I am not supportive of the…

Numéro du REO

025-1257

Identifiant (ID) du commentaire

176634

Commentaire fait au nom

Individual

Statut du commentaire

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Commentaire

I am not supportive of the proposed consolidation of Ontario’s conservation authorities as currently framed. While the government states that this proposal is intended to free up resources for front-line service delivery and better align conservation authorities with provincial priorities, it raises serious concerns about governance, accountability, and environmental protection.

1. Governance — not efficiency — is the central risk

The proposal prioritizes efficiency, consistency, and faster approvals. However, conservation authorities exist to apply precaution and manage risk — not to optimize speed or align primarily with growth objectives.

Science does not make decisions — governance does.

The proposal does not clearly demonstrate how conservation authority independence will be protected when oversight is centralized and decision-making is expected to align more closely with provincial housing and infrastructure priorities. Without explicit safeguards, science risks becoming advisory rather than determinative.

2. Centralization weakens local accountability

Large regional conservation authorities, overseen by a provincial agency, will inevitably distance decision-makers from the communities most affected by flooding, erosion, and watershed degradation.

This scale reduces transparency and public engagement while favouring well-resourced development interests that can navigate larger bureaucracies. Local accountability — a core strength of the current system — is diminished.

3. “Alignment with provincial priorities” undermines the conservation mandate

The stated objective of aligning conservation authorities with provincial priorities is deeply concerning given the government’s recent land-use and environmental record.

Conservation authorities must function as an independent check on development pressure. When faster approvals and predictability are treated as performance goals, risk tolerance shifts and precaution is eroded — particularly dangerous in a climate-change context.

4. Consolidation introduces real transition risk

The proposal understates the risks associated with large-scale consolidation, including:
• loss of institutional knowledge,
• staff turnover,
• inconsistent enforcement,
• and regulatory uncertainty during transition.

At a time of increasing flood and erosion risk, destabilizing the conservation authority system creates unnecessary exposure for communities and ecosystems.

Conclusion

Administrative efficiency alone is not a sufficient justification for restructuring Ontario’s conservation authorities. The proposal does not convincingly demonstrate that independence, precaution, and local accountability will be preserved. As such, I am dissatisfied with the proposal and do not support proceeding without substantial changes and stronger governance protections.