1. Remove the requirement…

1. Remove the requirement for budget approval from individual municipal councils for watershed-based programs considered non- mandatory.
In the creation of conservation authorities, the Province recognized that water does not stop flowing at political boundaries and that there are economies of scale through cost sharing. The current provincial proposal undermines the mandate, premise and value of the multi-municipality, watershed-based governance of conservation authorities.
The proposed requirement for additional municipal approvals will consume a far greater amount of effort by municipal and conservation authority staff. It will also cause a needless increase in time expended by municipal councils and conservation authority boards. This requirement would also mean that a conservation authority’s budget would only be approved at the pace of the slowest municipal approval. This could be months into the fiscal year.
This new administrative instrument appears cumbersome at best, and unnecessary red tape at its worst. It transfers components of budget decision making to municipal councils rather than leaving the responsibility with the conservation authority board of directors. It is not clear why a government having the stated intent of reducing red tape and improving efficiencies is creating such a complicated and time-consuming process. Conservation authority boards have direct knowledge of the needs of their individual watersheds, and they have the expertise for determining which watershed management programs and services are needed in order to provide the best assistance to their member municipalities.

2. The Province should continue to invest in the core mandatory programs and services to be delivered by conservation authorities and support CA eligibility for other provincial funding programs
There are currently provincial transfer payments to all CAs for natural hazards (Ministry of Natural Resources and Forestry) and source water protection (Ministry of Environment, Conservation and Parks). The Province’s ‘Made-in-Ontario Environment Plan’ recognizes how issues such as climate change can impact and threaten Ontario’s economic prosperity and the well-being of its people and states that addressing these challenges is a shared responsibility. However, the 2019 Ontario budget slashed 50% of the natural hazards program funding to conservation authorities. This is a clear contradiction to the Environment Plan, particularly given the flooding that occurred right after the funding was cut.

Individual Conservation Authorities are important on-the-ground delivery agents for numerous provincial programs through various means, including special contracts. The eligibility of CAs for these other provincial funding opportunities must not be reduced. Effective delivery of these programs will require increased support from the Province. This includes provincial funding programs such as the Trillium Fund and the Canada-Ontario Agreement for Great Lakes Water Quality.

3. Core mandatory programs be applied to municipal levy or could utilize other sources of revenue.
Given the instability of provincial transfer payments (a reminder, the 2019 cut of 50% to flood control was to an amount that had not changed for roughly 20 years) and additional pressures on municipal budgets, it is essential for Conservation Authorities to have the ability to charge fees and utilize fee revenues. It is important for Conservation Authorities to have flexibility in funding core mandatory programs. For example, funding may be part of the municipal levy or could be from other sources of revenue. It would be helpful for Conservation Authorities to be able to use self-generated revenue to support management of conservation lands.

4. The mandatory programs and services [proposed Section 21.1 (1)], to be prescribed in regulation, include the addition of: Conserving natural resources.
Conservation Authorities play a critical role as watershed and natural resource management agencies. As outlined in the Conservation Authorities Act (CAA), the objects of an authority are to “provide, in the area over which it has jurisdiction, programs and services designed to further the conservation, restoration, development and management of natural resources…” (Sec. 20(1)). Further, for the purposes of accomplishing its objects, an authority has the power to “study and investigate the watershed and to determine programs and services whereby the natural resources of the watershed may be conserved, restored, developed and managed” (Sec. 21(1)(a)). Watershed management has been the foundation for all CA programs and services since the inception of conservation authorities.
Being in nature restores people and helps them to stay active and healthy, reducing health care costs.
Including “conserving natural resources” as a mandatory program and eligible for municipal levy would recognize the important role that Conservation Authorities play. This would be consistent with the “Made-in-Ontario Environment Plan.”

5. The scope of standards and requirements to be prescribed in regulations must capture all key elements of the mandatory program and service area, and must be developed in consultation with conservation authorities, municipalities, and other stakeholders.
Of critical importance will be the development of standards and requirements for each of the core mandatory program areas and what constitutes eligible activities within each of the mandated areas.
The standards and requirements need to be framed to allow the specifics of each Conservation Authority’s jurisdiction. Each Conservation Authority has a different set of natural hazards, with different levels of risk based upon the specific geography of its individual jurisdiction. Specific requirements for individual watersheds will require consultation with the municipalities of that watershed.