I have reviewed the updated…

I have reviewed the updated 2025-12-09 posting for the “Proposed boundaries for the regional consolidation of Ontario’s conservation authorities” and offer the following comments.
1. Fragmentation: I have worked for municipalities and consulting firms and now as a sole practitioner from the Rasin River Conservation Authority near the Quebec boarder to the Upper Thames River Conservation Authority in the Kitchener – Waterloo area and from the Niagara Peninsula Conservation Authority to the Sudbury Conservation Authority including the City of Toronto. I have not found fragmentation to be a significant issue. There is no information provided on how much the “fragmentation” will be reduced and how much “fragmentation” will continue to exist when the amalgamation is completed.
2. Different Policies and Standards: While policies and standards differ from one Conservation Authority to another the difference is not significant and due diligence of review the information online or a quick email is adequate to identify those differences and to work with them. The standardization of standards is an issue the Province has had many years to resolve and should undertake that work on behalf of the existing Conservation Authorities.
3. Different Fees: Different fees are a function of the cost of doing business due to the various locations of the Conservation Authorities. Any increases borne by housing developers is insignificant when total costs of structures and utilities are considered. Most builders, landowners, and farmers seeking permits can write-off the fees against taxes significantly lessening the impact of fees.
4. Levels Of Staffing And Technical Capabilities: I have found no impact of different levels of staffing and technical capabilities, but the municipalities could provide funding to support an adequate staff compliment and the Province could mitigate any impacts of this issue by providing centralized technical resources and skills training (similar to the Minimum Distance Separation Formulas used in agriculture) and training to Conservation Authority and municipal staff and consultants.
5. Ontario Provincial Conservation Agency: the Ontario Provincial Conservation Agency is adding another level of bureaucracy and the associated costs. The cost of permits is a fee for service and the more layers of bureaucracy involve the greater the cost. The Province already has the ability to provide centralized leadership, efficient governance, strategic direction, and oversight of Ontario’s conservation authorities through the Ministry of the Environment, Conservation and Parks.
6. Duplicative Administrative Costs: No estimate of the reduction in duplicative administrative costs is provided. I believe is 100 people are required to do the work of 36 Conservation Authorities today, 100 will be required to do the work of seven (7) Conservation Authorities in the future.
7. Boundaries: Specifically with regard to the Western Lake Ontario Regional Conservation Authority, the inclusion of the watercourses flowing into Lake Erie may create the requirement for the Conservation Authority to have capabilities provided by the Lake Erie Regional Conservation Authority resulting a reduction the protection people and property focus than on the risks of natural hazards such as floodplains, shoreline erosion, stream valleys, and wetlands specific to the north shore of Lake Erie. The need to provide flood forecasting and warning for a different locustal and fluvial environment will be onerous and costly and may result in adequate resources not being provided due to the focus on Lake Ontario. Management of lands and recreational trails may deteriorate with the shifted focus away from the Lake Erie shoreline. The criteria applied for determining the proposed boundaries for regional conservation authorities of maintaining watershed-based jurisdictions – aligning with natural hydrological boundaries to support effective flood and water management, consistent with drinking water Source Protection Areas and Regions has not been followed.
8. River and Stream Flooding Hazard Limits – Two Zone Approach: The Two Zone Approach reflecting the actual risks involved in filling the flood fringe areas should be required for all Conservation Authorities particularly in Prime Agricultural and Rual Lands. The Provincial Planning Statement should be amended to requires the two zone approach to be applied where plausible requiring municipalities to include policies in their official plans.