To whom it may concern, As a…

To whom it may concern,

As a resident of Ontario, I submit the following comments on the ERO posting “Proposed boundaries for the regional consolidation of Ontario’s conservation authorities.” I believe it is both my responsibility and privilege to do so. I write as an expert in the field of environmental governance. I hold an M.A. in public policy, with research focused on environmental governance in Ontario, which has received recognition at both the national level.

I begin by emphasizing the importance of considering the Environmental Bill of Rights in relation to the current ERO posting. The decision to consolidate conservation authorities was made before the closure of this posting (Bill 68), and as such, the Ontario Government continues to disregard the public’s rights under the Environmental Bill of Rights. It is my opinion that the public consultation on the proposed boundary amendments is neither meaningful nor likely to influence government decision-making. This concern is supported by reports from the Auditor General (see Performance Audit Operation of the Environmental Bill of Rights, 1993, Annual Report 2025), which highlight ongoing issues—under both the current and previous governments led by Doug Ford—regarding decision-making processes and the protection of Ontarians’ rights under the Environmental Bill of Rights. The Province should carefully consider input from municipalities, landowners, conservation authorities, Indigenous communities, community groups, academics, and other stakeholders before making any final decisions, and uphold responsibilities under legislation.

Conservation authorities in Ontario play a vital role in the protection, conservation, and restoration of the natural environment for the benefit of current and future generations. They were first established under the Conservation Authorities Act of 1946 (now replaced by the 1990 Act) as a policy response to poor land, water, and forestry practices throughout the 1930s and 1940s. These practices contributed to widespread flooding and erosion across Ontario. Conservation authorities were created to address these growing concerns.

Three core principles guided their development. The first is local initiative, meaning local communities identify and solve problems without top-down imposition. The second is cost-sharing between municipalities and the provincial government. The third is watershed jurisdiction. Any decision-making surrounding conservation authorities must remain grounded in these three principles.

It is also important to recognize two major environmental criss shaped the role of conservation authorities. The first was Hurricane Hazel in 1954, whose devastating rainfall expanded the role of Conservation authorities in floodplain management. The second was the Walkerton Water Crisis in 2000. The Walkerton Inquiry recommended a multi-barrier approach to water protection, with Conservation authorities leading the planning and delivery of source water protection in Ontario. The Ontario Government implemented the Clean Water Act, 2006, based on these recommendations, assigning conservation authorities a legislated role as source protection authorities under the Ministry of the Environment. Any decision-making must uphold the capacity of conservation authorities to save lives and protect property, and must carefully assess any potential impacts on their ability to carry out this work.

While environmental crises have expanded the role of conservation authorities, “there have been numerous attempts by various provincial governments to reduce their role. In some cases, regulatory work ends up as a balance between science-based evidence, public values, and political ideology” (McCarthy et al. 2018). The current ERO posting reflects the continued weakening of conservation authorities in Ontario. These changes seek to push political priorities, including housing and development. Decisions about lands and resources owned and managed by conservation authorities should remain close to the communities that use and care for them. Effective planning, permitting, and decision-making must be grounded in science, geography, and local hydrology. Consolidation risks the loss of local expertise essential to public safety, environmental protection, and the delivery of community services. Locally developed services must be protected. A regional model may lead to reduced service levels, loss of expertise, or diminished community access. Regionalizing permitting must not create delays, bottlenecks, or reduced access to technical expertise. Precedent for decision making must first and foremost be on the protection of lives and property- and not political pressures.
The Ontario Government has not been a full partner in conservation authorities development since their inception. Historically, insufficient provincial funding is likely to be a contributing factor in the fragmented and variable nature of Conservation authorities across Ontario. Today, provincial contributions represent only 2% of operating budgets. There is a clear need for fair and transparent funding across both rural and urban municipalities, ensuring that cost shifts do not disadvantage smaller communities. The provincial government should take greater responsibility for adequately funding Conservation Authorities; however, these organizations must remain at arm’s length from government to ensure that their decision‑making is insulated from political influence.
Recognizing that the government has already decided to consolidate conservation authorities through the passing of Bill 68, I nonetheless state that I do not support the government’s decision to implement regional consolidation or to create the Ontario Provincial Conservation Agency.

Until the government provides the public with a meaningful opportunity to understand and engage with its plans—including the transition process, the governance structure of the regional system, transparent and consultative budgeting processes, and how local relationships will be maintained and strengthened—it is premature to request public feedback. As it stands, the government has neither articulated nor developed the framework necessary to implement the decision it has already made.