Mississippi Valley…

Dear Minister McCarthy,
RE: ERO posting 025-1257 Regarding Conservation Authority Amalgamation
Attached are the official comments of Mississippi Valley Conservation Authority regarding the proposed amalgamation of conservation authorities. They focus on the following key matters:
1. Press pause –Such broadscale change is unnecessary and could undermine achievement of the province’s goals due to the scale of change. Time is needed to engage with municipalities and CAs to discuss options, their relative merit, and to develop successful business plans.
2. Phase-in changes – Doing too much too quickly will increase the risk of service disruptions. Any changes either in jurisdictional boundaries or the introduction of provincial tools should be phased-in and tweaked before full roll-out.
3. Pay for Say – Municipalities are the primary funders, governors, and beneficiaries of CAs and all must retain current rights of representation and decision-making.
4. Province Pay – We reject any funding of a provincial agency by municipalities now or in future. And, the province should pay for the costs of amalgamation.
We appreciate the opportunity to provide input on this significant proposed change in service delivery by conservation authorities. We look forward to working with you and your team as you move forward with this initiative.
Sincerely yours,
Roy Huetl, Chair
Sally McIntyre, General Manager

Mississippi Valley Conservation Authority's Board of Directors:
1. Supports the objectives of the province as set out in ERO 025-1257.
2. Disagrees with the proposed means for achieving those objectives for the following reasons:
a. The current 36 CA approach has its challenges, but broadscale amalgamation is not needed to resolve them. MVCA has addressed many of the concerns raised by its member municipalities in recent years and is a well-run organization. Yes, it can improve and does so every year. MVCA is keen to continue on this path and work with the province to address outstanding issues by harnessing existing partnerships with other CAs to equalize capacity and harmonize policies across Eastern Ontario.
b. The proposed approach could undermine Ontario’s build faster goal due to a disruption in business processes, staffing, and technologies that generally accompany organizational amalgamations. As of mid-November, MVCA had met its permit review timeline targets 100% for major applications and 96% of the time for minor applications, for an overall rate of ~97%, with an average turnaround time of 3.6 days. Workplace disruption could undermine this.
c. Ontario has a long history of municipal amalgamations, and they more often than not result in increased costs while failing to deliver on promised efficiencies. ,
3. Disagrees with the proposed St. Lawrence Regional Conservation Authority concept for the following reasons:
a. It covers two water basins that are subject to different regulatory and funding mechanisms and have very different water management regimes.
b. Our majority funder, the City of Ottawa, could see property taxes leave the Lower Ottawa River Basin for which it has a leadership role in stewarding. The Ottawa River requires ongoing attention due to the many control structures upstream, its history of flooding, increasing risks due to climate change, and the need for interprovincial coordination.
c. Eastern Ontario has a large Francophone population that receives bilingual service by South Nation Conservation and the City of Ottawa. There is a concern that official bilingualism at an organizational level will be lost in those communities; or that bilingualism requirements will be imposed at the Regional level greatly increasing operating costs.
d. The ~18,500 km2 area of the proposed St. Lawrence Regional CA is comprised of significantly different geographic conditions, which each require specialized knowledge and expertise in order to effectively manage natural hazards. A reduction in size would allow for greater sharing of expertise across the region.
e. Furthermore, there are practical challenges in terms of customer service, and corporate and board cohesion and over such a significant area, particularly as the north-south transportation network is limited and poses real impediments during inclement weather.
4. Requests that the Ministry pause approval of the proposed St. Lawrence Regional Conservation Authority to allow for meaningful engagement with municipalities and conservation authorities of Eastern Ontario to develop a locally appropriate solution. To this end it is recommended that a Working Group be established for Eastern Ontario and given up to a year to examine issues specific to this region, assess options for their resolution, and to develop a business case for the preferred approach. The Working Group would consider amalgamation options as well as:
a. Review Enhanced Shared Service Delivery Model – MVCA has MOUs with RVCA, SNC, and TRCA, as well as long-standing MOUs with the City of Ottawa that allow for the sharing of expertise across our organizations to mitigate duplication of effort, mitigate increases in payroll, and to streamline business processes.
b. Review Potential Service Corporation Model – Under this model, Eastern Ontario CAs could incorporate and fund a centralized service to provide HR, IT, and similar administrative functions at reduced cost to all five CAs.
5. Recommends the following additional Boundary Setting Criteria should the province continue to pursue its proposed amalgamation approach:
a. Financial fairness—currently all municipalities support watersheds within their geographic boundaries. How with transfers amongst watersheds be managed (municipal levies, capital reserves, grant distributions, and asset investments.)
b. Operational effectiveness—travel times to sites, spans of control, management supervision over large distances, maintaining/enhancing customer service.
c. Governance effectiveness—ability of Board members to meet, develop Board cohesion, and effectively represent the interests of their municipalities.
d. Existing partnership agreements—many CAs already collaborate on a wide variety of matters in the absence of amalgamation.
e. Regulatory differences—the Ottawa River and St. Lawrence River are managed differently and operated under different transboundary agreements.
6. Suggests an alternative Lower Ottawa River Conservation Authority (LORCA) concept for consideration should the province continue to pursue amalgamation.
a. The proposed LORCA would comprise all land draining to the lower Ottawa River from the jurisdictions of MVCA, the Rideau Valley Conservation Authority, South Nation Conservation, and Raisin Region Conservation Authority.
b. There is a history of cooperation between MVCA, the Rideau Valley Conservation Authority and South Nation Conservation in rate setting, policy development, shared services, grant writing and project execution.
c. The three CAs have had scheduled quarterly meetings with the City of Ottawa for over 10 years and long-standing working relationships and service agreements in place that would help to mitigate the impacts of amalgamation. (For this same reason, amalgamation is not viewed as necessary as the current approach is working.)
d. While there are definite differences in geography as one moves from west to east, the proposed jurisdiction is well served by Highways 7, 417, and Ottawa Road 174 and centrally N-S by Highway 416. The distances are practical in terms of meeting the day-to-day needs of clients, staff, and Board members.
7. Suggests the following municipal representation if the province moves forward with the LORCA model. This is intended as a starting point for discussion only.
2025 Approx. Assessment Value Municipality No. of Board Reps.
86% City of Ottawa 8
5% Prescott & Russell 3
4% Lanark 3
2% Leeds & Grenville 1
2% Stormont Dundas Glengarry 1
1% Frontenac 1
1% Mississippi River Headwater Municipalities 2
While the assessment value of headwater municipalities is minor, their lands and the water control structures they host play a critical role in management of the Mississippi River system. It is proposed that these positions be appointed on a 2-year rotating basis so that each municipality has an opportunity for representation on the Board on a regular basis.
8. Recommends the following planning and transition approach should the Province move forward with amalgamating MVCA with other Eastern Ontario CAs.
a. Phased Implementation – Studies show that “rushed” amalgamations fail to achieve their objectives. Accordingly, it is recommended that the Province continue to consult with CAs on all aspects of the proposed amalgamations and consider phased implementation to allow focused effort in regions of greatest need and the application of lessons learned to other areas. Specifically, it is recommended that the amalgamation model be first applied on a trial basis to an area of the province most in need of attention before being applied elsewhere.
b. Establish a Transition Board – For each region, to develop and implement a phased approach to the harmonization of governance, planning and regulatory tools, business processes, and corporate services and tools. Provincially fund and provide a minimum of 4 years for each region to evolve from current state to the desired end-state.
c. Delay implementation of the centralized permitting system – This tool could add complexity where none exists today during a period of significant transition. There is a very real risk that any failure of that system could upset planning and permit applications across the province. Accordingly, it should be trialed and tweaked in one region before being implemented province-wide.
9. Objects to municipalities carrying any costs associated with the proposed amalgamations. All costs incurred through the amalgamation process and transition period should be paid by the Province.
10. Objects to any direct or indirect municipal funding of the proposed Ontario Conservation Authority Agency including fees for service and levies.
11. Requests that the Ministry examine alternative approaches to equalizing resources amongst CAs including review of the annual provincial transfer to conservation authorities that were halved in 2019 and have remained unchanged since.
12. Requests that the Ministry update provincial technical guidelines that inform permitting by conservation authorities in Ontario to facilitate greater consistency across the province.
13. Recommends that MVCA’s office in Carleton Place remain the primary service centre if regionalization occurs. MVCA is the only authority in Eastern Ontario with significant watershed management and operational responsibilities through its ownership and operation of 11 structures and the provision of operational support to OPG and MNR. The Carleton Place works yard and office provide good access to all structures and to urban expansion areas in the eastern portion of its jurisdiction.