I am writing to express my…

Numéro du REO

025-1257

Identifiant (ID) du commentaire

173695

Commentaire fait au nom

Individual

Statut du commentaire

Commentaire approuvé More about comment statuses

Commentaire

I am writing to express my strong opposition to the Province’s proposal to amalgamate Ontario’s 36 Conservation Authorities (CAs) into seven large Regional Conservation Authorities. While greater coordination and communication across CAs is valuable, this restructuring goes far beyond improving collaboration. It appears designed primarily to streamline development pressures rather than strengthen watershed protection, ecological resilience, or local decision-making.

Under the proposed structure, the new Lake Erie Regional Conservation Authority would cover more than 23,000 square kilometres, amalgamating eight CAs: Grand River, St. Clair Region, Upper Thames River, Lower Thames Valley, Long Point Region, Essex Region, Kettle Creek, and Catfish Creek. Each of these CAs currently reflects distinct watershed boundaries, local ecological conditions, and community needs. Combining them into a single administrative body will undermine the core principle on which CAs were created: that watershed management must occur at a local scale, informed by local knowledge.

One of the most troubling aspects of the proposal is the loss of local governance and representation. Today, boards are composed of member municipalities within each watershed. For example, the St. Clair Region Conservation Authority includes representatives from 17 municipalities, ensuring that decisions reflect local priorities. Under the new model, the Lake Erie Regional CA would represent 81 municipalities but have only 10–15 board members. This would severely diminish local accountability and erode the ability of smaller or rural communities to participate in decision-making about flood management, permitting, species at risk, and land-use planning.

The amalgamation would also generate substantial transition costs. Integrating staff, harmonizing policies, restructuring governance, merging IT systems, and aligning data standards will require major financial and administrative resources. These efforts will pull staff away from front-line responsibilities such as flood forecasting, invasive species management, ecological monitoring, and community outreach. There is no evidence that these costs have been fully assessed, nor that they will result in long-term savings.

Ecologically, the proposal is deeply flawed. The eight watersheds slated for amalgamation vary widely in hydrology, land use, geology, and Species at Risk (SAR) distributions. Effective recovery efforts for SAR require targeted, watershed-specific actions, partnerships, and funding streams. Diluting resources across such a large, ecologically diverse region risks deprioritizing smaller watersheds—many of which contain some of Ontario’s most imperilled species. Conservation outcomes depend on local expertise, which cannot be replaced by a large, centralized regional authority.

Finally, the timeline is unrealistic. Completing all governance, operational, and regulatory changes by January 2027 is not compatible with the scale of the proposed overhaul. Such a rushed transition risks operational failures, disruption to flood emergency services, and the loss of experienced staff.

Ontario’s Conservation Authorities are internationally recognized for their watershed-based governance model. They play a critical role in protecting the province’s natural resources, supporting climate resilience, and safeguarding communities. Rather than dismantling local authorities, the Province should pursue solutions that enhance collaboration—such as shared digital tools, joint technical working groups, and standardized guidance—while preserving local oversight.

For these reasons, I strongly urge the Province to withdraw the proposed CA amalgamation and work with municipalities, CAs, and conservation professionals to develop improvements that respect watershed boundaries, maintain local governance, and support effective environmental stewardship across Ontario.