I am a resident of the…

I am a resident of the Niagara Region and am providing input on the Ontario Government's Proposed Bill 68 Plan to Protect Ontario (Budget Measures). I am deeply opposed to this Bill for numerous reasons that include:

1. It is neither necessary nor justified to increase efficiency and efficacy of local Conservation Authorities. In our jurisdiction, the Niagara Peninsula Conservation Authority maintains high standards of efficacy in managing and protecting local watersheds, efficiency in terms of issuing permits (they have a very high percentage compliance with Ontario government standards for the timeline of issuing permits), maintaining community engagement and engaging in community fundraising. Amalgamating the NPCA with a larger body would seriously undermine all of these areas.

2. It poses a serious risk of losing local, specialized knowledge of unique conservation areas. Every local CA has a specific profile and management needs. Staff working at the NPCA (as well as other CAs) have developed their specialized knowledge over time and with experience. The proposed amalgamation into the Western Lake Ontario Regional CA would embed the Niagara Region within an approximately 4,900 square kilometre area serving 28 municipalities and nearly 2 million people. It is vanishingly unlikely that an RCA with this scope of responsibility would be able to respond in as efficient and effective a manner to local events and issues as the current local CAs are able to do. The Niagara Region is particularly sensitive in this regard since it incorporates not only the local watersheds and the Niagara Escarpment, but also a highly unique agricultural profile that includes fruit growers and vineyards as well as more typical crop and animal farms. I believe there is a significant risk of the very unique environmental management needs of our Region being lost in the scope of the new proposed RCA.

3. It introduces the likelihood of a more costly infrastructure that in all probability will siphon off funds needed for conservation management to support that infrastructure, as well as bringing significant one-time costs to effect the proposed transition.

4. It is very likely that the bureaucratic infrastructure of the proposed RCAs will be much more layered and cumbersome than the existing CAs. This will make it much harder for citizens to communicate with, provide feed back to, and acquire needed information from the CAs. At present, the NPCA has been exemplary in its accessibility, responsiveness and clarity when engaging with the public. The sheer geographical scope of the proposed RCA, never mind the breadth of its mandate in terms of varied watershed environments and the enormous population it would have to serve, drastically reduces the likelihood that local citizens will find their CA to be accessible and responsive. In turn, this is likely to reduce citizen engagement, compliance with conservation efforts, and knowledge and understanding of the environment that surrounds them.

5. It creates the very real risk that citizen financial contributions (donations) to RCAs will go down due to feeling alienated. Local CAs can (and in the case of the NPCA, do) develop and maintain deep connections to communities that, in addition to promoting community awareness of environmental sustainability and compliance with environmental protections, support citizen willingness to make donations and otherwise participate in funding activities.

6. It includes language that shows a clear bias towards controlling the environment for the convenience and benefit of people (particularly developers and builders), without affirmation of the critical role of conservation in protecting the environment from and for people. Premier Ford's government has already made one attempt to undermine environmental protections by attacking the environmental protections of the Greenbelt; this attempt was squashed due in significant part to a very strong community response. This response, in turn, was in part supported by the education provided by local CAs who recognised the very serious danger to the integrity of our protected environment. I believe that the proposed RCAs would greatly weaken local governance including the ability of local CAs to promote awareness of serious environmental consequences that will follow from unfettered exploitation of the environment. There must be a balance struck between municipal development and expansion needs, and ensuring that the environment in which development happens is effectively protected. The negative consequences of failing to maintain balance are already very clear through flooding, fire, erosion, loss of biodiversity, worsened air quality, et cetera, all of which have a direct and negative impact on human welfare. I believe that the proposed amalgamation is, in part, a deliberate attempt on the part of the current government to weaken environmental protections by wreaking local conservation authorities, for the purposes of paving the way for expansion in development into currently protected areas. If so, then this proposal is also lacking in transparency, integrity, good science and good faith.

Thank you for your attention in this matter.