I appreciate the opportunity…

I appreciate the opportunity to provide comments on the Province’s proposal to consolidate Ontario’s conservation authorities. I share the Government’s stated objectives of improving efficiency, consistency, and modernization in service delivery, and I support efforts that genuinely streamline approvals and improve outcomes for municipalities, landowners, and residents.

Through my experience working closely with the Grey Sauble Conservation Authority (GSCA), I have seen firsthand that many of these objectives are already being advanced without amalgamation. GSCA has implemented digital permitting, streamlined internal processes, and improved customer service, and continues to look for ways to modernize while remaining responsive to local needs.

That said, I do not support the proposed consolidation of GSCA into a Huron–Superior Regional Conservation Authority. The proposed model would create an extremely large organization—covering more than 23,500 km² and approximately 80 municipalities—bringing together watersheds that share little common hydrology, climate, land use patterns, or economic context.

In my view, this structure poses several significant risks:

1) Loss of local accountability and rural voice
Our conservation authorities operate with strong municipal representation and decision-making that is grounded in local realities. Under the proposed model, the priorities of rural communities could easily be overshadowed by larger urban centres located hundreds of kilometres away, weakening the watershed-based governance model that conservation authorities were designed to provide.

2) Increased costs and bureaucracy
To date, no cost-benefit analysis or feasibility assessment has been provided to demonstrate that consolidation would result in savings. Based on experience with other large reorganizations, transition costs related to IT systems, human resources, governance restructuring, and rebranding are likely to be substantial. These costs would ultimately be borne by municipalities, with little evidence that member municipalities or taxpayers would see any financial benefit.

3) Reduced responsiveness
Larger administrative organizations often introduce additional layers of approval and decision-making. This runs counter to the Province’s stated goal of streamlining processes and risks slowing permitting and program delivery at the local level.

4) Disruption of long-standing community partnerships
The GSCA manages approximately 29,000 acres of land, much of it donated by local residents with the expectation of local stewardship. The authority also relies on strong relationships with volunteers, landowners, community groups, and municipal partners. Consolidation into a very large regional entity risks eroding these relationships and the trust that has been built over decades.

I believe the Province’s objectives can be achieved without structural amalgamation. Meaningful modernization could be advanced through:
- Province-wide permitting standards and policies
- Provincially developed and regularly updated technical guidelines
- Refined key performance indicators to measure outcomes against provincial objectives
- Shared digital platforms and tools
- Stable and sustainable provincial funding to support modernization and service delivery

Responses to ERO Consultation Questions

1. Key factors for a successful transition and outcome of regional consolidation

I do not support the proposed regional consolidation and believe the Province’s objectives would be better served without adding additional bureaucracy. However, if consolidation proceeds, success would depend on:
- Pausing the current proposal to allow the Ontario Provincial Conservation Agency to develop a comprehensive business case, including cost-benefit and feasibility analyses
- Clear provincial leadership and phased implementation to minimize service disruption
- Retention of local staff and institutional knowledge critical to program delivery
- Retention of local offices, including management presence, to maintain accessibility and partnerships
- Continuation of locally prioritized programming that reflects community needs
- Transparent governance structures that preserve municipal influence and watershed identity
- Dedicated provincial funding to cover all transition costs
- Clear and ongoing communication with municipalities, stakeholders, and the public

2. Opportunities or benefits of a regional conservation authority framework

In my view, these benefits can be achieved through collaboration, shared systems, and voluntary service agreements rather than consolidation. Potential opportunities include:
- Sharing technical expertise and specialized resources across authorities
- Consistent permitting standards and digital tools provided provincially
- Joint procurement and shared services to reduce duplication

3. Suggestions for governance structure at the regional level

The current governance model provides strong accountability and representation. Municipalities, who were the original creators of conservation authorities, are represented by elected officials who govern the conservation authorities, ensuring programs and budgets reflect local priorities.

If consolidation proceeds, a more workable alternative would include:
- A streamlined regional board (approximately 10–20 members)
- Representation grouped by upper-tier or single-tier municipalities
- Board appointments made through existing municipal governance structures
- Levy apportionment aligned with upper-tier or single-tier municipalities
- Clear protocols for communication between the regional authority and local councils
- Opportunities for Indigenous and industry representation, with those members excluded from budget votes

4. Maintaining a transparent and consultative budgeting process

The current budgeting process is transparent and accountable, allowing each municipality to review and influence budget decisions. This would be significantly weakened under the proposed consolidation.

If consolidation moves forward, the following would be essential:
- A standardized regional budget framework with clear assumptions and timelines
- Locally developed operating and capital budgets for each local office
- Review by sub-regional or local budget advisory committees
- Publicly accessible budget documents aligned with municipal budget cycles
- Transparent levy apportionment and regular financial reporting

5. Maintaining and strengthening relationships with local communities and stakeholders

Relationships with local communities take years—often decades—to build. Without maintaining local offices, staff, and leadership, these relationships are at serious risk.

To mitigate this:
- Local offices and staff presence must be retained
- Clear decision-making authority for local issues must remain
- Local branding and identity should be preserved to maintain trust and engagement

In closing, I urge the Province to prioritize modernization through shared standards, tools, and funding rather than large-scale structural amalgamation. Conservation authorities have been most effective when they are watershed-based, locally accountable, and closely connected to the communities they serve. I remain supportive of collaborative efforts to improve efficiency and consistency, provided they do not come at the expense of local governance, responsiveness, and trust.