Public Comment – Opposition…

Public Comment – Opposition to ERO #025-1257
Proposed Consolidation of Ontario Conservation Authorities

I am writing to formally oppose the proposed consolidation of Ontario’s conservation authorities as outlined in ERO #025-1257.

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Prefatory Note on Scope and Consultation Framing

The discussion questions accompanying this proposal are primarily framed around implementation, optimization, and governance within a pre-assumed consolidation model. As such, they do not meaningfully accommodate feedback on whether consolidation itself is necessary, proportionate, or supported by evidence.

Because the scale of the proposed restructuring has permanent implications for watershed governance, natural hazard management, democratic accountability, and Indigenous rights, it is not possible to provide meaningful feedback without first addressing the validity of the underlying premise. This submission therefore responds to the proposal as a whole, rather than confining comments to implementation questions that assume consolidation will proceed.

A consultation that does not allow respondents to question the premise of a proposal is not a test of public support.
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1. Conservation Authorities Were Created to Address the Limits of Centralization

Our Conservation Authorities system was not an accidental or administrative convenience. It was created in 1946 in response to widespread flooding, erosion, deforestation, and watershed degradation that neither the Province nor individual municipalities were able to manage effectively on their own. The Province legislated the Conservation Authorities Act to allow municipalities within a common watershed to jointly form a conservation authority with shared responsibility for natural resource management, including flood and erosion control. These authorities were founded on three core principles: local initiative, cost-sharing, and watershed jurisdiction.

The purpose of the Conservation Authorities Act remains explicitly watershed-based:
“…to provide for the organization and delivery of programs and services that further the conservation, restoration, development and management of natural resources in watersheds in Ontario.”

This statutory language reflects the original design: conservation on a watershed basis, not through a centralized provincial bureaucracy.

It is therefore striking that the Province now proposes a form of consolidation that reintroduces distance between decision-makers and local conditions, despite the fact that watershed complexity, climate volatility, and land-use pressures are significantly greater today than when the CA system was created.
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2. Historic Events Shaped Local Watershed Governance

Ontario’s experience with Hurricane Hazel in October 1954 demonstrates the necessity of a watershed-based, locally responsive model. Hazel caused devastating flooding, destruction, and loss of life in Southern Ontario and directly influenced how conservation and flood management were practiced thereafter. In its aftermath, the provincial government amended the Conservation Authorities Act to enhance the flood-management capabilities of conservation authorities, including land acquisition and floodplain regulation to protect communities from future disasters.

Hurricane Hazel’s legacy is an example of how real events have influenced Ontario’s flood management policies, including the role of conservation authorities in assessing flood hazard areas and controlling development that would increase risk.

The CA system was explicitly designed to ensure that watershed science, local knowledge, and locally accountable decision-making would shape watershed outcomes. A move toward a large, centralized agency fundamentally contradicts conclusions drawn from defining moments in Ontario’s history.
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3. The Proposal Lacks a Public, Evidence-Based Justification

The Province’s proposal asserts that the current system is fragmented and that consolidation would bring efficiency and consistency. However, no publicly available, source-specific evidence has been provided to justify reducing 36 conservation authorities to seven on the scale proposed. I am unable to access:

• Watershed-by-watershed and CA-specific needs assessment;
• Cost–benefit analysis that compares amalgamation with alternative governance reforms;
• Service-level performance data demonstrating systemic failure, or impact analysis on permitting timelines, emergency response, or regulatory capacity;
• Risk assessment addressing impacts on emergency response and hazard management; or
• A transition or implementation plan detailing governance, staffing, or accountability safeguards.

Absent this information, affected communities are being asked to comment on a transformational governance proposal without the evidentiary foundation necessary to evaluate it.
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4. Consultation and Public Awareness Are Insufficient

The public comment period is brief relative to the scope and permanence of the proposed changes. Public awareness is limited, and the consultation appears to be occurring after key details have already been framed, rather than as part of a transparent, collaborative, options-development process.

Meaningful consultation requires adequate time, accessible supporting data, proactive engagement with affected communities, and a genuine openness to alternative approaches. These conditions are not met by this process.
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5. Indigenous Consultation Obligations Have Not Been Demonstrated

Watershed governance and conservation authority restructuring directly affect lands and waters subject to Indigenous rights and interests. While the proposal indicates that Indigenous communities will be consulted at a later stage, it does not demonstrate how consultation obligations have informed the proposed structure to date.

Consultation under Section 35 of the Constitution Act, 1982 must be early, meaningful, and substantive, particularly where governance structures affecting land and water are concerned. Deferring consultation until after major structural decisions are articulated raises legitimate concerns about whether Indigenous perspectives are shaping the proposal rather than reacting to it.
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6. Amalgamation Is Not a Proven Path to Efficiency

Ontario’s own experience with large-scale public-sector amalgamations demonstrates that promised efficiencies are often overstated, while administrative complexity, transition costs, and reduced responsiveness are common outcomes.

Conservation authorities perform risk-sensitive, time-critical functions, particularly during flooding and erosion events. Expanding governance scale and decision-making distance increases the likelihood of delay and misalignment between policy direction and on-the-ground realities.
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7. Viable Alternatives Have Not Been Adequately Examined

The goals cited by the Province: consistency, efficiency, and coordination- can be pursued through less disruptive, well-established mechanisms, including shared services, harmonized technical standards, coordinated regional science, and enhanced inter-authority collaboration. These approaches are widely used across the public sector to improve performance without dismantling locally governed, watershed-based institutions.

The proposal does not demonstrate that such alternatives were rigorously evaluated, nor does it explain why wholesale amalgamation is necessary or superior to these options. In the absence of a publicly available needs assessment, cost–benefit analysis, service-impact study, or transition plan, it is reasonable for affected communities to question what problem this scale of restructuring is intended to solve, and whose interests it ultimately serves.

Advancing a structural transformation of this magnitude without a transparent evidentiary foundation raises serious concerns about the rigour, discipline, and integrity of the policy development process, particularly given the permanent consequences for local governance, risk management, and public accountability.
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8. Limitations of the Discussion Questions

The discussion questions provided with this proposal are framed to assume that regional consolidation will proceed, and therefore focus on implementation rather than legitimacy. By doing so, they exclude feedback on whether consolidation should occur at all, whether it is proportionate to the problems identified, and whether less disruptive alternatives would achieve the same objectives.

This framing constrains meaningful dissent and risks producing a misleading appearance of consensus.
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Alternate Questions for Consideration

To support informed, good-faith consultation, I put forward the following alternate discussion questions:

1. What evidence demonstrates that existing conservation authorities are failing to meet their mandates at a systemic level?
2. What specific performance gaps cannot be addressed through shared services, harmonized standards, or targeted reform?
3. What risks does large-scale consolidation introduce for emergency response, flood management, and local accountability?
4. How will democratic representation and municipal influence be preserved in authorities spanning dozens of municipalities?
5. How have Indigenous communities been engaged in shaping the proposed governance model?
6. What measurable outcomes would justify the disruption and risk associated with amalgamation?
7. Should consolidation proceed at all, given available alternatives?
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Conclusion

The government’s own historical rationale and statutory language underscore that conservation authorities were designed as locally governed, watershed-based organizations precisely because neither provincial centralization nor fragmented municipal action alone was adequate to manage complex environmental and hazard challenges. Now, at a time when watershed complexity has increased due to climate volatility and development pressures, the Province proposes a governance model that undermines the very principles that have guided conservation authorities for nearly 80 years.

I urge the Province to pause this proposal, release comprehensive supporting evidence, extend and deepen public and Indigenous consultation, and fully assess alternatives that preserve local expertise, accountability, and watershed health.