Public Comment on ERO 025…

Public Comment on ERO 025-1257: Proposed Consolidation of Conservation Authorities

We appreciate the opportunity to provide feedback on ERO 025-1257. We are deeply concerned about this sweeping proposal to consolidate Ontario’s 36 conservation authorities into 7 regional bodies under the Ontario Provincial Conservation Agency (OPCA). If approved, this proposal risks weakening Ontario’s ability to protect communities and natural infrastructure at a time when climate-related risks are escalating.
We understand that the intended consequence of this proposal is “to improve the conservation authority (CA) system to free up resources for front-line service delivery to help protect communities and better align the work of Conservation Authorities with provincial priorities.”
However, several unintended consequences are also inherent in this proposal. These include:
(1) Reduced local oversight of development proposals;
(2) Loss of watershed-based planning and attention to site-specific environmental impacts;
(3) Increased development pressure, exacerbated by diminished local expertise and authority to enforce safeguards;
(4) Concentration of authority in the OPCA, creating a predictable risk of weakened regulatory protections in light of competing priorities.
As the July 2025 flooding disaster in Texas so vividly – and tragically – demonstrated, all of these conditions – reduced local oversight, development pressure and concentration of power – were present in the tragedy that unfolded. For years, Camp Mystic, where many of the fatalities occurred, actively sought to reduce floodplain restrictions. The owners of the Camp repeatedly appealed to FEMA to remove dozens of its buildings from the official 100-year floodplain maps between 2013 and 2020. These appeals were successful, and FEMA amended its maps to exclude at least 30 structures from the flood hazard designation. Removing buildings from floodplain maps eliminated stricter construction requirements and flood insurance mandates, making it easier for the camp to expand and build new structures without costly safety measures.
Ultimately, there is no single-point failure here – rather, this was a systemic breakdown that included regulatory oversight gaps and policy and enforcement weaknesses. We are afraid that the same conditions for systemic breakdown are inherent in the proposal that we are commenting on now. It does not seem so far-fetched that the OPCA could be Ontario’s stand-in for FEMA.
The most concerning aspect is that this proposal is coming at a time when communities need stronger defenses against flooding, loss of natural infrastructure (eg, woodlands, shorelands, wetlands, etc.) and climate-driven disasters. At a time when a strong and unified response is needed, we are looking at a dangerous erosion of local oversight and preparedness. This proposal will ultimately leave Ontario communities in a worse position than they already are to manage flooding, drought, and other climate-related risks that are growing more severe each year. Ontario alone experienced 19 major flood events in the last two decades, and climate change is expected to increase both their frequency and severity. How can Ontario be prepared for this, when conservation authorities – who hold detailed, localized knowledge about how specific watersheds function – no longer exist?

Following the 2025 Texas flooding disaster, a climate scientist at Texas A&M University said that “careful attribution studies [would] be needed to measure exactly how much his event had been affected by extra energy in the climate system due to increasing carbon in the atmosphere, BUT EVERY WEATHER EVENT WE SEE NOW CARRIES SOME INFLUENCE FROM CLIMATE CHANGE. THE ONLY QUESTION IS, HOW BIG THAT INFLUENCE IS”. (caps added)
If we learn nothing else from that recent major flooding event, it’s that the local knowledge and expertise of our local conservation authorities is essential for planning for, and preventing unsafe development and protecting ecosystems – shorelands, wetlands, forests, and watersheds, which are increasingly showing stress from the accelerating impacts of climate change and the increasing frequency of extreme weather events. Between 2015 and 2020, approximately 4,562 hectares of wetlands disappeared in southern Ontario —primarily due to land conversion for development. Wetlands are vital for flood mitigation and water filtration. Accelerating housing and other commercial and industrial development without strong environmental safeguards will only worsen this trend.
We’re living in a climate emergency, but this proposal (if approved) takes Ontario a step backward, to a time that no longer exists.
Recommendations:
1) Establish a provincial board-governed agency to enable an effective and co-ordinated response by conservation authorities to climate change;
2) Restore the mandate of Ontario’s 36 conservation authorities to oversee development approvals, including ecosystem protection and broader environmental safeguards removed by Bill 23;
3) Provide adequate funding and tools to conservation authorities to help communities manage flooding, drought, fires and other climate-related risks.