ERO# 025-1257 Proposed…

ERO# 025-1257
Proposed Boundaries for the Regional Consolidation of Ontario’s Conservation Authorities
Thank you for the opportunity to comment on the above Environmental Registry posting.
Excluded from consideration of revised conservation authority (CA, CA’s, authorities) boundaries are the subjects of future representation and governance. These have been identified in the posting for further consideration, and reviewers are asked for input on them. I would respectfully submit that such issues are so integral to the eventual success or failure of the proposed new conservation authority geography that they should be considered coincidentally with the boundary changes in order to allow for the creation of a complete and transparent picture of the new CA entities.
Under the present legislation, the consolidation of authorities will result in entities containing vastly more municipalities than the CA’s now existing (TRCA excepted). I have reviewed the list of municipalities that is conveniently contained in the supplementary materials.
The Conservation Authorities Act prescribes the appointment of municipal CA board members in accordance with the population of each. I have not completed even rough calculations of total number of board appointees for each CA but would it not be reasonable to speculate that a new authority, under the current Act, could have in excess of 150 or 200 board members. Boards thus constituted would be far too unwieldly and ultimately unworkable.
It will thus be up to the Province to prescribe a different formula for determining the number and distribution of board members for each new authority, such that board constitution is both practical and effective. At the end of the day, a vast reduction in the overall number of board members, locally and province-wide will be a necessary outcome.
CA’s were founded and have operated on the philosophy of grass roots representation and home-grown program management within legislative boundaries. Every city, town and township presently has one or more representatives on their authority’s board and, among other things, it is this concentrated form of representation that intimately connects CA boards to local resource management needs. CA’s connections to the lower tier of government is a key program driver and is intrinsic to the DNA of every CA.
A massive contraction in board members and the consequent dilution of local representation will result not just in the geographic consolidation of CA’s but, arguably, the creation of entirely new entities that have neither the appearance nor the underlying operating principles of existing CA’s. While those at Queens Park who are managing the change process are fully aware of this dynamic, I sincerely doubt that it has registered with everyone affected. Relatively enormous geographical jurisdiction and sparse, disconnected board representation are organizational attributes that are really anathema to the historic doctrine of Ontario’s conservation authorities. A strong argument could even be made for discarding the term “conservation authority” in favour of something different.
Let us have a more comprehensive look at what is envisioned in the final analysis, rather than laying out the boundaries of new conservation authorities and trying to figure out board representation and governance matters after the fact. In the form of an addition to the list of criteria for consideration of the new boundaries, I recommend that such consideration include, coincidentally, new governance and municipal representation models.
Finally, and as a footnote separate from the above, the ERO seems to assume that a consolidation of the CA’s will result in “improvement”. Yet, at best, only general, speculative arguments are offered in favour of such improvement. For those of us who have been involved in or have been observers of municipal and school board amalgamations, operating efficiencies and financial benefits are nearly impossible to quantify and can ultimately be elusive.

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