I am submitting this comment…

I am submitting this comment to express strong opposition, deep concern, and a profound lack of trust in the Ontario government’s proposal to consolidate conservation authorities and restructure their governance and boundaries. This proposal is not a neutral administrative reform. It is the continuation of a pattern of environmental governance in Ontario that prioritizes short-term political and development interests over long-term ecological integrity, public safety, and intergenerational responsibility.

Conservation authorities exist to protect people, property, and ecosystems through watershed-based management. They were intentionally designed to be locally accountable, science-driven, and insulated from political pressure to approve unsafe or ecologically damaging development. This proposal undermines those principles at a time when Ontario is already failing to meet its basic responsibilities related to climate adaptation, flood risk reduction, and environmental oversight (Auditor General of Ontario, 2022; Auditor General of Ontario, 2023a).

Given the province’s recent and well-documented record of disregarding evidence, weakening environmental safeguards, and interfering in land use planning, there is no reasonable basis to believe that expanding provincial control over conservation authorities would serve the public interest.

1. Watershed-based governance is foundational, not optional

Ontario’s conservation authority system was established under the Conservation Authorities Act precisely because watersheds are the correct ecological and risk management unit for flood control, erosion mitigation, wetland protection, and water resource management. This is not a matter of administrative preference. It is a core principle of environmental science and disaster risk reduction.

Extensive research demonstrates that when governance systems do not align with ecological systems, outcomes worsen, risks increase, and accountability erodes (Folke et al., 2007; Ostrom, 2010). Watershed governance requires proximity, local knowledge, and the ability to respond to site-specific hydrological and ecological conditions. Consolidating authorities into large regional bodies while introducing centralized provincial oversight weakens this alignment, regardless of how boundaries are described on paper.

The claim that watershed integrity will be preserved while governance is centralized ignores decades of evidence showing that institutional scale, decision distance, and accountability structures fundamentally shape outcomes (Cosens et al., 2017). Watershed governance cannot be preserved in practice while being hollowed out institutionally.

2. Ontario’s climate reality makes this proposal reckless

Ontario is already experiencing more frequent and severe flooding, erosion, shoreline instability, and extreme rainfall events due to climate change. These impacts are highly localized and cumulative. They require strong local monitoring, adaptive management, and independent regulatory authority.

The Intergovernmental Panel on Climate Change has made it clear that effective climate adaptation depends on governance capacity, decentralization, and institutions that match the scale of risk (IPCC, 2022). Weak governance increases vulnerability even in regions with significant natural resources.

Ontario’s own Auditor General has repeatedly found that the province is not adequately prepared for flooding and has not sufficiently integrated natural infrastructure such as wetlands and floodplains into flood risk reduction strategies (Auditor General of Ontario, 2022). The same reports note fragmented responsibilities and a lack of provincial leadership focused on prevention rather than recovery.

Instead of strengthening conservation authorities as front-line climate adaptation institutions, this proposal increases political exposure and weakens independence at precisely the moment when stronger precaution is required.

3. Flooding in Ontario is not hypothetical, it is ongoing and costly

Flooding is already one of the most expensive and damaging climate-related risks in Ontario. Events in Toronto, the GTA, Ottawa, Windsor-Essex, and across southern and northern Ontario have resulted in billions of dollars in damages over the past decade. Insurance payouts for overland flooding have increased dramatically, and many impacts are not insured at all.

The Auditor General of Ontario has explicitly warned that failure to manage flood risk effectively will result in escalating costs to municipalities and taxpayers (Auditor General of Ontario, 2022). Conservation authorities play a critical role in floodplain mapping, development control, wetland protection, and hazard mitigation.

Any restructuring that weakens their independence or reframes their role as facilitating development rather than preventing harm directly increases public risk.

4. Development efficiency is being prioritized over public safety

The language used to justify this proposal is deeply troubling. Conservation authority review and permitting processes are framed as barriers, delays, or inefficiencies that must be streamlined to support housing and infrastructure priorities.

This framing fundamentally misunderstands the purpose of environmental regulation. Permits exist to prevent development in flood-prone areas, unstable slopes, wetlands, and other hazardous locations. Faster approvals are not a public good if they result in preventable flooding, erosion, or long-term infrastructure failure (Burby, 2006).

The explicit objective of aligning conservation authority services with provincial housing priorities creates an unacceptable conflict of interest. Conservation authorities must be able to say no, even when development is politically expedient. Reorienting their mandate toward facilitating development undermines their credibility and function as independent regulators.

5. The Greenbelt scandal destroyed public trust

Public trust is central to environmental governance. That trust has been severely damaged.

The Auditor General’s special report on changes to the Greenbelt documented a pattern of decision-making that ignored evidence, bypassed established planning processes, and prioritized development interests over environmental protection (Auditor General of Ontario, 2023a). This was not an isolated error. It revealed systemic governance failures and political interference in land use planning.

In parallel, the Auditor General reported that Ontario has failed to implement key recommendations related to flood risk adaptation and environmental reporting, despite increasing climate risks (Auditor General of Ontario, 2023b).

In this context, proposals that increase provincial control over conservation authorities cannot be credibly presented as benign modernization. They fit a broader pattern of centralizing power, weakening independent oversight, and reframing environmental protection as an obstacle rather than a safeguard.

6. Conservation authorities exist because of past disasters

Ontario’s conservation authority system emerged in response to catastrophic flooding and erosion, including Hurricane Hazel. These institutions were built because the consequences of poor land use planning and weak watershed governance were deadly and devastating.

Those lessons are even more relevant today. Climate change is increasing the frequency and severity of extreme weather events. Weakening watershed-based institutions now ignores history and increases the likelihood of repeat failures.

7. Centralized oversight increases political risk and reduces resilience

The proposal to create a provincially governed Ontario Provincial Conservation Agency introduces a clear risk of politicization. Even if regional conservation authorities retain operational roles, centralized oversight tied to provincial priorities inevitably shapes incentives, funding decisions, and institutional behaviour.

Research consistently shows that polycentric governance systems with strong local authority are more adaptive and resilient than centralized systems, particularly under conditions of uncertainty and change (Ostrom, 2010; Pahl-Wostl et al., 2012). Centralization simplifies control but increases the risk of system-wide failure.

Ontario’s conservation authorities are not perfect, but their municipal governance model provides a critical layer of accountability. Removing or diluting that accountability increases the risk that environmental decisions will be driven by political imperatives rather than science and precaution.

8. This proposal reflects a fundamental values failure

At its core, this proposal reflects a governing philosophy that treats watersheds as administrative units, environmental protection as a service to be optimized, and local governance as an inconvenience. It prioritizes speed, optics, and control over care, evidence, and responsibility.

Environmental protection is not an impediment to prosperity. It is a precondition for it. Weakening the institutions that protect Ontario’s waters, wetlands, and communities undermines long-term economic stability as well as ecological health.

9. What Ontario should do instead

If the province is genuinely concerned about consistency and capacity, there are evidence-based alternatives that do not undermine governance:

1. Provide stable, long-term funding for conservation authority science, monitoring, and hazard management.

2. Develop province-wide technical standards collaboratively, without stripping local decision-making authority.

3. Support voluntary shared services for administrative functions, not forced consolidation of governance.

4. Fully implement Auditor General recommendations related to flooding, wetlands, and climate adaptation.

5. Strengthen transparency and public reporting on environmental outcomes, not just approval timelines.

11. Ontario flooding impacts are real, escalating, and already overwhelming local systems
Flooding in Ontario is not speculative or future-oriented. It is an ongoing and escalating crisis with measurable human, financial, and ecological costs.
Major flood events in Toronto and the Greater Toronto Area in 2013, 2017, 2018, and 2019 caused billions of dollars in insured and uninsured damages, overwhelming municipal stormwater systems and disproportionately impacting lower-income neighbourhoods located in flood-prone areas (City of Toronto, 2019; Insurance Bureau of Canada, 2020). In 2017 and 2019, eastern Ontario and Ottawa experienced historic spring flooding along the Ottawa River, forcing mass evacuations and causing extensive infrastructure damage across multiple municipalities (Government of Ontario, 2019).
The Insurance Bureau of Canada has identified flooding as the leading cause of insured property losses in Ontario, with annual losses increasing dramatically due to climate-driven extreme precipitation (Insurance Bureau of Canada, 2020). Importantly, many flood impacts are not insured at all, leaving municipalities and residents to absorb long-term costs.
Conservation authorities are central to mitigating these risks through floodplain mapping, wetland protection, development control, and watershed-scale planning. Any proposal that weakens their independence or reframes their role as facilitating development rather than preventing harm directly increases flood risk and downstream costs borne by municipalities and taxpayers.
12. Ontario conservation authorities already demonstrate why local governance matters
Ontario’s conservation authorities vary dramatically in watershed characteristics, risk profiles, and governance contexts. The Toronto and Region Conservation Authority, the Grand River Conservation Authority, the Niagara Peninsula Conservation Authority, and the Credit Valley Conservation Authority each manage highly distinct watersheds with different hydrological dynamics, development pressures, and climate vulnerabilities.
For example, the Grand River watershed includes some of the most flood-prone communities in Ontario, with a long history of coordinated flood management, upstream-downstream collaboration, and municipal engagement. The Niagara Peninsula Conservation Authority manages complex interactions between escarpment geology, agricultural land use, shoreline erosion, and cross-border watershed dynamics.
Centralizing governance across such fundamentally different systems risks flattening local nuance and reducing the ability of conservation authorities to respond appropriately to place-based risk. Municipal representation on conservation authority boards is not symbolic. It is a core accountability mechanism that ensures decisions reflect local conditions, public risk tolerance, and community priorities.
Removing or diluting this accountability in favour of provincial oversight undermines the very effectiveness the government claims to seek.
13. Municipal autonomy is being eroded without justification
Municipalities fund a significant portion of conservation authority operations through levies and rely on them to protect residents, infrastructure, and property values. Despite this, the proposal moves decision-making power upward while leaving financial responsibility largely at the local level.
This is an unacceptable governance imbalance.
Municipal governments are closest to the impacts of flooding, erosion, and environmental degradation. They bear the immediate costs of disaster response, infrastructure repair, and community displacement. Stripping municipalities of meaningful influence over watershed governance while maintaining their financial obligations is neither democratic nor responsible.
Ontario municipalities are not obstacles to be managed. They are essential partners in environmental protection. This proposal treats municipal governance as a problem to be solved rather than a foundation to be strengthened.
14. Intergenerational responsibility is being actively undermined
Environmental governance is, at its core, an intergenerational responsibility. Decisions made today about floodplains, wetlands, and watershed integrity shape risks and costs decades into the future.
Climate change has already locked in higher levels of hydrological volatility. Weakening precautionary institutions now shifts risk onto future generations who will inherit degraded ecosystems, higher disaster costs, and fewer governance tools to respond.
This proposal prioritizes near-term political objectives, particularly housing approval timelines, over long-term resilience. That is an ethical failure. Future Ontarians will bear the consequences of decisions made today, without having had any voice in them.
Conservation authorities exist precisely to slow down short-term pressures in favour of long-term safety and sustainability. Undermining them represents a failure to uphold basic principles of stewardship and intergenerational justice.
15. Sharpened conclusion
This proposal is not about modernization. It is about control.
It reflects a governing philosophy that views environmental safeguards as barriers, local accountability as inefficiency, and precaution as expendable. It comes at a time when Ontario is already failing to adequately prepare for climate-driven flooding, has ignored multiple Auditor General recommendations, and has demonstrated a willingness to interfere in land-use planning for political ends.
Ontario cannot afford further erosion of environmental governance. The costs, both human and financial, are already too high.
I reiterate my call for the province to withdraw this proposal in its entirety and to recommit to watershed-based, locally accountable, science-driven conservation authority governance. Anything less is an abdication of responsibility to municipalities, communities, and future generations.