ERO 025-1257: Ontario is Redrawing the Conservation Authorities. Who is Holding the Pen?

If you’ve ever walked through one of the Red Pine plantations that dot the Oak Ridges Moraine (ORM), you’ve seen the legacy of an earlier crisis.

By the early 20th century, large swathes of southern Ontario were logged, razed, over-grazed, and eroded into a near-desolate landscape of sand dunes and frequent local dust storms. On the ORM, conservationists responded with ambitious reforestation campaigns and, eventually, with a new regime that managed our natural assets by watersheds rather than by political boundaries.

That idea became Ontario’s Conservation Authorities (CAs). For nearly 80 years, they’ve been the hand behind flood protection, forest restoration, and source-water protection across the Greater Golden Horseshoe. It’s also the CAs that are facing Ford Nation’s axe yet again.

The Environmental Registry of Ontario posting, “Proposed boundaries for the regional consolidation of Ontario’s conservation authorities” (ERO 025-1257), proposes collapsing 36 CAs into seven large regional bodies and creating a new Ontario Provincial Conservation Agency to provide “centralized leadership” and oversight. Most of the notice is devoted to maps, watershed descriptions, and broad claims about fixing “fragmentation,” “inconsistent timelines,” and “duplication,” along with high-level criteria for drawing the new boundaries. What it omits are concrete details on governance. The ERO posting makes no mention of how boards will be composed, how many members municipalities may appoint, whether and how provincial appointees will sit, who will chair these bodies, or how conflicts with the new provincial agency will be resolved.

Beyond a single vague assurance that regional CAs will “remain independent organizations operating with municipal governance and oversight,” the province is effectively proposing to dissolve our current bioregional governance systems and make the legislative details public after the fact.

Silence Speaks

Currently, the CAs are overseen by municipal representatives. Take, for instance, the Toronto and Region Conservation Authority (TRCA), which oversees much of the western and central ORM. The TRCA Board of Directors is made up of 28 members appointed roughly proportionally by participating municipalities, including Toronto, York, Peel, Durham, and Adjala-Tosorontio. Those directors are largely municipal councillors who face re-election every four years. While it isn’t a perfect system, it does serve a set of key functions:

• Democratic appointment and removal: Board members are directly accountable to councils and, indirectly, to residents.

• Local knowledge: Councillors bring local knowledge of flooding, development pressures, and community needs.

• Shared ownership: When municipalities are around the table, there is at least some balance between provincial priorities (housing targets and infrastructure) and local responsibilities (providing baseline protections from natural hazards).

ERO 025-1257 neglects this entire democratic context. We’ve seen this move before. From slashing Toronto’s council in half, to shifting municipal control through strong-mayor powers, to installing provincial supervisors over elected school boards, the Ford government has repeatedly centralized its control over regional matters by thinning out local, elected representation. Given the recent and ongoing provincial interference in environmental planning, from the Greenbelt scandal to the repeated cuts to the Conservation Authorities Act, it is impossible not to see this next move as a power shift toward more provincial appointees and fewer municipal voices.

“Surplus” to whom?

Governance isn’t the only silence. The posting is also remarkably quiet about land.

Collectively, Ontario’s CAs are the second-largest public landowners in the province after the Crown, managing roughly 146,000–150,000 hectares of forests, wetlands, moraines and other natural systems. These lands include many of the trail networks, forests, and valleylands that people rely on for their local recreation needs.

If you consolidate 36 corporate bodies that own land into seven new ones, you trigger a long list of legal and administrative questions:

• Who will own what? Will land titles be transferred to the new regional CAs? To the new provincial agency? Some mix of both?

• What counts as “surplus”? In every restructuring, there is pressure to rationalize land holdings. Without strong safeguards, we risk seeing core conservation lands quietly reframed as “excess” assets.

• What legal tests will apply to disposals or swaps? Right now, each CA has its own land acquisition and disposition policies, often written to keep conservation lands in public ownership unless strict conditions are met. Will those policies survive consolidation, or be replaced by a uniform, weaker provincial standard?

• Who has standing to object? If a beloved local forest or floodplain is slated for sale under a new regional regime, will local municipalities and residents have clear, enforceable rights to challenge that decision?

None of these questions is answered in ERO 025-1257. They aren’t even asked. For a proposal that reorganizes the second-largest public landowner in Ontario, that silence should speak volumes.

From Local Stewardship to Provincial Control?

On paper, the government insists that regional CAs will continue to focus on natural hazards, watershed health, and source-water protection. But process shapes outcomes.

A process where boundaries are drawn at Queen’s Park, where an unelected provincial agency sets the tone, and where substantive legislative details are completely absent is a process that could easily drift from local, watershed-based stewardship toward centralized, politically driven control.

That matters for the ORM and the entire Greenbelt Area, where Conservation Authorities have often been the last line of defence against short-sighted land-use decisions. When municipal councils waver, when their expertise is lacking, and when they need a baseline to judge best practices, it is the CAs’ technical staff and boards who insist that floodplains are not safe building sites, that wetlands are not “vacant land,” and that forests are infrastructure, not surplus lands sold off to insiders.

The Pines

The rows of Red Pine that cross the ORM  should be a stark reminder of how badly things can go wrong when land and water are treated as expendable. A century later, these forests are still being actively managed to encourage succession and recreate the ecological richness that once flourished in southern Ontario.

They are also a reminder that public institutions like our Conservation Authorities are not expendable. They were created to serve a public good. They were created to stop short-sighted economic or political gain from jeopardizing our long-term futures. If we allow CA governance, land base, and local accountability to be quietly rewritten under the banner of efficiency, we risk unravelling that legacy.

The ERO 025-1257 comment window is open until December 22, 2025. If you care about the ORM, the Greenbelt, or simply the security of your own community in the face of floods and climate change, you need to speak up before the ink is dry and before the entire structure of conservation in Ontario is rewritten.