I have reviewed the Province…

I have reviewed the Province of Ontario’s proposal to amend the Conservation Authorities Act and consolidate Ontario’s 36 Conservation Authorities into seven regional bodies overseen by a new provincial agency (ERO Posting #025-1257) and am opposed to the proposed consolidation. My local Conservation Authority would become part of the Eastern Lake Ontario Regional Conservation Authority (ELORCA), which will include 48 municipalities across the proposed region and cover 16,000 km2. As a result, it will be extremely difficult for the small rural communities to retain the same kind of watershed services and representation that they deserve.

Valid concerns have been raised about the limited information provided to support the provincial proposal. Local municipalities received minimal advance notice, no cost-benefit analysis or transition plan has been released, and the proposal offers no clarity on how land transfers, municipal service agreements, risk management offices, or emergency response roles would function. Conservation Authorities are willing to work with the Province to accomplish some of their goals, such as a shared permit application across the Conservation Authorities, but this can be accomplished without the amalgamation.

The new proposal will result in a longer turn around time for permitting due to a much larger geographic area and potentially allowing development in unsafe locations because of the inevitable loss of local knowledge. The Province already has the authority to establish overarching legislation, regulations and standards through the Conservation Authorities Act and the Ministry of Environment, Conservation and Parks to address concerns related to permitting, by establishing guidance, online permitting platforms and technical standards through legislation that could help build homes without a forced amalgamation.

If the government truly wanted to protect the environment and people and property from natural hazards, such as flooding, and accomplish their goals of building more homes, they should restore the funding that was cut in 2018 to allow each of the individual 36 Conservation Authorities to access the information and technology they require and hire the staff to complete the work which will result in faster turn around times. As the proposal stands there will be increased costs and delays.

With regards to the discussion questions identified on the ERO posting:

Key factors to support a successful transition and outcome of regional consolidation?
I am concerned about the limited information provided in support of the Province’s proposed consolidation of conservation authorities. Local municipalities received minimal advance notice, and to date no cost-benefit analysis, implementation framework, or transition plan has been released. In addition, the proposal provides little clarity regarding how land transfers, municipal service agreements, risk management offices, or emergency response roles would function under a regional authority model.

Moving forward, conservation authorities and stakeholders must be informed of decisions as they arise and be provided with meaningful opportunities to address concerns and communicate with municipal partners and stakeholders. The process to date has lacked transparent communication between the Province and conservation authorities. Furthermore, the sole proposal available for comment was open for only 45 days, which is insufficient time to coordinate a thorough response and engage meaningfully with stakeholders.

Additionally, keep local offices and local experts in their watersheds. As it stands the current local employees have local expertise, and relationships with local partners. Each watershed is geographically and demographically unique and has individualized programs and services. For example, some Conservation Authorities complete dam operations and are on call. The Conservation Authorities perform flood forecasting and warning duties including operating various dams throughout the watershed to reduce the potential impacts of flooding and require timely attention. These operations are vital to community safety and must be completed in a timely manner. Restructuring of how these operations are conducted and/or where employees are located could result in decreased efficiency in delivering these services and lead to risks to people and property.

Smaller conservation authorities also benefit from deep local knowledge of their communities, ecosystems, and flood risks. For example, Conservation Authority staff are familiar with the lakes and waterways in their watershed because they visit them regularly and typically live within the region. There is concern that this localized knowledge may be deprioritized or lost within a large, centralized bureaucratic structure, particularly where smaller populations may be perceived as less significant.

There is no evidence that Conservation Authorities are a barrier to housing approvals. Where Conservation Authorities advise caution or restrict development, it is typically because a location is unsafe or at risk from flooding, erosion, or other natural hazards. These are measures that protect public safety and prevent property damage, infrastructure loss, and other expensive consequences. Weakening this oversight does not support responsible or economically sound housing development.

What opportunities or benefits may come from a regional conservation authority framework?
A benefit would be sharing technical services, however, amalgamation is not necessary to accomplish this and many Conservation Authorities are already doing this. Conservation Authorities already participate in service sharing initiatives with neighbouring conservation authorities, which deliver many of the efficiencies the Province seeks. There is concern that amalgamation may introduce additional administrative layers that could negatively affect timelines rather than improve them.

There is no evidence that the proposed amalgamation will result in faster turn around times for permit approvals. As of now greater than 95% of the permits issued by the Conservation Authorities meet the timelines that the provincial government has laid out.

Governance structure at the regional level
The amalgamation will not result in an effective governance model. The new boards will span multiple watersheds, expansive geographic areas, each with their own unique geography and watershed concerns. The new larger regional boards will inevitably dilute local accountability and expertise. Small rural municipalities will lose their voices to the larger urban areas. In order to be effective, all municipalities must have an equal opportunity to participate meaningfully in decision-making, and the Conservation Authority Boards will need to maintain municipal representation, as well as have sub-watershed advisory committees that allow the local voices and expertise to be heard and valued.

How to maintain a transparent and consultative budgeting process across member municipalities?
Transparency will be much more difficult under the current proposal due to the number of municipalities funding such a large area. Historically, the Province funded up to 50% of Conservation Authority operations; today, provincial support has fallen to less than 10% on average forcing local Municipalities to fund the majority of watershed services provided by Conservation Authorities. The proposed restructuring would shift governance away from the Municipalities who fund and support Conservation Authorities, resulting in a significant loss of local decision-making, community accountability, and rural representation.

A comprehensive cost-benefit analysis must be completed and shared publicly. To date, municipalities have received minimal information regarding financial impacts, transition costs, land transfers, municipal service agreements, risk management offices, or emergency response responsibilities.

There is also concern that conservation authorities will be required to financially support the new regional structure through increased fees and levies. For example, proposed efficiencies such as standardized permitting platforms may ultimately be funded by conservation authorities themselves, potentially requiring authorities to pay the Province for system access. These costs would likely be passed on to applicants through higher permit fees and could divert funding away from other essential services.
Given the lack of transparency and financial detail, it is extremely difficult to meaningfully respond to questions regarding budgeting processes.

How can regional conservation authorities maintain and strengthen relationships with local communities and stakeholders?
By keeping local offices open. If property owners and contractors cannot get a hold of a local office, they will have to contact the regional office which will result in lost time and will result in longer turn around times getting homes built. Regional offices will not have the same response times as local offices and local experts.

Anecdotally, a lot of rural populations and urban populations don’t always see eye to eye. There is often a difference in core beliefs and values. The rural members of small rural watersheds have little reason to trust that urban populations - who will all be incorporated into the new Regional Conservation Authorities - will have their interests in mind. If local offices were closed, and relocated to city centres, there could be a general distrust of the authority from rural populations.

Final Thoughts and Additional Comments
Proposed Regional Conservation Authorities Are Too Large
- The proposed regional boundaries are excessively large and risk reducing the effectiveness of Conservation Authorities. Oversized jurisdictions will stretch staff capacity, limiting the ability to conduct site inspections, investigate violations, adjust dams during flood events, and engage meaningfully with the public. Non-mandatory but highly valued public education and outreach programs are also at risk.

Slow the Process and Evaluate Actual Benefits
- It remains unclear how consolidation will meaningfully accelerate housing construction. Conservation authorities do not control labour availability, material costs, tariffs, or market conditions—factors that frontline staff consistently hear are the primary reasons for construction delays.
- Conservation authorities already demonstrate high compliance with provincial permitting timelines. There is concern that amalgamation may slow approvals due to increased bureaucracy and greater physical distance from development sites, limiting the ability to conduct timely and accurate site visits.
- There should reconsideration for more than 7 Conservation Authorities, and that the new Authorities should be based on geography – similar geographic areas, similar topography, similar land uses, similar demographics, areas that share extensive watershed boundaries.

Impacts on Non-Mandatory Programs
- The future of non-mandatory programs remains uncertain. While the Province has indicated there will be no job losses, it has also suggested staff redeployment to focus on mandatory functions such as flood forecasting and permitting. Will the non-mandatory program staff be redeployed to achieve faster permitting timelines? There has been no transparency regarding the fate of non-mandatory programs or the staff who deliver them.
- These programs are often the primary point of contact between conservation authorities and the public, playing a critical role in education, stewardship, and community engagement.

Job Loss Is Inevitable at This Scale
- Despite assurances to the contrary, consolidation on this scale will inevitably result in job losses. Senior management and administrative staff have earned their positions through experience and expertise. “Redeployment” often amounts to demotion or displacement, and attrition-based reductions still constitute job loss.
- Recent health unit amalgamations in the Kingston/Belleville area provide a cautionary example. Despite assurances that no jobs would be lost, seven offices are now being closed and sold just two years later.

The Province must recognize that consolidation at this scale and speed risks harming both service delivery and employees. Consideration should be given to alternative models that result in smaller, more manageable regional conservation authorities.