I oppose ERO 025-1257…

I oppose ERO 025-1257 because the proposal to consolidate Ontario’s 36 conservation authorities into seven regional bodies—under a new provincial agency—does not present a transparent problem definition, baseline performance data, or a cost-benefit and risk analysis commensurate with the scale of change. The registry notice characterizes the current system as “fragmented” with inconsistent turnaround times, but it offers no queue metrics, staffing analyses, service-level targets, or modeling to substantiate that amalgamation is the least-risk path to improved outcomes. In the absence of evidence, a multi-year structural reorganization is more likely to divert attention and resources from core public-safety programs such as flood forecasting/warning, hazard-land regulation, permitting, and source-water protection.

Consolidation at the scale proposed would also dilute local watershed knowledge and slow responsiveness. Conservation authorities were designed on watershed boundaries precisely to capture local hydrology, groundwater regimes, shore processes, legacy infrastructure, and municipal relationships. While the posting lists “service continuity” as a criterion, it provides no operational plan, triggers, or resourcing guarantees to prevent degradation during transition (policy harmonization, fees, SOPs, IT/data integration). Without detailed governance design for the new provincial agency and the regional boards—composition, appointments, municipal and Indigenous representation, budgeting, dispute resolution—municipalities and rightsholders cannot assess accountability or fiscal risk.

The supplemental material maps proposed regions and lists participating municipalities and current CAs but does not address how source-protection program nuances, cumulative-effects management, or varied local vulnerability scores will be integrated across much larger jurisdictions. Stating that programs “will not change” is not a substitute for a transition critical path, service-level guarantees, staffing plans, and funded implementation. The same gap applies to Crown consultation: there is no clear plan for Indigenous engagement, accommodation, or the embedding of Indigenous knowledge within the proposed structures.
Less disruptive alternatives exist and should be evaluated publicly before proceeding: province-wide service standards for permitting and flood programs; shared-services clusters (IT, legal, HR); inter-CA MOUs for surge capacity; a common provincial permitting/data platform; and targeted capacity funding where specific bottlenecks exist. These options would address consistency and timeliness while retaining locally accountable watershed governance. Given the missing analysis and transition detail, I request that MECP withdraw or pause ERO 025-1257 and publish: (i) a problem statement with baseline performance by CA; (ii) an options analysis including non-structural alternatives; (iii) a full governance model and transition plan with funding; (iv) a municipal/Indigenous engagement plan and impact assessment; and (v) explicit service-level guarantees for permitting, flood programs, and source-water protection before introducing legislative changes. If the ministry proceeds, the consultation period should be extended and the supplemental package expanded with CA-by-CA operational implications so that municipalities, Indigenous communities, and stakeholders can provide informed comment
In summary, the current record does not demonstrate that amalgamation will maintain—let alone improve—public safety, watershed health, or service timeliness. Ontario can achieve consistency and efficiency through standards, shared services, and targeted supports without dismantling the watershed-based model that underpins local accountability. I urge the ministry to withdraw or materially revise the proposal in line with the requests above