To whom it may concern, It…

To whom it may concern,

It is our understanding that the consolidation of Ontario’s 36 conservation authorities into 7 regional CAs has been brought forward in an effort to operate with greater consistency and streamline the permit process.

As the President of RC Spencer Associates Inc., my engineering firm has been operating in Southwestern Ontario for over 35 years, with hundreds of projects requiring conservation authority approval, primarily in the Essex Region Conservation Authority (ERCA) region. Through my experience, I can substantiate that the input and local expertise of the conservation authority staff have been invaluable in advancing projects through the design and approval stage, with consideration to protect property owners from the dangers of flooding and erosion.

I am very concerned that through the consolidation into regional conservation authorities, the focus will shift toward broad review standards without adequate consideration to our specific local watershed characteristics. The local CA staff have decades of site-specific historical knowledge which they can use to provide informed direction and guidance to ensure that flood risks are mitigated in the most appropriate manner. A shift toward generalized regional standards and review practices will take away from the quality input that we have come to appreciate from our local conservation authorities.

Another significant concern that will inevitably result from the regional approach will be the loss of efficient communication. Through decades of experience with our local conservation authorities, we have built a working relationship where open communication has become normal practice. The approach of larger regional CA offices will result in a disconnect from the local issues and create new layers of administrative burden in assigning projects for review.

In recent years we have observed the benefits of the CLI-ECA review process introduced in 2023. This framework shifted away from regional ECA review process and transferred the approval authority for municipal sewage and stormwater systems to the local municipalities. This change has resulted in significant improvements to review timelines and approvals.

We feel that the “Proposed Boundaries for the Regional Consolidation of Ontario’s Conservation Authorities” is moving in the opposite direction. It appears to be shifting the focus away from the local review agencies, that have direct accountability to local municipalities, creating a generalized regional approach which will result in a disconnect from local concerns.

Therefore, it is our recommendation that the permit review and approval process needs to prioritize and acknowledge the value of local review staff with specialized local watershed knowledge. There is a notable advantage to maintaining the current model of local staff presence, which creates a natural accountability in the success of the projects as well as the protection to the property owners from flood risk.

Yours Truly,
RC Spencer Associates Inc.

Richard C. Spencer, M.A.Sc., P.Eng.
Consulting Engineer
President