As the Chief Administrative…

As the Chief Administrative Officer, the comments contained herein are being submitted at the direction of the Council of the Municipality of Lambton Shores.

The Municipality of Lambton Shores strongly opposes the proposal to amalgamate thirty-six (36) Conservation Authorities (CAs) into seven (7) Regional Conservation Authorities (RCAs), based on the comments contained herein.

Lambton Shores currently covers two (2) major watersheds; as such, Lambton Shores is represented by both the Ausable Bayfield Conservation Authority (ABCA) and the St. Clair Region Conservation Authority (SCRCA). Under the proposed amalgamation, Lambton Shores would be represented by both the Huron-Superior RCA and the Lake Erie RCA.

The Huron-Superior RCA would consolidate seven (7) CAs and represent seventy-seven (77) municipalities (including the City of Thunder Bay).

The Lake Erie RCA would encompass eight (8) CAs and represent eighty-one (81) municipalities.

The Municipality opposes the current CA amalgamation plan based on the following concerns:

Local Representation:

The information distributed by the MECP indicates that the local governance model will not change and that member municipalities will continue to be represented on the boards of the RCAs. Based on the number of municipalities represented in each RCA, this would seem impossible, or at the very least unmanageable. The RCAs that Lambton Shores would be part of include 77 and 81 municipalities, respectively. Boards of this size are inconceivable and, frankly, not feasible, which would ultimately lead to the loss of local representation.

The MECP also indicated that the sources of funding for the RCAs, which include a significant portion from municipal levies, would not change. As a result, local representation is critical and expected. That is to say, if local municipalities are still paying the levy, they will expect direct representation.

Timing of the Proposal:

Our understanding is that the timing of the proposed change would coincide with the next municipal election in 2026. It is also our understanding that local boards would cease to exist in their current form after the election is complete. Lambton Shores fails to see how it would be possible to complete the amalgamation within that timeframe. If the proposal does proceed on this schedule, we expect that errors will occur and details will be missed, all to the detriment of the local municipalities that, as noted above, are paying for the service.

We were also very surprised to learn that the Province has not engaged with the Chief Administrative Officers and General Managers of the current CAs in any meaningful way, other than to inform them of the proposed change prior to informing the public. These are the professionals who should be consulted and relied upon to move the proposal forward. Without their input, we feel the amalgamation is doomed to fail.

Loss of Local Expertise:

The current proposal would result in massive RCAs that cover large and varied watersheds. Our concern is that local knowledge would be eroded over time and eventually lost. The dynamic beach areas along the shores of Lake Huron are vastly different from the shores of Lake Simcoe. Hazards, ecosystems, and flood control systems vary significantly across watersheds. We expect that the RCA system would result in the eventual loss of the expertise that is currently held within the existing CA system. It is unclear how this would better serve the municipalities that are paying for these services.

Permitting and Regulatory Administration:

One of the main reasons cited for the proposed amalgamation is the perceived delays experienced by builders, landowners, and farmers seeking permits. If this is indeed an issue, the Province is fully capable of passing regulations to establish timelines, fees, and other requirements applicable to each CA. The Province should also be reminded that many of the regulations in which CAs are involved were put in place by the Province itself. If the Province has concerns with these regulations, it can amend them directly.

If the Province wishes to standardize aspects of permitting and regulatory work across CAs, it has the ability to do so without undertaking a complex amalgamation process. We remain skeptical that a larger, geographically dispersed entity would be better positioned to address permitting matters and stakeholder inquiries. We have not witnessed this outcome with other large organizations.

Conclusion:

For the reasons outlined above, the Municipality of Lambton Shores strongly urges the Province to reconsider the proposed amalgamation of Conservation Authorities. The current model provides essential local representation, watershed-specific expertise, and responsive regulatory services that would be significantly undermined by the creation of large, regionalized authorities. The scale and timing of the proposal, combined with the lack of meaningful consultation with municipalities and conservation professionals, create unacceptable risks for governance, service delivery, and environmental stewardship. Lambton Shores respectfully requests that the Province pause this initiative and engage in a more thorough, collaborative review with municipalities and existing Conservation Authorities to address identified concerns through targeted, evidence-based reforms rather than wholesale restructuring.