I am commenting on the…

I am commenting on the Conservation Authority Amalgamation as proposed in ERO 025-1257. I do not agree with the proposal to consolidate Ontario’s 36 Conservation Authorities (CA, CAs) into 7 regional ones under the proposed Ontario Provincial Conservation Agency (OPCA). A consolidation of this size and nature risks the province’s ability to protect municipalities and natural infrastructure from escalating climate-related risks.

I observe that the intent of the proposal is to streamline the CA permitting system for developers, to make frontline service delivery easier for the protection of municipalities and to ensure the CAs are aligned with provincial priorities.
But the proposal has some inherent weaknesses that include as follows:

a) Reduction in local oversight of development proposals;
b) Less attention to watershed-based planning and site-specific environmental impacts;
c) Increased development pressure compounded by lessened local input and ability to enforce safeguards;
d) Centralization of authority in the OPCA, resulting in the risk of weakened regulatory protections and
competing priorities
e) Important local knowledge may be left out of key decisions, leaving municipalities open to flooding and other environmental hazards;
f) Local municipalities lose oversight of their monies despite funding CAs;
g) Amalgamation means limitations to CA mandates, resourcing, and independence from past years;
h) No mention is made of how hands-on monitoring to protect widely disparate watersheds and landscapes, drinking water, and flood protection will be done;
i) How would existing CAs and donated lands be handled;
j) Proposed regional CAs would cover large areas. Citizens would not know people in these large areas, have difficulty getting responses to questions and concerns, and a consequent loss to local needs.

The inherent weaknesses in the proposal leave Ontario and its Citizens open to systemic regulatory breakdown including gaps in oversight, policy, and enforcement weaknesses. This is concerning particularly with the human caused Climate Change we are now experiencing. It is important not to let down defenses against floods, habitat loss, and disasters affected by Climate Change. But, letting down defenses is the very thing the CA Amalgamation will do by consolidating 36 local CAs into just 7. It eliminates local oversight and preparedness meaning we will be more vulnerable to climate induced risks in the future.

CAs were formed 79 years ago, beginning in 1946. These were formed in response to flooding, development in bottomlands, loss of natural environments. and erosion in and along watercourses. The usefulness of CAs was further shown when Hurricane Hazel passed through Southern Ontario on the night of October 15, 1954. As a result of that 1000-year storm, the regulatory authority of the CAs was enhanced. Their functions have continued to remain useful to the Citizens of Ontario.

In the last two decades, this province has experienced 19 major floods. The local CAs were there already managing these climate induced risks. But recently their job has been made harder to do with the advent of legislation in the form of Bill 23 which resulted in major changes to the CAs Act. Standards under Ontario Regulation 41/24 and reinforced mandatory programs under O. Reg. 686/21 resulted in changes addressing concerns about consistency, transparency, and capacity. Hence, the CAs and the Act governing them have been weakened meaning many environmental protections are severely lessoned. Amalgamating 36 CAs into just 7 regional ones would further denigrate what protections are left and render them virtually meaningless.

I want CAs that can react locally to enhance watershed protection, prevent flooding, regulate development near watercourses and lakes, conserve/preserve drinking water sources, and protect municipalities.

Here are my Recommendations:

1) The 36 CAs are working just fine. The mantra of if they’re working, why affect changing to 7 regional CAs. Leave them as they are;
2) Restore the ability of the 36 CAs to oversee development approvals especially if these are near watercourses and lakes, including ecosystem and natural environment safeguards repealed recently;
3) Properly fund CAs to help municipalities to safely react to Climate Change risks;
4) Equip Conservation Ontario to enable effective and coordinated response by CAs to Climate Change;
5) Take a second look at all the environmental legislation that has been repealed/changed in Ontario asking why doing this has not resulted in additional housing being created in this Province. All that legislation was meant to “protect the province” for future Citizens. Repealing/changing it has done nothing to alleviate the so-called “housing crisis.” So somewhere along the line, the thinking is ill-advised. Bring back the legislation. Doing so is thinking provincially, and acting locally particularly regarding the 36 CAs we presently have.

CAs are effective due to their local expertise and governance aligned with watershed boundaries, not by artificial regions. Amalgamated Regional CAs relegate decision-making to places away from Citizens and municipalities who know their watersheds the best. Many years of monitoring, partnerships, and place-based science cannot be ramped up or replaced by distant regional or provincial bodies. Take note if you will - these changes will worsen water protections, increase flood risks, and put Citizens at risk.

So, I have written to you today as a concerned Citizen of Ontario because I do not agree with the Province of Ontario’s proposal as outlined in ERO Notice 025-1257 to amalgamate Ontario’s 36 CAs into seven large, regional bodies. Instead, I urge you to protect the watershed-based, municipal-informed governance model that has safeguarded Ontario’s waters and communities for decades. To do otherwise renders any environmental laws that Ontario has meaningless in the scheme of things and disrespects our shared future.