On behalf of the Corporation…

On behalf of the Corporation of the County of Brant please see comments enclosed below extracted from RPT-0417-25 (attached) approved by the County of Brant Council on December 16, 2025.

County staff have summarized comments into six sections that align with the discussion questions posed in the ERO posting:

•Regional boundaries and criteria
•Transition strategies for moving to a regional model
•Opportunities and benefits of a regional model
•Governance structure for the proposed consolidated agencies
•Transparent and consultative budgeting processes across member municipalities
•Opportunities to maintain and strengthen relationships with local communities and stakeholders

In response to the consolidation and introduction of the OPCA, the GRCA established a Conservation Authorities Act Regulations Ad-hoc Committee to provide input on proposed changes. County staff have reviewed the feedback compiled by this committee to ensure alignment.

Regional Consolidation and Boundaries
Overall, when considering the proposed regional consolidation, staff compiled the following feedback. These comments reflect input from County staff who work with conservation authorities in various capacities, feedback from members of Council, and insights from local conservation authorities:
•Reduced influence of municipal partners. With more municipal partners under a consolidated model, the influence of individual municipalities could be diluted.
•Balancing the role of different municipalities. Within a consolidated model, feedback from larger municipalities could be prioritized. Should consolidation be pursued, care and attention should be taken to ensure that all municipal partners are represented in the governance model.
•Reflecting the diverse interests of rural versus urban communities. Different municipalities will have different interests when it comes to development, growth, flood management, agriculture, and more. Prioritizing fair and equal representation will be important.
•Preserving local ecological expertise and impact. The proposed boundaries are expansive and encompass diverse ecosystems. Effective watershed management requires localized knowledge, including awareness of historical and local flood events, understanding of how upstream dam/reservoir management impacts downstream municipalities, and expertise on specific local projects (such as technical flood mapping). Consolidation could weaken protections against flooding and erosion, particularly as climate change and extreme weather events demand strong local expertise.
•Impacts on collaborative projects. The GRCA and the County are in the final stages of implementing updated flood zone mapping. This will be a critical tool for warning the community and enabling efficient flood response. This achievement was made possible through the close working relationship with GRCA under the current conservation authority structure. Under a regionalized model, it is important that these collaborative, localized projects continue.
•Uncertainty surrounding the long-term future of non-mandatory programs. MECP has stated that current non-mandatory programs will continue after consolidation (such as Rural Water Quality Capital Grants and the Annual Children’s Water Festival), and existing agreements will be transferred to the regional entity. However, future reviews aimed at streamlining mandatory program delivery could impact these valuable programs.
•Potential decline in service quality and responsiveness. Staff are concerned that during the transition period and under a larger regionalized conservation authority, communication and service delivery may suffer. Notably, County projects requiring permits (such as trail and park projects) and developments could experience delays. Similarly, slower enforcement actions may lead to the degradation of wetlands and watersheds.
•Reduced mapping support. Currently, the GRCA’s GIS department works closely with the County’s GIS team on shared digital platforms. Regionalization could introduce service delays or platform changes, potentially impacting mapping capabilities and emergency preparedness.
•Reduced opportunities for collaboration and consultation. County staff regularly work with conservation authority staff on a range of projects. Restructuring and staffing changes could weaken these relationships and make collaboration more challenging, particularly for technical work such as maintaining and developing municipal drain systems, which require specialized local knowledge.
•Loss of distinct local priorities and strategic focus. While standardized processes may improve efficiency, they risk applying a one-size-fits-all approach that overlooks unique watershed needs. For example, the County of Brant faces elevated flood risk due to the interaction of two major watercourses and existing development patterns. Addressing this requires tailored strategies and local expertise. Under a regionalized model, uniform processes could fail to account for unique circumstances.
•Uncertainty over funding requirements. Currently, the budgetary impact of consolidation is unclear. Additional administrative layers and changes to the funding formula could increase municipal apportionments, despite goals of efficiency.

While a more centralized agency could support greater consistency across the conservation authority framework, this model could compromise the local ecological expertise and programs tailored to distinct community needs over the long-term. To mitigate these concerns, the GRCA encourages the province to explore creating smaller, regional conservation authorities that align with existing Source Water Protection Zones. This approach would strengthen province-wide consistency and capacity while preserving meaningful municipal involvement and ensuring that watershed management continues to be guided by the local priorities, expertise, and partnerships that have long supported effective conservation across Ontario.

Elements to Support Successful Transition
The proposed consolidation of regional conservation authorities will impact the framework which these groups operate under, and how the County collaborates with authorities. To inform a successful transition process, staff encourage the following:
•Develop a clear transition roadmap and communication strategy. The OPCA should establish a structured process and timeline for consolidation that includes responsibilities during transition, milestones, and phasing. Transparent communication and a phased approach will help municipalities and other impacted parties prepare for changes and minimize service disruptions. A comprehensive communication strategy could provide timely and accessible information on the new regional boundaries, updated points of contact, any changes to permitting or operational processes, and how municipal relationships and responsibilities would function throughout the transition period.
•Maintain levels of service throughout the transition. The GRCA and LPRCA deliver non-mandatory programs within the County, including the Rural Water Quality Capital Grant program. Moving forward, the new regional entity should prioritize the same level of service and if the programming and level of service is set to decline, the funding model should be adjusted to reflect this.
•Engage municipalities. Involving local municipalities throughout the design and delivery of the new regional conservation authorities would be beneficial. Ongoing engagement with municipalities and current conservation authorities would support an effective transition.
•Preserve local expertise. Local knowledge is critical for emergency management, development decisions, and community education. Staff recommend maintaining local offices and ensuring personnel with regional expertise continue serving their communities. Specifically, maintaining current knowledge and understanding of local flood infrastructure and river characteristics, as well as historical awareness of flood events, is critical when trying to predict the impacts of approaching flood events and ice jams. Loss of this knowledge could jeopardize community safety and impact critical infrastructure.
•Phase in new standards. When updating permitting processes and other standards, new consistent approaches should be gradually introduced to allow municipalities and other stakeholders adequate time to adjust. Training and information sessions should be used to phase in new procedures and help municipalities, property owners, and developers adjust accordingly.
•Adopt a longer implementation timeline for consolidation. A longer timeline would provide time to assess impacts and ensure desired outcomes are achieved before formalizing changes and regional boundaries.
•Protection of watershed reserves, infrastructure, and land assets. Watershed municipalities and the GRCA are concerned about how their locally funded reserves, land assets, and long-term capital programs will be treated within an amalgamated structure. Strong assurances, such as financial and reserve protection policies, would help ensure that assets built over decades through local investment are not diverted to support unrelated regional priorities.

Opportunities and Benefits of Regional Model
The County recognizes the value of modernizing the current system and supports efforts to enhance consistency, improve permitting, update technical standards, and strengthen coordination across Ontario. Potential benefits of a regional framework include:
•Greater consistency. Consolidating conservation authorities into a regional framework could make it easier to create uniform permitting practices, technical standards, and service levels, which could provide clearer expectations for municipalities, the development sector, and other stakeholders.
•Opportunity to modernize service. Regionalization offers the chance to introduce new tools, such as shared permitting systems and standardized public portals, improving customer service, and accessibility.
•More equitable distribution of resources. Consolidation could lead to a more equitable distribution of resources, giving smaller or rural municipalities access to specialized expertise that may have been limited by local budgets or staffing. Larger organizations are also better positioned to secure federal or provincial funding for broader, high-impact projects.

While these benefits are significant, success will depend on how consolidation is implemented. Oversized authorities could create new challenges, including reduced responsiveness to local issues, slower decision-making, and weakened community relationships. A balanced approach that preserves strong local representation and responsiveness is essential.

Governance Structure
The Ontario government is seeking feedback on the governance model for the new regional conservation authorities. To date, the province has indicated that these authorities will remain independent, municipally governed organizations. Member municipalities will continue to have representation on a board of directors and retain full governance responsibilities. However, with a larger number of municipalities involved, the province acknowledges that not all partners can be represented on the board. A formula will be required to determine board membership.

The Ontario government is seeking feedback to help inform the governance structure of the proposed regional conservation authorities. The County offers the following suggestions:
•Balancing representation and effectiveness. To avoid concentration of influence, no single municipality should be able to dominate board decisions. The new board should be small enough to function effectively, while still representing the diversity of the watershed. The GRCA recommends that the board should have approximately 25-30 members to achieve this balance. Also, shorter board terms could be introduced to promote shared leadership, especially in cases where several municipalities are represented through a single grouped seat.
•Ensure geographic and community diversity is reflected in board make-up. When appointing the board of directors, care should be taken to ensure that the municipal representatives are from various locations throughout the regional boundary. Ensuring a mix of representation from more rural/urban communities and areas across the geographic boundary will help to ensure diverse opinions and insights are reflected. Similarly, it will be important to balance representation from large, medium, and small municipalities.
•Prioritize local involvement. With 81 municipalities, representation will be complex. Sub-committees or local advisory committees could be developed to retain municipal input on local programs and services.
•Maintain transparent communication. The board of directors should prioritize open and honest communication with all member municipalities. For example, meeting minutes should be circulated to all municipalities after board meetings to keep members informed on decisions made, opportunities to provide feedback, new programs, and budget information.
•Adopt consultative decision-making processes. Leverage more consultative decision-making processes and explore opportunities to use tools such as surveys and general meetings where all members have an opportunity to share insights.

Finding a balanced governance approach that ensures fair representation, transparent decision-making, and strong local input will be critical to the success of the proposed regional conservation authority framework.

Transparent and Consultative Budgeting
The County of Brant allocates an agreed upon amount to the two conservation authorities (LPRCA and GRCA) on an annual basis, to deliver programs within the County. In 2025, the total apportionment from the County to the GRCA and LPRCA totaled $417,037 and $174,429 respectively to cover mandatory programs. MOUs are also in place that outline the amount of funding transferred to support non-mandatory programs, including the Rural Water Quality Capital Grants Program and the Brant/Brantford Children’s Water Festival.
Under the new regional model, adopting a fair, transparent and consultative budget process is important. Staff recommend that the province consider the following:
•Maintain or reduce current municipal contributions. The County’s contribution should not exceed current levels and should decrease over time as efficiencies from consolidation are realized.
•Establish clear service and funding agreements. Clear agreements outlining services and funding models should be established between municipalities and the proposed regional authority.
•Adopt a fair and transparent funding formula. A balanced apportionment formula, based on factors such as assessment value, population, and watershed area, is currently in use and could continue under a regional model. A blended approach that considers both population and geographic size would help reflect the different financial capacities of municipal partners. Smaller municipalities receiving fewer services would contribute less, while larger municipalities would transfer proportionally more.
•Accounting for differing revenue generating capacities. As noted above, the GRCA and LPRCA rely primarily on user fees for programs and services, making them less dependent on municipal transfers. Consolidation with authorities that depend more heavily on municipal funding could increase the County’s financial obligations. During budgeting, efforts should be taken to ensure municipal contributions do not exceed current apportionments and that local revenue and fundraising amounts are reinvested locally
•Inclusive annual budgeting processes. All member municipalities should have meaningful involvement in annual budget decisions. Sub-regional or watershed-based consultation meetings could help ensure local priorities and capital needs are considered. Budget documents should be clear, publicly accessible, and shared early enough to align with municipal budget cycles. Offering multiple engagement opportunities, for example, presenting at councils when requested, providing virtual workshop sessions, soliciting written feedback, and conducting one-on-one briefings, ensures that any municipality, regardless of size and location, could participate fairly in the process.
•Provincial funding for OPCA. The OPCA should be funded exclusively by the province. Municipalities should not bear ongoing costs for this agency. As regional authorities become established and standardized processes are implemented, the OPCA’s role and operating budget should decline.

In summary, these recommendations aim to ensure that the regional consolidation process maintains fairness, transparency, and fiscal responsibility while protecting local priorities and investments.

Maintain and Strengthen Relationships with Local Communities and Stakeholders
As noted above, staff across the County collaborate with the conservation authorities to deliver valuable programs and services. To maintain and strengthen relationships throughout the transition, staff recommend the following strategies:
•Prioritize clear communication throughout the consolidation process. Supporting clear communication is crucial between the conservation authorities and municipality to support timely permitting processes and guidance on planning and building activities. If authorities are to be consolidated, and processes are to change, communication will be imperative during this transitionary period.
•Increase consultation. Provide more opportunities for member municipalities to provide feedback and inform decision-making. Illustrate how insights are being used to inform directions.
•Reflect local priorities in new guiding strategic plans. The OPCA is slated to help regional conservation authorities develop strategic plans to advance their work. Member municipalities should be engaged during this important planning to ensure local priorities, such as climate mitigation and adaptation, are reflected.
•Support the continued delivery and development of localized resources and projects. As noted above, preserving close working relationships and preserving localized resources (like flood mapping) are critical to support the safety and well-being of community members. Under a regionalized model, it is important that collaborative, localized projects continue.

Summary and Recommendations
The Ontario government is proposing significant changes to the conservation authority framework. While some updates may promote greater consistency and streamline approvals, the County has concerns about the expansive boundaries of proposed regional authorities, the potential loss of local expertise, and the adoption of a one-size-fits-all approach. This report outlines key considerations and recommendations should regional consolidation proceed, in alignment with guidance provided by the GRCA.

The County supports the GRCA’s recommendation to explore a more balanced regional model that:
•Aligns with science-based watershed boundaries.
•Retains local staff and offices.
•Supports municipal involvement through local advisory committees.
•Ensures transparent and consultative decision-making and budgeting.