Halton calls out Province on missing consultations re conservation authorities

Here is a letter and Discussion Paper from all Halton area mayors and Halton Region chair, as Conservation Halton’s formal response to the letter circulated by The Honourable Jeff Yurek, Minister of the Environment, Conservation and Parks to all conservation authorities on August 16, 2019.

Minister Yurek’s letter called for conservation authorities to review and consider their activities and begin preparations to wind down activities that fall outside the scope of their core mandates.

The Conservation Halton Board of Directors met on August 28 to review the matter and as a result, Conservation Halton would like to encourage the Province to meet with conservation authorities as promised to discuss regulations and define core programs through meaningful consultations.

A copy of Conservation Halton’s annual report is available at conservationhalton.ca/annualreport.

August 28, 2019

The Honourable Doug Ford, Premier of Ontario,
Legislative Building Queen’s Park, Toronto, ON M7A 1A1
The Honourable Jeff Yurek, Minister of the Environment, Conservation and Parks,
Ministry of the Environment, Conservation and Parks 5th Floor, 777 Bay St., Toronto, ON M7A 2J3

Dear Premier Ford and Minister Yurek,

We are writing in response to your letter dated August 16, 2019 that was sent to all Conservation Authorities and their member municipalities.

We look forward to engaging with you when you start your promised consultations for creating the definitions and regulations required to move forward with your agenda to define what is included in the core mandate of the Conservation Authorities.

To assist with such promised consultations, we are providing the attached discussion paper for your consideration, as well as Conservation Halton’s 2018 Annual Report (Appendix A).

We believe Conservation Halton is efficient, transparent and accountable. Specifically:

  • Conservation Halton’s programs and services are within their mandate as defined by the CA Act. There are no programs that divert focus from helping municipalities grow and manage risks associated with flooding hazards.
  • The Board of Directors of Conservation Halton is made up of 70% elected officials, including three mayors. The Board approves all business plans and budgets. Furthermore, Conservation Halton engages in detailed discussions with municipalities before the budget is presented to Regional Council.
  • Conservation Halton uses zero tax dollars to manage and operate Conservation Areas and generates a surplus which offsets significant costs (about $2.5mil in 2018) that would otherwise be funded through Municipal tax levies. Municipalities have no desire to take over these responsibilities.
  • Conservation Halton employs approximately 800 seasonal workers, mostly youth, and supports local businesses and tourism. These 800 jobs are at risk with the apparent direction of the Province. Furthermore, CH attracts 1.2mil visitors annually that would be 1.2 million disappointments should CH lose its ability to manage these cherished assets.
  • Conservation Halton has already committed to service delivery improvements. Planning and permitting services are delivered without mission creep, within the scope of the CA Act and Municipal MOUs. Turnaround times are adhered to and reported on with complete transparency.

We hope you find this letter and the discussion paper helpful as you map out a meaningful consultation process. We strongly recommend engaging in pre-consultations with Conservation Halton and other CAs to ensure we are working together to define the governing regulations and to continue our long­standing partnership.


Gerry Smallegange, Chair, Conservation Halton Board of Directors
Gary Carr, Halton Regional Chair
Mayor Gordon Krantz, Town of Milton
Mayor Rob Burton, BA, MS, Town of Oakville
Mayor Rick Bonnette, Town of Halton Hills
Mayor Marianne Meed Ward, City of Burlington


Conservation Halton, along with other CAs, have been anticipating provincial consultations for the development of regulations that will define these mandatory programs and services and what specifically is captured under them. As of today’s date, Conservation Halton does not know the details of specific programs and services that are mandated. For example, will water quantity monitoring to support flood forecasting and floodplain mapping to support hazard regulations be considered part of the mandatory programs and services? Will tree planting and stewardship initiatives in our watersheds that slow down flood waters be considered part of the mandatory programs and services? Will broader environmental monitoring be considered part of mandatory programs or will the Province assume the responsibility and costs of undertaking monitoring in an efficient and responsive manner?

Responsible Finances and Efficiencies
At Conservation Halton, we made a commitment three years ago to develop a sustainable, long-term financial strategy. As a result, our operating budgets have been at or below the rate of inflation over the past two years. Our capital expenditures were restructured to ensure a disciplined approach to capital allocation towards maintaining our four dams, flood conveyance channels and other structures in a state of good repair. Those funding reserves have been established with support and guidance from Halton Region.
Additionally, we use no tax dollars to fund our conservation area operations or capital investments, and the returns we generate at our conservation areas help offset tax supported program costs. We now have one of the lowest proportion of tax revenues in Ontario, with municipal taxes funding 34% of our annual budget, while generating 59% through our own conservation area operations. Provincial revenues will make up a meagre 1.35% of our annual operating budget for the upcoming year.

By taking away the ability for CAs, and specifically Conservation Halton to develop financial partnerships with municipalities and develop revenue-generating programs, not only will you decrease the employment opportunity for youth in the region and increase the tax payers’ bill for core programs but you will also limit, if not eliminate, our capacity to invest in these conservation areas to make them more accessible for a rapidly growing population.

Conservation Halton provides a large variety of benefits (all self-funded) to the Halton community; the most notable one is that we support youth employment through our 800 seasonal employees, most of which fall within the ‘youth’ segment, in the Region and provide $4.3mil in seasonal wages. In 2018, our recreation programs exceeded our revenue generation targets with 7.7% growth.

We will continue to work with our member municipalities to finalize our 2020 budget and the scope of the activities that are included therein. We would appreciate the Province confirming its continuing financial support for the Source Protection program until such time as the transition period is completed to avoid any in-year budget adjustments. We have already had to contend with the mid-year loss of $145,277 of Section 39 transfer payment from the Province for one of our mandatory programs – hazards management.

Transparency and Accountability
We are very proud of how Conservation Halton works with our municipalities to align our work with their needs and meet the targets that are set out. Equally important is our commitment to accountability and transparency, not just in terms of program costs but in terms of service delivery standards that are clear and quantifiable. We lead every budget cycle request with a review of how we performed the previous year and who benefited from our programs.

Furthermore, we clearly lay out how our programs are funded:

  • By municipalities as part of our regulatory responsibilities,
  • By municipalities through municipal MOUs and other sources such as grants, e.g. plan review, education, stewardship, environmental monitoring. MOUs with Halton area municipalities were renewed earlier this year after a two-year review, and
  • Non tax supported core programs that are entirely self-funded, e.g. recreation events, operations and capital.

We therefore do not abuse our power to levy but instead work with our municipalities to ensure our performance warrants tax levy funding and that our priorities are aligned. Our latest Annual Report clearly details our performance. If desired, our detailed business plans for every program and service can be shared as well.

Focus on Core Mandate
Conservation Halton is focused on our core programs and more importantly, on ensuring that the cost, time required, and scope of those programs are aligned with regulations, where applicable. For instance, we publish turnaround times for all our permits. As of the beginning of 2019, we issued 97% of our minor permits within the prescribed 30 days (provincial target is 80%). We have quarterly meetings with BILD and local agriculture groups to discuss process improvements and find solutions where needed.

As per our strategic plan, here are a few examples from the year that show how our efforts are focused in the right areas while adding value for residents, businesses, municipalities and other stakeholders.

  • Public Safety: Our watershed monitoring network has expanded from 16 hydrometric stations to 35 digitally connected stations using Internet of Things (IOT) devices to collect, analyze and deliver insights from our data to predict weather impacts on riverine conditions and inform the public and our partners through accurate, timely flood status updates and warnings. Our goal is to improve our accuracy and lead time for storm events. We also launched a comprehensive update of our floodplain mapping to identify areas susceptible to flooding and help reduce flood risk in our communities through proactive planning and restoration.
  • Development Permits and Planning: We’ve continued to work hard in delivering timely, predictable, cost-effective services across all our products and services. Through ongoing engagement with developers, process re-engineering and a desire to re-write the narrative around customer value, we have exceeded our stretch goal of processing 95% of minor permits within 30 days and continue to work with our development review partners to improve service delivery on technical reviews and planning applications, also ensuring that we are not commenting on matters beyond our scope or changing the goal posts for customers.
  • Recreation and Management of Conservation Authority Lands: For the second year running we welcomed over 1 million visitors to our conservation areas and launched several new programs and events, such as the Hops and Harvest Festival showcasing local breweries and food vendors. We continue to offer innovative, engaging, family-friendly experiences to our growing communities through our network of seven conservation areas. Our brand is strong, and we are committed to leading the market when it comes to outdoor recreation, wellness and leisure within our watershed. It bears repeating that our conservation areas and all festivals (including maple syrup for instance) are 100% self-sustaining financially. We are proud of how responsibly we have monetized our assets to generate revenues while creating tremendous value and employment opportunities for our local communities.
  • Education: We hosted over 64,000 students from local schools at our outdoor education centres, including at our newly built archaeology room in the Wolf Clan Longhouse at Crawford Lake. We partnered with other organizations on 144 occasions to help engage residents and students alike around Climate Change and other environmental events, because if we can’t tell an engaging story to raise awareness, then we can’t make the kind of collective impact that is necessary for our communities to remain prosperous and resilient.
  • Environmental Restoration: For our communities to be sustainable we must balance the impacts of growth and development with improvements to green infrastructure, ensuring our water, land and air can sustain our activities today and in the future. In 2018 we monitored and analyzed data from 176 monitoring stations, engaged 11,000 residents in hands-on stewardship activities, managed close to 10,000 acres of natural lands, planted thousands of trees (over 4 million to date), carried out 43 environmental improvement projects and leveraged every $1 invested in restoration projects by Conservation Halton to $15.92 worth of improvements through public/private sector partnership funds.

Next Steps
We don’t want increased risk to public safety or increased liabilities to the Province, municipalities and conservation authorities due to lack of funding for critical programs and services. The current level of provincial investment in CA flood operations and the funding available to maintain aging dams is inadequate, and it is putting a strain on municipal finances. We strongly encourage the Province to undertake meaningful, focused pre-consultations with CAs prior to consulting all stakeholders around the regulations you are working on. We feel strongly that through these pre-consultations we can help the Province gain a clear understanding of what CAs do, and we can assist the Provincial Government in fulfilling its commitment to Ontarians.

We believe that the Conservation Halton Board and participating municipalities should be allowed the time to consider the full implications to their watersheds before reducing any programs or freezing fees and levies. The regulations that will outline the agreements necessary between municipalities and CAs will increase transparency on what CAs are equired to do, what is discretionary and how it impacts the municipal levy. Again, we would like to focus on the development of the regulations that will provide the consistent framework for what the government wants to do.

In conclusion, the new CA Act directs our Board members (Section 14.1) to act honestly and in good faith with a view to furthering the objectives of the Authority. That is just what our Board intends to continue to do. The elected officials and citizen appointees who make up our Board of Directors allow us to work closely with each of our municipal partners to deliver a variety of locally supported programs and services valued by residents. We look forward to working with the province to define the governing regulations and to continuing our long-standing partnerships with both the Province of Ontario and our local municipalities.

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