Although the proposal…

Although the proposal retains watershed boundaries, consolidating multiple watersheds into larger administrative authorities introduces a scale mismatch between governance structures and the spatial scales at which hydrologic, geomorphic, and land–water interaction processes operate. Established watershed management principles emphasize maintaining adequate spatial and managerial resolution to account for heterogeneity, prioritize sensitive and high-risk sub-watersheds, and implement integrated, adaptive, and risk-based decision-making informed by local data and professional judgement. In large and diverse jurisdictions such as Ontario, where urbanization pressures are highly concentrated within specific watersheds, the aggregation of dissimilar watersheds risks shifting management focus toward averaged administrative performance rather than differentiated, risk-informed outcomes. While improving consistency and permitting efficiency is a legitimate objective, restructuring watershed governance primarily to accommodate development timelines may reduce adaptive capacity, weaken system agility, dilute watershed-specific technical expertise, and constrain meaningful stakeholder engagement. Strengthening existing watershed-based governance frameworks would better support science-based, resilient, and accountable environmental and natural hazard management.