Proposed boundaries for the…

Proposed boundaries for the regional consolidation of Ontario’s Conservation Authorities (ERO#25-1257)

Comment period: November 7- December 22, 2025 through the ERO posting or by email to ca.office@ontario.ca

This response is provided on behalf of the Board of Directors of the Lower Thames Valley Conservation Authority (LTVCA), board members represent 10 member municipalities within the lower Thames valley watershed.

In the Province’s proposal, the LTVCA watershed would be consolidated with seven other Conservation Authorities representing 81 member municipalities to form the Lake Erie Regional Conservation Authority.

ERO Proposal #025-1257 would result in Regional Conservation Authorities that would be incapable of delivering effective programming and be accountable to local municipalities. Although, the LTVCA does support streamlining and standardizing certain areas such as planning and regulations it opposes the plan to consolidate.

If the Province’s continues with the plan to consolidate and proceeds with the ERO Proposal, the following are recommendations to create a plan that keeps local accountability and local programming.

Question 1: What do you see as key factors to support a successful transition and outcome of regional conservation authority consolidation?
• Slowing down of the current rushed process to get it right. It took 80 years to create the present conservation authorities – less than 2 months of meaningful consultation in no way will create a workable result.
• Consultation at the watershed level ahead of legislative action ensuring that user pay input into changes.
• Full and transparent cost-benefit analysis of the proposed consolidation and the anticipated additional costs to municipalities and ratepayers for maintaining an overarching Agency, as well as amalgamation costs.
• Identification of an actual problems and concerns that are attempted to be addressed by the significant modifications being put forward (with specific cases/numbers).
• The proposed timeline for implementation of a yet-to-be-determined regional entity of early 2027 is both unrealistic and unnecessarily hurried. A phased approach spanning a period of three-to-four years, coinciding with municipal election cycles allows for a phased implementation period that would comprehensively address the issues (and potential issues) resulting from amalgamation/consolidation
• A user-interface to a robust and shared permitting system, which is intuitive and facilitates natural hazard assessments, for authority staff and for the commercial/residential development sector, to file applications for clearances and approvals.
• Establishment of smaller sub-region hubs, with a small management team complement to oversee program staff, develop budgets, manage procurement for the sub-region and to secure and manage physical assets.
• Suggest implementing changes through the Ontario Provincial Conservation Agency (OPCA) without changing watershed boundaries for the first 3 year mandate of the OPCA. Determine if provincial concerns can be resolved, and if not, then proceed with amalgamation of CAs.
• Existing Boards should be maintained after October 2026, becoming transition boards of each CA.

Question 2: What opportunities or benefits may come from a regional conservation authority framework?
• Standardized natural hazard mapping products and digital resources to better support local development and flood monitoring as long as provincial funding becomes available as it once was to create this mapping.
• Shared operational technology, resources, best practices, standard operating procedures, policies and protocols.
• The reorganization allows the Province to fully consult with First Nation to develop governance approaches to any new Conservation Authorities that consider First Nations input and their role as rights holders in those watershed organizations.
• Note: All this can be achieved without amalgamation of Conservation Authorities

Question 3: Do you have suggestions for how governance could be structured at the regional conservation authority level, including suggestions around board size, make-up and the municipal representative appointment process?
• An equitable governance model will be very difficult to establish in a regional watershed that is as big as those that are proposed.
• The LTVCA continues to recommend a smaller regional model – perhaps a version of the Source Protection Regions to be able to develop better governance moving forward.
• The existing Conservation Authority model determines representation based on inclusion of each municipality within a watershed area. This is critical and accepted by rate-payers. This model must move forward to ensure a user say for user pay principal is met.
• A significantly enlarged geographical reach does not provide for a manageable number of people or watershed area, if programs are going to be continued to be offered on a local basis. Direct relationships of residents to board members and staff are critical for local program delivery.
• Municipalities will be unwilling to contribute funding significantly distant of their geographical location. The governance model must ensure local funds are spent locally. The largest budget decision making area (for local programs) should be the existing CA boundaries regardless of the future boundaries of the regional CA.
• A two tiered model should be considered. The model where the current boards are still in place and appointed members of the local boards form the regional board would work. The local boards would prepare local budgets to ensure local programming and the regional board would oversee the standardization and provision of services that should be provided on a larger regional basis.

Question 4: Do you have suggestions on how to maintain a transparent and consultative budgeting process across member municipalities within a regional conservation authority?
• Significantly increasing the geographical area, far beyond a single watershed, destroys a transparent and consultative budgeting process across member municipalities unless local budgeting is maintained
• Create local watershed sub-regions of the regional authority, to facilitate accountability, transparency and consultative budgeting. The sub-regions, through the sub-regional Boards would be responsible for generating their sub-regional budgets and consulting with their respective municipalities. While ERPs (Enterprise Resource Planning), financial statements/report, and audit function can be centralized to the regions. There are certain aspects of financial planning and management that should remain decentralized and assigned to the sub-regions, such as budgeting for local capital project undertakings, as local staff have superior knowledge of the needs of the sub-region, as opposed to staff at a head office.
• Regional responsibilities in a two tiered structure would have to be budgeted regionally but reviewed locally to maintain a transparent and consultative budgeting process.

Question 5: How can regional conservation authorities maintain and strengthen relationships with local communities and stakeholders?
• Local service delivery creates relationships. The ability to connect with technical staff in-person and particularly during storm/flood events, is especially impactful for both residents and municipal partners. Maintaining a local presence with local expertise, providing local service is the single most effective way to ensure that relationships with community and stakeholders are maintained.
• Significant funds are raised locally for various projects. This includes the donation of lands by families for the enjoyment of their communities. Assurances that these funds and lands will be utilized for their intended purposes and meet donor expectations is especially key given the current funding model.