Good day, Below please find…

Good day,

Below please find the submission of comments from the Conservation Halton Board in response to Bill 68 and proposed boundaries for the regional consolidation of Ontario’s Conservation Authorities (ERO #025-1257).

Sincerely,

Adriana Ingrid Birza
Senior Advisor, Office of the President & CEO
2596 Britannia Road, Burlington, ON L7P 0G3
905.336.1158 ext.2295 | cell: 905.805.2947 | abirza@hrca.on.ca

1. What do you see as key factors to support a successful transition and outcome of regional conservation authority consolidation?
Conservation Halton (CH) appreciates the Province of Ontario’s goals of standardization, consistency, and enhanced capacity for Conservation Authorities (CAs). We welcome the Province’s commitment to strengthening relationships and support for CAs. Key factors that would support the successful transition to any proposed model include:
• Phased implementation – Consider phasing the implementation of the standardization and consolidation to areas where support is most needed. Develop a clear and phased implementation plan.
• Quick wins – Prioritize quick wins and changes that will have the greatest impact on achieving the Province’s goals. Leverage expertise and best practices from high-performing CAs to help identify opportunities for quick wins and areas for improvement.
• Expert working groups and advisory groups – Establish working groups with CA staff from key program and service areas to harmonize policies and permit requirements, identify opportunities for regulatory improvements, create standardized procedures and processes, prioritize hazard mapping updates, and integrate data. The Province may also consider an advisory group of key stakeholders to advance the proposal further.
• Local expertise and services – Retain local offices to ensure stakeholders continue to access high-quality services, dedicated staff, and open communication channels.
• Local assets and resources – Ensure CA assets and resources continue to serve local watershed priorities. Existing CA reserves, infrastructure, and land assets, along with aspects of asset management plans, Board-approved reserve policies, and capital investment plans for facilities and infrastructure, must not be lost. Redistributing well-developed reserves to other jurisdictions could dilute CH’s mature asset management program and ability to deliver high-quality services, assets, and resources that the local community values.
• Local accountability and decision-making – Maintain a local governance and decision-making model by enabling the establishment of Local Boards based on watershed boundaries or current CA boundaries. This would ensure that the principles of effective watershed management, which are rooted in bottom-up, community-informed decision-making, are preserved.
• Financial support during the transition – Provide financial support during the transition to minimize financial strain on approved CA budgets and continuation of frontline watershed services.
• Budget processes and revenue streams – Maintain the current municipal budget process and CA budget and apportionment regulation for 2026 (or as long as necessary) to avoid disruptions. Ensure self-generated revenue streams remain uninterrupted.
• Change management and communication – Ensure open communication with CAs, municipalities, and the public, as well as provide change management support to CAs.
• Regional Conservation Authority boundaries – Consider including additional criteria for determining Regional Conservation Authority (RCA) boundaries to ensure RCA Board structure and boundaries best reflect the communities they will represent. Additional considerations such as community characteristics (e.g., rural versus urban), overall RCA size and jurisdiction, growth pressures, and watershed resource issues should inform boundary decisions. Consider reducing the size of RCAs and allow CH to voluntarily consolidate with CAs that have shared boundaries and similar performance and program standards. Alternatively, the Province could consider a) consolidating permitting and planning responsibilities with direct oversight by the Ontario Provincial Conservation Agency (OPCA); b) a consortium of high-performing CAs with shared services; or c) allow CH and our municipal partners to establish a local watershed entity with responsibility for key assets (e.g., land, parks, infrastructure) and select programs and services, as well as to maintain current branding.
• Updated Provincial technical policies and guidelines – Expedite the delivery of regulatory tools to support hazard management programs and services, and to ensure timely and consistent permit reviews (e.g., technical guides to support permitting and flood hazard mapping).
2. What opportunities or benefits may come from a regional conservation authority framework?
Potential opportunities that may come from the consolidation of CAs include:
• Improved resource-sharing and modernization, particularly for CAs with limited capacity or technical expertise.
• Greater consistency in policies, permitting, planning reviews, hazard mapping, programs, and administrative systems. Shared modelling tools, monitoring databases, and mapping platforms will enhance climate-resilient planning.
• Expanded access (where technically feasible and cost-effective) to parks and open spaces for annual pass holders and visitors, improving the overall experience.

3. Do you have suggestions for how governance could be structured at the regional conservation authority level, including suggestions around board size, make-up, and the municipal representative appointment process?
Suggestions related to RCA governance structure include:
• Ensure the criteria for determining RCA Board representation goes beyond population to create a fair structure that reflects the entirety of the RCA. Additional criteria could include land base, community characteristics (e.g., rural versus urban), and/or apportionment contributions.
• Set a maximum number of RCA Board members (e.g., 20-25 members) to ensure the Board is efficient and effective.
• Consider extending the current term of the Board to facilitate a smooth transition.
• Define formal guardrails or governance principles for the OPCA Board to ensure local RCA Board governance and decision-making is maintained. OPCA Board representation should include at least one representative from each RCA.
• Enable the establishment of Local Watershed Boards with meaningful authority. Local Boards could be based on existing CA boundaries and have oversight over select programs or service areas and/or specific geographical areas (e.g., existing drinking water source protection regions).
• Consider RCA-nominated municipal representation on the OPCA Board.
4. Do you have suggestions on how to maintain a transparent and consultative budgeting process across member municipalities within a regional conservation authority?
Suggestions on maintaining a transparent and consultative budgeting process across member municipalities include:
• Maintain Ontario Regulation 402/22 (Budget and Apportionment), which came into effect for the 2024 budget year, to avoid disruptions to municipal budget processes and program funding during and beyond the transition. This will ensure continuity of services and funding for ongoing programs.
• Streamline the budget approval process and mechanisms to reduce administrative burden while maintaining transparency, as it would be cumbersome and inefficient for the new RCAs to undertake the same level of engagement that current CAs do with every participating municipality (e.g., one RCA may have 25-50 municipalities).
• Standardize the budget framework and ensure early engagement with municipalities. Ensure budgeting is transparent, collaborative, and aligned with service-level expectations.
• Preserve CA self-generated revenues and reserves for local priorities, consistent with existing Board policies.
• Consider creating a transition fund administered by the OPCA to support the costs associated with transition and consolidation based on defined criteria and rules. These costs can be extensive, ranging from legal, insurance and risk, contractual, etc.
5. How can regional conservation authorities maintain and strengthen relationships with local communities and stakeholders?
RCAs can maintain relationships with local communities and stakeholders by:
• Retaining local offices to maintain public and stakeholder access to high-quality services, dedicated staff, and open communication channels.
• Leveraging CH’s decades of public trust and name recognition, as well as data and science resources, to build new tools, technologies, and services that would benefit Ontarians (e.g., interactive and predictive hazard and environmental modelling).
• Ensuring continuity of current programs and services (e.g., hazard management, education, parks programming, and events); maintaining high-quality service, communication, and local accountability is essential.
• Engaging consistently with residents, partners, and stakeholders.
• Ensuring open communication with CAs, municipalities, Indigenous partners, and the public, as well as providing change management support to CAs.