RE: Proposed boundaries for…

RE: Proposed boundaries for the regional consolidation of Ontario’s conservation authorities

Thank you for this opportunity to make comment on the proposed boundary changes for the Conservation Authority (CA) system. As a former employee of the Ministry of Natural Resources, I have more than a passing interest and understanding of the history of the Conservation Authority system in Ontario. Given this, I have reviewed the consultation document, the changes that have been made to the CA system over the last few decades and have the following comments on the proposals.

BOUNDARY ISSUES

Many of boundaries are unreasonable. They weaken the capacity to bring local or even regional awareness of the challenges and issues faced with regard to land conservation and watershed management. They also will harm the process of consultation and weaken the process to ensure decision making is understood by all stakeholders.

As an example of scope overreach, the proposed CA that would serve Thunder Bay also services communities on Lake Huron. Simplification of watershed management does not occur just because you close offices. This significant explosion in geography will water down (pardon the pun) local expertise that is required to understand the river and shoreline challenges in this vast area.

Focusing on the Huron-Superior Regional Conservation Authority, patterns of water diversion and shore erosion are very different across the proposed new CA. Challenges of lake level increases and declines in Superior and Huron provide substantially different challenges for development and protection. Extreme weather presents in different ways as will future climate induced changes in the riparian network around this vast region.

I am also concerned that consolidation can easily lead to deferral of responsibility to others. Whatever else may happen, the Lakehead District Conservation Authority is a local/regional body that is responsible and can be appealed to a Director in Barrie or Owen Sound will not be well taken here in the Northwest.

The ability to select CA boards will be substantially complicated by either 1) a very large board or 2) a board with substantially less representation, and therefore buy-in, by municipalities served by the new CA. Selecting the board would have to be done by the Ministry or through regional plenums that would elect from within their members. As a former civil servant, I am well aware of the balance that is required when cities such as Thunder Bay share jurisdictional boundaries with many smaller regional communities as already exists with our EMS, Health Unit and CA. Stretching that tension over a region this large will create more conflict.

The current CA system is supported by their boards and staff. However, they also have a myriad of partnerships, local knowledge keepers and community supporters who will feel devalued in this process. That will be to the detriment of programs and services they help to fund, manage and support. Their frustrations will be driven by the Ministry’s perceived desire to remove local autonomy and responsibility by removing programs. It will also be fueled by a clear assumption in this proposal – that local CA’s are considered a roadblock by the Ministry. The modernization measures could have been implemented without this massive centralization of actual program authority. Given that fact, the reduction from 26 to 7 CA’s is a way to cut costs and reduce the capacity of the system to address issues that ensure that permits are issued based on accurate information.

MODERNIZATION - ADMINISTRATIVE EFFICIENCY

The commitment of the Ministry to modernize the CA system by funding provincial tools, processes and resources to make decision making more transparent and streamlined.

A standard portal for request and permits could offer great benefits for applicants and for the CA staff who could benefit from consistent training and operating practices. The devil is in the details here. An effective system will require time and resources to be designed, developed and implemented, as required through a Systems Development Lifecycle methodology. The process must start by consulting with all users – applicants and CA reviewers. There are also opportunities to work with Municipalities and other agencies to ensure the portal is not an isolated tool. Hopefully the government will work with Ontario or Canadian firms to ensure we are growing technical capacity here at home.

In the same vein, a GIS platform that houses province-wide data for floodplains, waterways, wetlands and other critical infrastructure could go a long way to leveling the playing field for both small and large CA’s (or sub-offices in your much smaller vision). Again, this could represent challenges during implementation as multiple systems and standards are realigned. The other big issue here is that the skill-sets required to manage such systems, even for users are in high demand in many areas of the economy, so you will need to consider the pay levels that are required to have competent employees. The other component of this initiative is a commitment to maintaining and updating the resources.

The first two goals are laudable, but I am concerned about the priority placed on performative standards, given the lack of clarity around the resources and staffing to be provided to offices on the ground. Watching the recent exercises in health care, I have serious concerns about the ability of the government to respect challenges faced by lower density jurisdictions. Standards can only be met when local offices have enough staff to align with workload by recognizing that some areas will have fewer transactions than others.

Standards also tend to depend on homogenized task definition. The ‘clock’ needs to start when the appropriate support for applications has been provided. There must be an allowance for a back and forth to ensure that timelines are not forced and that subjective, biased or incomplete submissions can be reviewed and properly vetted.

CONCLUSION

The discussion paper makes reference to “the OPCA is intended to … provide(ing) centralized leadership and oversight of all conservation authorities, facilitating resource and information sharing, as well as freeing-up resources for front-line conservation authorities to help ensure faster, more consistent and transparent permitting.” Flood pain mapping needs to be updated, not put aside in order to issue permits on inaccurate or outdated science. Issues that are coming at our communities fast, with the impact of development and climate change.

If consolidation is only focused on faster decision-making, rather than better decisions, you are neglecting the best part of the CA system – protecting waterways, wetlands and citizens from future damage. On that front, I see little benefit in this plan.

While government consolidations in search of efficiency are popular, they do not often translate into better services when it comes to program delivery. They tend to overly centralize decision making and reduce the opportunity for ‘locals’ to participate and understand why events happen, or do not. Local governance is a messy process, but it is required so that leaders can learn and grow. Bigger entities make bigger mistakes, and it is my experience that smaller mistakes are easier to review and learn from. As such I am not in support of the decimation of local CA’s. While the questions posed in the proposal document focused on implementing the changes, I do not see a successful path for this scale mergers, and am especially concerned about the lack of program logic behind the combination of the Huron/Superior watersheds.