I am opposed to the proposed…

I am opposed to the proposed consolidation of 36 Conservation Authorities (CAs) into 7 regional CAs. This is a terrible idea at a scale that will erase all the benefits of the local knowledge, expertise and relationships with municipalities, communities, farmers and property owners, built up, in some cases over 80 years. CA's may not be perfect but they have been on the front line of managing our watersheds, preventing flooding through protection of vulnerable areas, protecting and restoring water resources and preserving natural areas for ecosystem and recreational value. Issuing permits, which they seem to do fairly efficiently, to provincial standards most of the time, is just a small part of what they do. If you want to improve an administrative function, take a look at that; don't blow up a whole system that does some amazing work.

Your ERO posting offers no evidence that the consolidation will actually improve things or specifics about you expect to achieve and over what timeline. I see no relationship between speeding up affordable housing development. Why would you put housing projects in areas that may be hazardous to both humans and natural ecosystems? Consolidation at a Province-wide scale will only distract attention and divert resources from the watershed stewardship that is so critical at this time when we are facing more extreme weather and wildfires than ever before. This kind of grand amalgamation scheme never saves money and trades so-called "economies of scale" for loss of local voices and attention to individual watershed priorities. Community representation will never be maintained in Regional CA that includes thousands of square kilometres and 70 or 80 municipalities. It's just not possible.

The "inconsistency" in approaches that the posting cites as a reason for consolidation is actually one of the strengths of the CA system. Ontario is a tremendously large and diverse province, with great variations in climate and landscape. A system that would apply the same policies and strategies to the northern, forested watershed around Thunder Bay on the Canadian Shield to the Lake Simcoe watershed, where agriculture and urban development are key factors is doomed to fail. The estimated costs and time to achieve this "transition" have not been presented and I suspect will far outweigh alternatives that might tweak the current CA system to improve it. Keep the local voice, the local expertise, collaboration, and responsiveness that characterize the vast majority of Ontario's CAs.

A much more effective approach would be for the Province to actually consult the CAs and other stakeholders and Indigenous rights holders about potential improvements, invest Provincial funding in areas such as joint development and implementation of digital solutions for mapping, data collection and storage, and permitting. The CAs already work together (e.g. through Conservation Ontario, project partnerships) and with municipalities on many projects (e.g. source protection). Don't pursue consolidation at an unworkable scale and unknowable cost. Instead, the Province should support and enhance existing joint CA efforts by providing financial resources and supportive policies (rather than ones that undermine CA stewardship such as the provincial changes to wetland and species at risk policies).

Finally, municipalities and local citizens and businesses are primarily footing the bill for CA operations, through tax levies and user fees. The Province largely abandoned its role in funding CAs years ago. The communities that are paying the freight for the CA function and are directly affected by CA activities should have the final say in how they are structured. A top down, one-size-fits-all approach imposed by a Minister, an unaccountable board and a provincial agency sitting in Toronto is not acceptable. It is not acceptable to me as an Ontario citizen, as local taxpayer, as person living on the recently expanding edge of the flood plain, or as user of Conservation Authority services in my community.

While I appreciate the opportunity to submit this comment, I have no hope that our Provincial government will listen to it or any of the others being submitted. The Auditor General has laid out the government's disregard for the EBR. It also is very clear from the decision notices on other postings, which indicate that hundreds of submissions opposing a proposed action were received, but that "no changes were made" in response.