I am writing to provide…

I am writing to provide comments on the proposed regional consolidation of Ontario’s conservation authorities.

I strongly support the role of conservation authorities in protecting people, property, and watershed health through science-based, watershed-scale management. However, I have serious concerns that the proposed consolidation into seven large regional conservation authorities will add an additional layer of bureaucracy, consume scarce public resources, and weaken local accountability, while providing little evidence that it will improve service delivery or environmental outcomes.

Watersheds function at a local scale. Flood risk, erosion processes, groundwater systems, aquatic habitat, and land use pressures vary significantly within and between watersheds. Existing conservation authorities have developed deep, place-based knowledge, long-term datasets, and trusted relationships with municipalities, landowners, Indigenous communities, and local partners. These relationships and datasets are critical to effective flood forecasting, permitting decisions, drinking water source protection, and ecological restoration. Consolidation at the scale proposed risks diluting this local expertise and weakening accountability to the communities most affected by watershed decisions.

A fundamental concern with this proposal is the lack of publicly available evidence demonstrating that consolidation at this scale will achieve the stated objectives. The province has not released a cost–benefit analysis, transition cost estimate, or comparative assessment of alternative approaches such as shared services, provincial standards, or targeted investments. Without this information, it is not possible for the public or municipalities to evaluate whether consolidation is necessary, proportionate, or in the public interest.

The proposal also appears to represent a top-down, non-collaborative approach to decision-making. Conservation authorities, municipalities, staff, Indigenous communities, and watershed stakeholders appear to have had little meaningful involvement in shaping the direction of this proposal prior to its release. Structural decisions of this magnitude should be co-developed with those responsible for delivering services and accountable to local communities. Proceeding without early consultation undermines public trust and democratic accountability.

Rather than reducing duplication, the creation of a new provincial conservation agency and large regional authorities risks adding another layer of bureaucracy between local watersheds and provincial decision-makers. Additional governance structures, reporting requirements, and oversight bodies may slow decision-making, increase administrative burden, and distance conservation authorities from the communities they serve. This is particularly concerning for time-sensitive functions such as flood response, permitting, and emergency management.

Compounding this concern is the absence of adequate provincial funding to support the proposed changes. Conservation authorities already operate with limited resources, and provincial funding typically represents a very small portion of operating budgets, while municipalities and other partners bear the majority of costs. Introducing new governance requirements, reporting obligations, and transition activities without commensurate funding effectively downloads costs onto municipalities and local ratepayers.

Significant staff time and financial resources will be diverted away from front-line work to support consolidation-related activities, including governance restructuring, legal reviews, labour relations, asset transfers, policy harmonization, information technology integration, branding and rebranding, and ongoing reporting to a new provincial agency. These activities do not improve flood protection, water quality, or habitat on the ground, yet they will demand substantial effort during a period of increasing climate-driven risk.

There is also a real risk of service disruption during and after consolidation. Loss of institutional knowledge, staff turnover, and administrative uncertainty can directly affect flood forecasting, permitting timelines, and public safety. These risks are not acknowledged or addressed in the proposal.

Of particular concern is how consolidation and cost pressures may affect programs that the public strongly supports, including Species at Risk (SAR) recovery and stewardship initiatives. Local conservation authorities play a critical role in delivering SAR programs through on-the-ground monitoring, habitat restoration, landowner engagement, and public education. This includes stewardship programs for highly visible and valued species such as the Spiny Softshell Turtle. Without clearly protected, dedicated funding, there is a real risk that these programs will be deprioritized within large regional budgets.

The proposed Lake Erie Regional Conservation Authority would encompass extremely diverse watersheds with very different hydrologic, ecological, agricultural, and urban characteristics. Managing such a large and complex region under a single authority raises serious concerns about equitable resource allocation, loss of local prioritization, and reduced responsiveness to watershed-specific risks.

If consolidation proceeds despite these concerns, several safeguards are essential:

Local watershed offices must retain meaningful decision-making authority.

Dedicated, stable funding must be secured for local monitoring, restoration, and Species at Risk programs, including turtle stewardship.

Long-term datasets must be protected and remain comparable over time.

Governance structures must ensure strong municipal representation tied to watersheds, not population size alone.

Budgeting processes must be transparent and clearly demonstrate how municipal contributions are used within each watershed.

All transition costs, risks, and timelines must be publicly disclosed and justified.

Conservation authorities are most effective when they are locally grounded, scientifically robust, and democratically accountable to the communities they serve. Any reform should be evidence-based, adequately funded, and developed through genuine consultation, rather than imposed through top-down restructuring that adds bureaucracy and downloads costs.

I urge the province to pause this proposal, release supporting analysis, and engage in meaningful, collaborative consultation before advancing legislative or structural changes.

Thank you for the opportunity to comment.