Ontario Land Trust Alliance…

Ontario Land Trust Alliance Comments on ERO - 025-1257 Proposed boundaries for the regional consolidation of Ontario’s conservation authorities
December 19, 2025

Please accept this submission from Ontario Land Trust Alliance (OLTA) in response to Environmental Registry of Ontario (“ERO”) Number 025-1257.

Ontario Land Trust Alliance appreciates the opportunity to comment on Ontario’s proposal to consolidate 36 Conservation Authorities (CAs) into seven Regional Conservation Authorities (RCAs).
The Province of Ontario has introduced significant changes to the Conservation Authorities Act, including the creation of the Ontario Provincial Conservation Agency (OPCA) and the proposed consolidation of 36 conservation authorities into seven regional bodies. OLTA supports CA modernization and consistent service standards, and is recommending that the proposals be reviewed to ensure that services and knowledge-based decision making is regionally and locally connected. We also would like any consolidation proposals to ensure that there is no erosion of local services, no loss of local expertise or science-based decision making, and stronger enforcement abilities for CAs to ensure development occurs in the best areas for the watershed and for the people.

Risks of the amalgamation include:
• Potential loss of local accountability, control, and expertise - Reduction in local municipal control and representation. Local level watershed management may be less responsive to unique local needs for managing flood risks
• Reduced Science-Based Decision Making - Amalgamation could lead to decision-making becoming more politically motivated, i.e., more permits may be granted for development in locations that would ultimately case more harm to the community, through loss of valuable natural infrastructure and increased flood risk.
• Ineffective functioning for CAs that are that are not geographically or hydrologically linked, resulting in poorer outcomes for the people in those watersheds – for example – merging Lakehead Region Conservation Authority (LRCA) into a Lake Superior and Northern Lake Huron region. Lake Superior and Lake Huron are two huge lakes with extensive and separate watersheds. The area that LRCA serves is very different from the Lake Huron conservation authorities and in a very different environment.

OLTA is proposing the following recommendations to mitigate these risks:
1) Any changes should include a stronger enforcement role for CAs to ensure that development does not happen in areas that serve a critical ecosystem and hydrological function, and does not worsen the impacts of flooding or erosion in these or surrounding areas.

2) Any consolidation of CAs should not result in erosion of services, or increased costs for residents or municipalities.

3) The significant lands held by CAs must be protected, be defined in Provincial legislation and not left to municipalities and individual CAs to determine.

4) Any consolidation should be science-based and not occur between areas that are physically disconnected, or in regionally separate local watersheds, with differing local needs and priorities.
Decision making should take into consideration the invaluable role of CAs to manage watersheds; protect communities from natural hazards; and deliver programs to improve the conservation, restoration, and management of our watersheds; and maintain these essential roles.

Thank you for providing an opportunity for OLTA to comment on this proposal.