conservation Authorities are already responsive to local needs.
NFU-O Local 312 believes that the proposed model for Conservation Authorities will erode the trust that Conservation Authorities have built with communities and landowners, disrupt service delivery, and discourage voluntary land stewardship. We know that landowners are more open to change and collaboration when they see Conservation Authorities as partners.
Loss of local governance and democratic accountability
NFU-O Local 312 is concerned about the governance, accountability, and decision-making under the proposed regional model.
Under the new model, we have identified that municipalities will have no guaranteed representation on the new regional boards. The amalgamation of the Conservation Authorities into large regions undermines the ability for small, rural municipalities to affect decision-making. For example, the proposed Lake Erie Regional Conservation Authority, which will include all of our members, includes 81 municipalities and 2.2 million residents. We are concerned that small rural townships will neither have their voices heard or meaningfully influence decisions under this new governance structure. Small rural municipalities—who already operate with limited tax bases—will have little say in how their money is spent across massive regions serving millions of people. This means that local priorities which serve the benefits of rural communities may be overridden by distant decision-makers without the proper context for the decisions. The conditions affecting our members farming near Lake Huron and on the Ausable River are vastly different from those farming on the Thames River.
The centralization of authority could also lead to less accountability to rural municipalities. The current model guarantees funding is used on a local scale. A regional model does not guarantee conservation funding will return back to rural communities, especially as the geography and service requirements of Conservation Authorities expand.
NFU-O Local 312 is also concerned about the financial burdens that municipalities will have to bear for the change to regional Conservation Authorities. Under the proposed changes, municipalities will bear the financial burden of conservation funding without meaningful accountability from their regional Conservation Authority. The proposed scale of the regional Conservation Authorities fundamentally disadvantages rural, agricultural, and upstream communities—precisely the places where proactive conservation delivers the greatest public benefit.
The Government of Ontario has consistently reduced funding to Conservation Authorities since 1996, reducing staff and hampering service delivery to local communities. We are worried that the amalgamations of governance may not provide cost savings, but instead increase administrative costs and create distance between the institutions and the people that they serve. NFU-O Local 312 believes that Conservation Authorities should be locally accountable, and properly funded in order to deliver the best results.

Conservation Authorities provide real value to farms and rural communities
NFU-O Local 312 believes that this proposal takes a narrow definition of value when assessing Conservation Authorities. The proposal to amalgamate Ontario’s Conservation Authorities is focused on creating value by increasing efficiency. For the reasons outlined above, we believe that this goal of increased efficiency may not be met by implementing this proposal.
Watershed-based Conservation Authorities provide economic value to rural communities by protecting them from floods. Millions of dollars in damages are saved annually by protecting developments from floods and by floodplain management. The flash floods that happened in Toronto in July 2024, caused $1 billion in insured losses. Preventative measures informed by local knowledge of floodplains and infrastructure programs are more valuable the combined insured losses and unmeasured damages to cities, townships, and communities.
Water-shed based Conservation Authorities also provide assistance to stewardship projects which assist farmers in building health soils. The Senate of Canada’s report, Critical Ground: Why Soil is Essential to Canada’s Economic, Environmental, Human, and Social Health, argued that Canada should designate soil as a strategic national asset for the measurable and unmeasurable value that soils provide to us. Critical Ground’s recommendations include work that Conservation Authorities are already engaged in, providing soil testing and peer-to-peer learning networks. The report also argued for the incentivizing of ecological goods and services on farms, which include best management practices, such as farm forests, riparian zones, and windbreaks and buffers. Conversation Authorities provide staff, funding, and technical assistance to help farmers and land-owners which choose to implement these practices. Increased soil health is an economic benefit to farmers, reducing input costs and increasing yields.
Best management practices to increase soil health can be costly, but are achievable when farmers are provided with proper funding, labour assistance, and technical knowledge, all of which Conservation Authorities provide or can leverage community partners for. In London-Middlesex, our Conservation Authorities collaborate with Alternative Land Use Services (ALUS) Middlesex to provide funding and leverage local relationships to deliver conservation outcomes efficiently.
The economic value of climate change mitigation, through increased soil health and best management practice implementation is immeasurable. Climate change will increase weather-related risks and crop failure. The Government of Canada’s Drought Monitor classified Southwestern Ontario as “Abnormally dry” for the entirety of the 2025 growing season. Canada is experiencing temperature increases from climate change at twice the global average rate, and we should expect to see greater pressure on water usage which will affect farmers and rural communities. This has economic repercussions, too. Ontario’s Risk Management Program provides $250 million annually to manage risk in the agricultural sector, while $80 million was distributed to Ontario farmers through the Government of Canada’s AgriStability program in 2024., Payments to Ontario farmers through risk management programs will continue to increase as the risks of climate change become more apparent. Investments in climate change mitigation and adaptation are already being made through watershed-based Conservation Authorities. These investments offer a less expensive and more proactive approach to climate change than risk management programs.
Conservation authorities provide critical assistance to farmers, helping them to achieve a triple bottom line: environmental, social, and economic value.
Conclusion
NFU-O Local 312 supports the reasonable, workable alternatives to the proposed amalgamation offered by the Conservation Authority Board. These recommendations include: stopping the regional amalgamations, amalgamating water-sheds within similar regions if necessary, and using existing source protection regions.
Farmers and rural communities in Ontario do not need fewer Conservation Authorities. We need stronger relationships, better funding, and governance that matches ecological realities of our farmers. NFU-O Local 312 urges Ministry of the Environment, Conservation and Parks to halt the proposed amalgamation of the Conservation Authorities, engage in meaningful consultation about the activities of our Conservation Authorities, and strengthen the Conservation Authorities and their crucial service delivery capacity.

All of this respectfully submitted by
National Farmers Union – Ontario Local 312 (London-Middlesex)
December 2025