Thank you for the…

Thank you for the opportunity to input into the proposed amalgamation of conservation authorities in Ontario. The proposal, as present, is seriously concerning on a number of levels. The conservation authority model has been identified worldwide as a model of efficiency and effectiveness for its localized approach to watershed management. The proposed 'consolidation' of these organizations that protect lives and properties from the dangers of flooding and erosion creates serious concerns about the future of environmental sustainability within the Province of Ontario.

While the identified goals of improved efficiency seem relative, amalgamating conservation authorities will certainly cause bottlenecks and delays and remove the 'boots on the ground' response by those who are experts in their own watershed areas. The proposal raises many, many concerns about its ability to be implemented. What's more, the actual problem that this proposal is trying to solve has not transparently been identified.

Should the province decide to move forward with this plan, please find below some input to the questions identified with the ERO posting:

Q1. Key factors for a successful transition:
• First and foremost, clearly identify the problem this proposed amalgamation is trying to solve.
• Conduct real watershed-level consultation before legislative changes are considered. As municipalities are the key funders of conservation authorities, ensure their voices are heard.
• Complete a true and transparent cost-benefit analysis.
• Rather than wholesale changes, a pilot amalgamation should be tested to identify pain points and develop a functional mode.
• The proposed watershed regions are far too vast. Smaller sub-regions should be developed using the watershed principle. Consider Source Protection Areas as a model that may work.

Q2. Potential benefits:
• While in my opinion, there are no real benefits to the proposed amalgamation, there may be some benefit in shared technologies, should they be funded by the province. There may also be some reduced duplication of administrative costs, but again, the amalgamation as proposed is far too vast.

Q3. Governance structure suggestions:
• No suggestions.

Q5. Maintaining local relationships:
• Localized watershed offices are of critical important to provide boots on the ground response to natural hazards.
• Developers, municipalities and other technical experts rely on local watershed expertise to find creative solutions to challenging development issues - not centralized in a mega-bureaucracy.
• Ensure that category 3 services as negotiated with local municipalities are protected.
• Ensure that localized community engagement and educational programming can still continue.
• Many conservation authorities also have related Foundations that raise hundreds of thousands of dollars annually to support local conservation projects. It is of critical importance the funds raised for local projects are able to proceed and that the funds remain localized for the project for which they were intended. However, it is also possible that should the proposed consolidation go forward, many of these Foundations will no longer be able to raise funds as donors could perceive that they are in support of a 'government' agency, rather than a local conservation authority and related conservation projects, presenting a risk to the programs and projects that these funds support.