I am writing as a resident…

I am writing as a resident of Thunder Bay to share my opposition to the Province’s proposed amalgamation of the Lakehead Region Conservation Authority (LRCA) with six other Southern Ontario Conservation Authorities to form the “Huron-Superior Regional Conservation Authority”. I support the LRCA’s recommendation that the Lakehead Region Conservation Authority form a stand-alone Regional Conservation Authority as the “Northwestern Ontario Regional Conservation Authority”.

1. Overview

The proposed Regional Conservation Authority boundaries are not appropriate for Northwestern Ontario. Ontario’s criteria for developing these boundaries indicate that a “Northwestern Ontario Regional Conservation Authority” should be established, growing from the LRCA’s 70 years of efficient, effective, and valuable service in Northwestern Ontario.

2. The proposal is inappropriate for Northwestern Ontario, the Northwestern Lake Superior Watershed, and the LRCA, geographically, administratively, and financially

The proposed boundaries for the regional consolidation of Ontario’s conservation authorities do not align with geographic, administrative, or financial realities of Northwestern Ontario.
The Northwestern Lake Superior Watershed, and the LRCA serving it, are located in Northwestern Ontario, between 1,300 to 1,500 kilometres, or a 14-to-16-hour drive, away from the rest of the proposed “Huron-Superior Regional Conservation Authority”. The proposal will see the LRCA, which presently serves eight Northwestern Ontario municipalities, merged with six other Conservation Authorities in Southern Ontario, who service a combined 72 municipalities (this number may be slightly lower given Ontario’s December 9, 2025, update to ERO posting #025-1257). It does not make sense to combine these geographically distant areas into one Regional Conservation Authority.

Furthermore, the local purview, governance, and administration of the LRCA will be lost in the singular regional board of directors for the “Huron-Superior Regional Conservation Authority”. Presently, the LRCA’s board consists of 11 members who are appointed by municipalities serviced by the LRCA. These board members live in the region and are closely connected in Northwestern Ontario, enabling a deeper understanding of priorities in the region as well as higher levels of accountability.

The board of the proposed “Huron-Superior Regional Conservation Authority” will have heavy representation from Southern Ontario, including individuals who likely have not even visited Northwestern Ontario before. This will lead to priorities in Northwestern Ontario being overshadowed by priorities from Southern Ontario (an issue Northwestern Ontario frequently experiences in Ontario politics, but that should not be normalized). This structure will not serve Northwestern Ontario, the Northwestern Lake Superior Watershed, and the LRCA well. Instead, a “Northwestern Ontario Regional Conservation Authority” with on-the-ground, connected, and involved leadership and administration is needed.

Finally, the LRCA already has strong relationships with municipalities in Northwestern Ontario, and half of its budget comes from municipal levies. Another 45 percent of its budget comes from self-generated revenue and external funding. Only five percent of its budget comes from the provincial government. This budget is at risk of being substantially altered, likely at higher costs to Northwestern Ontario municipalities and residents, then redirected to Southern Ontario as part of the “Huron-Superior Regional Conservation Authority”. As this happens, the government may need to provide subsidies or other equitable supports for access to important services for Northwestern Ontario residents and municipalities, costing the government more in the long run.

Overall, the proposal is inappropriate for Northwestern Ontario, the Northwestern Lake Superior Watershed, and the LRCA. A “Northwestern Ontario Regional Conservation Authority” would be more appropriate.

3. The criteria used to determine the proposed boundaries support establishing a “Northwestern Ontario Regional Conservation Authority”

The ERO posting lists the following criteria used to determine Regional Conservation Authority boundaries: (1) maintaining watershed-based jurisdictions, (2) relationships between conservation authorities and municipalities, (3) balancing expertise and capacity across conservation authorities, and (4) service continuity.

These criteria point to the need for a “Northwestern Ontario Regional Conservation Authority” instead of combining the LRCA into the “Huron-Superior Regional Conservation Authority”.

First, a “Northwestern Ontario Regional Conservation Authority” is congruent with maintaining watershed-based jurisdictions. The Northwestern Lake Superior Watershed and the Eastern Lake Huron Watershed are secondary watersheds only connected by their primary watershed, the “Great Lakes - St. Lawrence River Watershed” (which includes the entirety of the Great Lakes and most of the other proposed Regional Conservation Authorities). Maintaining a secondary watershed-based jurisdiction for Northwestern Ontario makes sense.

As the boundaries are currently proposed, they do not maintain watershed-based jurisdictions. They consolidate the sole Conservation Authority in the Northwestern Lake Superior Watershed with six other Conservation Authorities in the Eastern Lake Huron Watershed to form a disparate “Regional Conservation Authority” in separate regions and different secondary watersheds over 1,000 kilometres apart (see the Ontario Watershed Boundaries Interactive Map). Establishing a “Northwestern Ontario Regional Conservation Authority” grounded in the LRCA’s continuing successful service to the region would be more appropriate to maintain an efficient, effective watershed-based jurisdiction for a Regional Conservation Authority.

Second, a “Northwestern Ontario Regional Conservation Authority” will better uphold relationships between Conservation Authorities and municipalities. The LRCA currently has strong relationships with the municipalities they serve in Northwestern Ontario, and a “Northwestern Ontario Regional Conservation Authority” would enable these relationships to continue, without dragging in distant Southern Ontario municipalities.

The criterion related to relationships between Conservation Authorities and municipalities is supposed to “reduc[e] administrative duplication and overlap for municipalities and conservation authorities to simplify accountability and strengthen local partnerships,” according to the ERO posting. However, the proposed boundaries will do the opposite for those in the LRCA’s current catchment area.

As of right now, 50 percent of the LRCA’s funding comes from a municipal levy (note that another 45 percent comes from self-generated revenue and external funding, and only 5 percent comes from the provincial government). Local partnerships are strong and administrative duplication is minimized because of the positive relationships the LRCA has with municipalities in the region – they work together to get work done efficiently and effectively. For example, the LRCA averages less than five days to issue a permit once it is requested. It makes sense to establish a “Northwestern Ontario Regional Conservation Authority” building on the LRCA’s 70 years of success instead of adding the LRCA into the “Huron-Superior Regional Conservation Authority”.

Conversely, adding the LRCA and Northwestern Lake Superior Watershed to the “Huron-Superior Regional Conservation Authority” will make permits less accessible and efficient for people and developers in Northwestern Ontario, as it will serve 72 Southern Ontario municipalities in addition to the current municipalities in the LRCA’s catchment, bogging down approval timelines and adding bureaucracy. Further, local partnerships will not be strengthened, as the municipalities and Conservation Authorities in Southern Ontario are not local to Northwestern Ontario. Accountability will also not be simplified since the Regional Conservation Authority and its leadership will be greatly removed from the local community.

Third, the LRCA already has well-developed expertise and capacity, with knowledge of local floodways, flora, fauna, and geography. This expertise and capacity does not need to be balanced with that of Conservation Authorities in Southern Ontario – it has been curated to serve Northwestern Ontario. Part of this expertise and capacity also comes from the LRCA's relationships and work with Indigenous peoples and nations in the region. Given all of this, it makes sense to support the LRCA to grow into the “Northwestern Ontario Regional Conservation Authority” instead of forcing the LRCA to consolidate into a Regional Conservation Authority in a distant region.

Fourth, a “Northwestern Ontario Regional Conservation Authority” would ensure service continuity in Northwestern Ontario. As mentioned earlier, the LRCA averages less than five days to issue permits. They also manage 10 Conservation Areas, provide numerous services, and have well-established operations. Creating a “Northwestern Ontario Regional Conservation Authority” with the LRCA would build on that success.

On the other hand, the consolidation of the LRCA into the “Huron-Superior Regional Conservation Authority” with six other Conservation Authorities in Southern Ontario will not maintain service continuity. There will be limited prioritization of Northwestern Ontario issues and needs, as there will be limited representation on the regional board. Assets like the Conservation Areas will be merged into regionally owned assets, which could then be de-prioritized or even removed by board members who have not even been to Thunder Bay or Northwestern Ontario before. There will likely be longer wait times and higher costs for permits for those in Northwestern Ontario given the number of people and amount of development in the Southern Ontario parts of the “Huron-Superior Regional Conservation Authority”. This is not service continuity; this is service degradation. There will also be substantial costs to re-brand, merge finances and IT services, and overall transition and re-structure the LRCA’s existing operations, which will impact service provision and continuity, as well as create unnecessary extra costs.

In short, Ontario’s criteria for establishing Regional Conservation Authorities supports the creation of a “Northwestern Ontario Regional Conservation Authority” instead of combining the LRCA into the “Huron-Superior Regional Conservation Authority”.

4. Conclusion

In conclusion, Ontario should strongly consider establishing a “Northwestern Ontario Regional Conservation Authority” with the LRCA, instead of amalgamating the LRCA, the Northwestern Lake Superior Watershed, and Northwestern Ontario into a distant and disconnected Regional Conservation Authority. Ontario’s criteria for establishing the proposed Regional Conservation Authority boundaries support the creation of a “Northwestern Ontario Regional Conservation Authority”. It would be inappropriate geographically, administratively, and financially to add the LRCA and Northwestern Lake Superior Watershed into the proposed “Huron-Superior Regional Conservation Authority”. Creating a “Northwestern Ontario Regional Conservation Authority” per the LRCA's recommendation is justified and will better serve Northwestern Ontario municipalities and residents, as well as the Northwestern Lake Superior Watershed overall.