At first glance, I don’t…

At first glance, I don’t think it’s a good idea to consolidate 36 Conservation Authorities into 7, as I understand that there is very nuanced and local knowledge that could be missed in decision-making and permit-issuing that could have problematic consequences in terms of flooding, wetland and ecological damage.

The premise of these changes might be “true”; truthfully, I don’t know as I have trusted the Conservation Authorities to do their work; in my experience as a local citizen they seem to be doing that. Perhaps as you have said, the current system is “fragmented, with each conservation authority following different policies, standards, fees and levels of staffing and technical capabilities. This has led to unpredictable and inconsistent turnaround times for approvals across all conservation authorities, creating uncertainty and delays for builders, landowners and farmers seeking permits, and undermining conservation authorities’ ability to protect communities from floods and natural hazards.” So, it would make sense to bring some standardization to policies, standards, fees, staffing levels; to try to make turnaround times more consistent and create more certainty for those seeking permits.

For the specific questions you ask:
A. What do you see as key factors to support a successful transition and outcome of regional conservation authority consolidation?
• Robust consultation with current Conservation Authority staff, municipalities, ordinary citizens, and Indigenous nations to guide the consolidation; which may even be to decide against consolidating or to increase to a number between 7 and 36.
B. What opportunities or benefits may come from a regional conservation authority framework?
• As you have mentioned, more standardized policies, practices and more predictable expectations for those seeking permits.
C. Do you have suggestions for how governance could be structured at the regional conservation authority level, including suggestions around board size, make-up and the municipal representative appointment process?
• Again, please consult with those currently working within the Conservation Authorities and municipalities as they have the on-the-ground knowledge and experience to guide you. Too much of this top-down decision making.
D. Do you have suggestions on how to maintain a transparent and consultative budgeting process across member municipalities within a regional conservation authority?
• Please refer to advice from the Auditor General who consistently seems to think there is a lack of transparency and accountability from this current government.
E. How can regional conservation authorities maintain and strengthen relationships with local communities and stakeholders?
• Reach out to the Toronto and Region Conservation Authority: I think they do an excellent job of engaging the local communities.

What I think seems okay:
Section 35.4 in the Conservation Authorities Act.
3. Promote consistent policies, standards and fees for programs and services provided by authorities.
4. Assess and report on the effectiveness of authorities in furthering the conservation, restoration, development and management of natural resources in watersheds in Ontario, including outcomes related to the implementation of their programs and services.
5. Oversee and evaluate the financial performance of authorities to ensure their long-term operational and capital financial sustainability, including the financial sustainability of their programs and services required under section 21.1.

However, I am uncomfortable with Subsection 6 “Guide and evaluate the strategic planning by authorities to ensure it aligns with provincial objectives’, as I don’t trust the current government’s provincial objectives – which seem to favour the interests of developers and donors over robust environmental stewardship and what is actually good and needed by the population, such as affordable housing.

Regarding subsection 7 “Support the development and implementation of a standardized and centralized system for processing applications for permits issued by authorities”: “standardized and centralized” systems sounds promising, but I worry there can be serious blind spots because sometimes exceptions should be made based on nuanced local conditions or circumstances.

Section 35 – Board of Directors:
(3) The Lieutenant Governor in Council shall, in appointing a person as a member of the board of directors, take into consideration,
(a) the person’s knowledge and experience in public administration, corporate governance and finance;
(b) the person’s knowledge of programs and services provided by authorities; and
(c) such other matters as may be prescribed by regulation. 2025, c. 15, Sched. 3, s. 4.

Why would deep ecological knowledge and expertise not be included in the considerations for membership? “Knowledge of programs and services provided by authorities” is not the same as deeply understanding land, water and ecological issues. Particularly, things that are noted to be under the care of Conservation Authorities such as hazardous lands, wetlands, rivers or streams, “areas that are adjacent or close to the shoreline of the Great Lakes-St. Lawrence River System or to an inland lake and that may be affected by flooding, erosion or dynamic beach hazards”, activities to change waterways or wetlands, “flooding, erosion, dynamic beaches or unstable soil or bedrock”, “conditions or circumstances that, in the event of a natural hazard, might jeopardize the health or safety of persons or result in the damage or destruction of property.” I think at least some members of the board of directors should have direct knowledge of and experience with such issues.

35.8 – The Secretary of the Cabinet shall appoint the first CEO. Again, I don’t trust this government to appoint someone whose primary concern is ecological stewardship; rather I anticipate that someone will be appointed to advance the government’s agenda of issuing permits for development where development is unwise or ecologically unsound or problematic.

35.15 – I am surprised by the three-year reporting cycle. Perhaps this is normal for government bodies? It seems like rather large lapses of time, during which serious damage can be done without oversight or “course correction” if needed.

35.20 - If the Minister considers it to be in the public interest to wind up the affairs of the Agency: does this mean the Minister could simply shut down the work of Conservation Authorities altogether? It almost sounds like that is the direction the government is headed, which does not sound like a good idea for the watersheds of Ontario, the safety of Ontarians, and prudent development in our province.

Section 40.4, about Regulations: it sounds like the government is intent on redefining things in Section 28 to make it more convenient for developers, which may not be in the best interests of the lands and waterways:
“(a) governing the prohibitions set out in section 28, including,
(i) prescribing the limits on river and stream valleys for the purposes of subparagraph 2 iii of subsection 28 (1),
(ii) determining or specifying areas for the purposes of subparagraph 2 iv of subsection 28 (1),
(iii) determining or specifying areas in which development should be prohibited or regulated for the purposes of subparagraph 2 v of subsection 28 (1),
(iv) prescribing activities or types of activities to which the prohibitions set out in subsection 28 (1) do not apply and respecting the manner or circumstances in which the activities or types of activities may be carried out and any conditions or restrictions that apply to the activity or type of activity,
(v) prescribing areas in which the prohibitions set out in subsection 28 (1) do not apply and respecting the manner or circumstances in which the activities may be carried out in such areas, and any conditions or restrictions that apply to carrying out activities in such areas,
(vi) defining “development activity”, “hazardous land”, “watercourse” and “wetland” for the purposes of section 28;
(b) governing applications for permits under section 28.1, the issuance of the permits and the power of authorities to refuse permits, including prescribing requirements that must be met for the issuance of permits under clause 28.1 (1) (c), conditions that may or may not be attached to a permit or circumstances in which a permit may be cancelled under section 28.3 and respecting the period for which a permit is valid under section 28.2”.

I’d like to quote a few things I have seen online, as they express better than I can the concerns that I have:

A Progressive Conservative citizen made a few points that I find important:
- Efficiency Should Not Come at the Cost of Our Environment and Local Voice
- Efficiency should not be used as a shield to justify decisions that undermine environmental protection, local expertise, and democratic representation
- Centralized decision-making tends to ignore realities on the ground.
- In the current model, the municipalities involved have direct representation, which is important for local voices, accountability and decision-making.
- “diluting representation removes community input and replaces it with a distant, bureaucratic structure than cannot understand the needs of each watershed, municipality or rural community”
- The current model employs staff who have deep, site-specific knowledge of local hydrology, flood risk, erosion zones, wetlands, and ecosystems. That knowledge is built over decades and is essential during emergency situations such as flooding and extreme weather events.
- Centralizing governance risks disconnecting decision-makers from that expertise, slowing emergency response times and limiting public access to staff who actually understand the land. Conservation Authorities work because they are local. Stripping that away is not modernization; it is regression.
- A large, regionalized model may introduce new layers of uncertainty and delay for builders, developers, and farmers.

I concur with the voices I’ve heard that are concerned by “streamlining” which actually weakens environmental protections, removes local voices, and centralizes power; “governance by shortcut.” Also, “Protecting our environment and respecting local expertise should not be partisan issues. They are responsibilities. Efficiency should never mean less accountability, less science, and less community input.”