4 December 2025
Hon. Todd McCarthy MPP
Ministry of the Environment, Conservation and Parks
College Park, 5th Floor, 777 Bay Street
Toronto, ON M7A 2J3
Re: Submission to ERO #025-1257 re Proposed Consolidation of Conservation Authorities
Dear Minister McCarthy:
On behalf of the Board of Directors of the Rescue Lake Simcoe Coalition (RLSC), I am writing to formally submit our comments to the Environmental Registry of Ontario (ERO) regarding the proposal to consolidate Ontario’s thirty-six conservation authorities into seven mega-regional entities.
RLSC is the leading citizen-based environmental organisation dedicated to the protection of Lake Simcoe and its watershed. We work closely with local municipalities, partner organisations and the public to advance science-based freshwater protection. As Board Chair, I write to express our concern with the proposed consolidation, particularly as it relates to the continued implementation and integrity of the Lake Simcoe Protection Plan (LSPP).
1. Consolidation risks diluting the Lake Simcoe Protection Plan
The LSPP is the only watershed-specific, legislated protection plan of its kind in Ontario. It is grounded in place-based science and decades of monitoring, modelling and stakeholder engagement. Its success depends on continuous, locally informed scientific work and collaboration between municipalities, the conservation authority and the province.
If the Lake Simcoe Region Conservation Authority (LSRCA) were absorbed into a much larger conservation authority—with responsibilities stretching across two Great Lakes and a vast geographic area extending into Northern Ontario—Lake Simcoe would, in effect, become one department among many inside a large, multi-watershed organisation. That structural shift risks diluting the focused attention the LSPP requires and currently receives from LSRCA. A larger, more generalized Authority cannot maintain the depth of local focus that the LSPP demands.
2. Loss of local scientific expertise will impede monitoring and long-term recovery
Lake Simcoe’s challenges are acute and distinct:
- Phosphorus levels remain approximately double the LSPP target;
- Chloride concentrations continue to increase steadily, driven by road salt;
- Climate-change pressures—including intense rainfall—heighten flood risks; and
- Natural-heritage cover is below recommended thresholds.
These conditions require ongoing monitoring performed by scientists who understand Lake Simcoe’s tributaries, groundwater, shoreline dynamics and land-use pressures. Under consolidation, this specialised local expertise risks being redeployed, pooled or subordinated to broader multi-regional priorities. There is also a risk of economic impact. The value of ecosystem goods and services provided by the Lake Simcoe watershed is estimated at more than $975 million per year with over $200 million annually from tourism alone.
3. Governance and accountability may be weakened
The current LSRCA governance model—anchored in representation from watershed municipalities—ensures transparency, accountability and responsiveness to local conditions through locally elected and accountable municipal elected officials.
Under the proposed amalgamation, it is unclear how governance would be handled, but the indications are the Board of Directors would not have the same local links as the LSRCA does now, such that our regions’ municipal representation would be drastically reduced, diluting the voices of communities most affected by Lake Simcoe’s health. A decision-making authority responsible for multiple Great Lakes watersheds would be inherently more distant from local issues. Accordingly, municipal partners would have less influence over watershed priorities such as stormwater management, natural heritage protection and growth-planning impacts or influencing provincial mandated development into rural areas rather than intensification. A large-scale authority cannot deliver the same degree of local responsiveness or accountability.
4. Increased costs and operational complexity
While the stated rationale for consolidation is efficiency, evidence from public-sector restructuring suggests the opposite. The integration of information systems, regulatory frameworks, monitoring programs, staff teams, governance structures and geographically dispersed operations may increase costs, not reduce them. Efficiency cannot be achieved when an operating area becomes so vast that internal coordination becomes a challenge in its own right. It is also our belief that the LSRCA is one of the more efficient, modern Authorities in the province.
5. Recommendation
For these reasons, the RLSC respectfully urges the Ministry to:
- Exclude the Lake Simcoe Region Conservation Authority from the consolidation framework, recognising its legislated responsibilities under the Lake Simcoe Protection Act and Plan.
- Maintain and enhance local scientific, technical and enforcement capacity within the Lake Simcoe watershed.
- Ensure that any provincial reforms strengthen, rather than weaken, the implementation of the LSPP.
- Commit publicly that the LSPP’s monitoring, reporting and adaptive-management framework will not be compromised in this process.
Conclusion
As water quality pressures mount across southern Ontario, we should be strengthening environmental policies. The LSCRA and its shoreline municipalities have been instrumental in making some noteworthy progress even without the needed sustained provincial and federal investment in LS. We feel that this consolidation will put this progress at risk.
Lake Simcoe is one of Ontario’s largest inland lakes, one of its fastest-growing regions and the only watershed with its own legislated protection plan. The proposed amalgamation poses risks to the lake’s long-term health and to the accountability structures that safeguard it.
We urge the government to maintain the LSRCA as a distinct, locally accountable conservation authority with the scientific, technical and governance capacity needed to fulfil the LSPP.
Thank you for considering our submission. We would welcome the opportunity to meet with you or your staff to discuss these concerns further.
Sincerely,
Jennie Ucar
Chair, Board of Directors
Rescue Lake Simcoe Coalition
cc: Hon. Caroline Mulroney, MPP for York—Simcoe
Hon. Stephen Lecce, MPP for King—Vaughan
Hon. Doug Downey, MPP for Barrie—Springwater—Oro-Medonte
Hon. Michael Parsa, MPP for Aurora—Oak Ridges—Richmond Hill
Hon. Jill Dunlop, MPP for Simcoe North
Hon. Andrea Khanjin, MPP for Barrie—Innisfil
Hon. Laurie Scott, MPP for Haliburton—Kawartha Lakes—Brock
Brian Saunderson, MPP for Simcoe—Grey