Thank you for the…

Thank you for the opportunity to comment on the proposed amalgamation of Ontario’s Conservation Authorities. I wish to make clear the depth of and reasoning behind my fierce opposition to such a poorly considered strategy likely to create so many enormous problems for little to no benefit in exchange. This appears to be nothing less than a direct attempt to hobble the conservation authorities as a prelude to eliminating them from the Ontario landscape, using reduced effectiveness directly caused by this plan as cause.

In this plan, I see the potential for only one small benefit, which may not even come to pass, balanced against a legion of problems and negative impacts. This singular benefit would be the potential for easier knowledge sharing between employees of what are currently separate organizations. The stated goals of the amalgamation plan: standardization of procedures, updating processes, and so forth would not qualify in my eyes, as all of them could be implemented without amalgamating effective local organizations into unwieldly conglomerates covering thousands of square kilometres each. I would be inclined to join the conservation authorities in their support for standardization and improvement of processes, procedures, and tools, but amalgamation would be the most complex, most difficult, and least cost-effective way to pursue those goals.

The problems with this proposed amalgamation mostly revolve around loss of local services and relationships, funding concerns, and the role of the new provincial conservation agency in directing the new regional conservation authorities. The need for local-level organizations is obvious, as it could take regional conservation authority staff hours to reach a work site if they were required to start from a regional headquarters every day. Adding to this the specialized local knowledge and relationships that conservation authority staff have developed, which would be diminished or lost in a regional framework, makes the flaws clear. Decisions and programming cannot be made from a major city and delivered across such a vast area, with so much variation. Given that Conservative politicians have traditionally been the loudest voices for small, local governance, the need to explain this concept to a Conservative government is perplexing. Funding and representation of small, rural communities are also cause for concern under this amalgamation plan. A small amount of residents’ municipal taxes are paid to the conservation authorities to fund the services they provide, but under a regional framework, there is a distinct possibility that these funds would be put to use not for local program delivery, but in more densely populated cities, providing less benefit to the taxpayer providing the funds. As well as having their taxes funding programs they can’t benefit from, rural residents would also see a reduction in representation on the boards of conservation authorities, as a regional conservation authority could not possibly have a board with enough seats to include representatives of every township that falls in their enormous areas of operations. The net effect would be a loss of services and ability to be heard in decision making compared to the current watershed model. This is before considering the increased costs that would be incurred in restructuring and rebranding the conservation authorities into a regional framework, which would also need to be borne by residents. Donors would face uncertainty as well as taxpayers, since their land and financial donations would be administered from farther away, reducing certainty that they would be used in the manner agreed to with local conservation authorities. Finally, the need for the OPCA is not clear, especially with so little known about its intended function. It seems that the OPCA would duplicate the role already filled by Conservation Ontario, but instead of being staffed by subject-matter experts, it would be filled with political appointees of unknown background, and funded by the regional conservation authorities, which puts the financial burden on municipal taxpayers. The only role the OPCA seems to serve is to give the provincial government more influence, while maintaining or shrinking their role as a minority funder of the system they would have greater power to direct.

Given all of the above, I strongly urge the province to reconsider, or better, abandon the plan to amalgamate Ontario’s 36 conservation authorities. These are specialized, effective organizations that can only be harmed by cutting them down to seven and asking them to work across areas as large as the watersheds of Great Lakes, which will in turn create worsening outcomes for the people of Ontario.