I do not fully disagree with…

I do not fully disagree with this proposal, but I believe that it needs to be refined and further developed to address serious shortcomings.

Conservation Authority boundaries were initially established, in large part, to manage flooding and reduce flood risk in populated areas (e.g. by permitting so that homes are not built in floodplains). The current boundaries of the CAs are suitable for this purpose as they follow watershed boundaries, meaning that (in most cases) CAs do not need to coordinate with each other to manage things such as reservoir levels. The new conservation authority map is also suitable for flood management, as the proposed regional CAs are also divided by watershed boundaries.

Over the years, CAs have acquired new responsibilities. One of these is managing shoreline erosion. This has been a challenge for many CAs for several reasons, including:

1) Sand is transported along the shoreline and across CA boundaries as it is moved along the shoreline by alongshore currents. Therefore, efforts to effectively manage sediment budgets and thus coastal erosion must be coordinated across multiple CAs. At present, this is not happening effectively, and many CAs use different standards and hazard mapping methodologies to establish shoreline development setbacks.
2) CAs vary widely in terms of the population within their boundaries. As a result, the resources they are able to dedicate to shoreline management is not commensurate with the length of shoreline that they manage. Some CAs, such as the TRCA, have a team of people dedicated to erosion management, while other smaller CAs may have only one full time staff member who also has other responsibilities.
3) There are not many scientists in Ontario trained in coastal management. The current structure makes it difficult to share these people across CAs, increasing reliance on consultants to produce shoreline management plans.

In my opinion, this proposal would be better for shoreline management than the current system, as the RCAs cover larger sections of shoreline with multiple littoral cells, and would have the resources to hire one or more dedicated staff members to develop, implement, and regularily update shoreline management plans. However, some boundaries should be adjusted to better reflect littoral cells. For example, it may be wise to include part or all of the St. Clair Region conservation authority (e.g. the watersheds that drain into lake huron) in the Huron-Superior RCA. This is only one example and this proposal should be compared to a map of the littoral cell boundaries in the Great Lakes (which itself needs to be updated).

CAs have also become more involved in nutrient management to reduce the amount of phosphorous and nitrogen entering the Great Lakes (especially Lake Erie). While the larger RCAs would also assist with coordinating these efforts more effectively for each lake, a lot of the successes of this program have come at the local scale. Each CA has worked hard to develop relationships with the farmers in their boundaries, which has led to the successful implementation of cover cropping, riparian buffer strips, and other programs to reduce nutrient inputs into the Great Lakes. If this plan for RCAs moves forward, efforts should be made to maintain those local-scale relationships to ensure that this progress continues. Additionally, each CA has developed relationships with its local school boards, and uses these relationships to offer critical educational programming so that youth are connected with nature and aware of environmental issues. These local relationships must also be maintained, perhaps by appointing one outreach person for every 1-3 school boards that fall within an RCA's boundary.

Finally, I find it non-sensical that Lakehead Region Conservation Authority is included in the Huron-Superior RCA. The Thunder Bay region has a completely different shoreline geology and land cover distribution from the rest of the Huron-Superior RCA, and thus a different set of needs and concerns. Additionally, since Thunder Bay is distant from the rest of the Huron-Superior RCA, it is easy to foresee their concerns and needs being ignored by administators in the south. If Lakehead does need to be amalgamated with other CAs, it should be included with the rest of Northeastern Ontario.

Thank you for your time and consideration.