We are a group of leading…

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Building for Sustainable Value Centre, Ivey Business School, Western University

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We are a group of leading professors and researchers working on business sustainability through cross-disciplinary research, leadership programming and community engagement. We have concerns regarding the costs associated with the proposed changes to the Ontario Wetlands Evaluation System.

1) Economic Benefits of Wetland conservation

There are several economic benefits to preserving wetlands rather than developing them. According to scientists and economists, the value of services and goods provided by global ecosystems, such as wetlands, amounts to about USD 33 trillion. Wetlands help stimulate many industries, such as fishing, recreational activities, hunting (under specific circumstances), and others. Anglers, hunters, trappers, and recreational sport shooters spent $6.5 billion in Ontario in 2019. They contributed $4.7 billion (0.6%) to Ontario’s GDP and supported 36,900 jobs. The health of these local industries is dependent on the health of wetlands. This demonstrates the economic activity generated for Ontario by wetlands remaining undeveloped. Thus, wetlands are indeed much more for economic purposes than most would think.

2) The Consequences of a Looser Wetlands Definition

This regulation removes “Cluster wetlands,” opening the door to evaluating each wetland individually and to develop on them. Wetlands are complex and some of the most productive ecosystems on the planet. They are also one of the most endangered, as over 70% percent of wetlands within settled regions of Canada have been lost or degraded. The provincial government is receiving comments on a proposed amendment to the Greenbelt Area boundary. It is essential to consider what the loss and development of these lands mean for local communities across Ontario. For example, wetlands loss is associated with both a decrease in local water quality and with mitigating and preventing flooding. Therefore, communities that have their wetlands developed into new housing may experience issues with local water quality and see increases in flooding.

3) Wetlands Provide Cheap Flood Protection

Changing how wetlands are defined and evaluated economically affects municipalities and the province. Loosening protections for wetlands will allow for low-rise real estate development to occur. Municipalities tend to fund 20% of the capital costs but are responsible for their maintenance. Over time, the costs of infrastructure services, e.g., streetlights, wastewater, etc., get passed on to ratepayers. They become costly for municipalities to benefit from over the long term, given sprawling low-rise developments.

The proposed regulation will remove wetlands’ benefits for flood protection, water filtration, carbon sequestration, and recreation, which are considered ecosystem benefits. A University of Waterloo study valued the ecosystem system services of wetlands in southern Ontario to be worth $9,995 per hectare per year. Since wetlands’ benefits vary from watershed to watershed, it is worth considering adjusting such a benchmark according to the area. For instance, wetlands in the Lake Simcoe watershed have ecosystem benefits worth $11,172 per hectare per year. Thus, the government should consider the economic benefits of loosening this regulation against these economic benchmarks.

4) Wetlands and Climate Change Protection

Wetlands are a vital asset in the fight against climate change. The simplification proposed in this regulation may prove detrimental to Ontario communities in terms of resilience to climate change. In 2021, the Insurance Bureau of Canada (IBC) estimated that weather-related events due to climate change cost Canadians around $2.1 billion in insured damages. This figure could reach up to $139 billion by 2050. Environment and Climate Change Canada scientists reported in 2020 that climate change has made rainfall more extreme and storms with extreme rain more frequent. For instance, Toronto had significant rainfall events in 2017 and 2018.

Meanwhile, communities are funding wetland protection efforts in coastal areas thanks to their benefits in mitigating the impacts of severe weather events. For instance, Swiss Re is working with Mexican authorities to underwrite an insurance product protecting its coral reefs, recognizing the economic benefits of protection. Therefore, removing wetlands for development is highly detrimental to resilience to climate change. The irony is that this regulation is being changed to support the government’s plan to increase homeownership. However, the long-term consequences of simplifying how wetlands are defined may lead to homeowners having increased exposure to adverse weather events like flooding.

5) Lack of Fairness for Stakeholders

The regulation proposes removing conservationists as part of the OWES. Their proposed lack of involvement is concerning, given many conservationists’ expertise on their local wetlands. The regulation eliminates the role of conservation professionals, from conservation organizations to MNR specialists (biologists, hunting regulators, and anglers). It also removes the need for evaluators to give results of an evaluation to conservationists. Such measures further prove that the proposed regulation is trying to limit the voice of conservationists and other stakeholders. This means risking losing species on wetlands, which act as tourist attractions within and outside Ontario.

6) Repealing Rare Species Protections

Along with the potential destruction of valuable wetland infrastructure, the proposed regulation repeals various protections for Ontario’s rare species. Most notably, the proposal would cut the role of MNR workers and conservationists in preserving rare species and allow the sale and removal of wetlands containing rare species that were previously protected. Wetlands, including those on private land, play an essential role in preserving rare species.

Rare species could only be addressed if it is immediately apparent that using a wetland as their habitat is a deliberate attempt to open space for development. A wetland that is lost is not easily replaced. A review of 59 studies of biodiversity recovery by Pezzati et al., 2018 found that recovery times varied from less than one year to 10,000 years with active restoration efforts. The risk to Southern Ontario is especially significant. The Carolinian life zone, an ecoregion extending from Windsor to Toronto, is Canada’s most biodiverse region. It comprises only 0.25% of Canada’s total land but is home to 50% of its species at risk.

7) The Risks of Low-Density Housing in Flood-prone Areas

Many solutions to the housing issue do not involve destroying our valuable wetland regions. Ontario mainly builds low-density single-family homes, with the province building 8,671 single-family units in 2021 alone. These low-density homes fail to solve Ontario's housing shortage. They are increasingly unaffordable due to rising housing prices in Canada and are inefficient land use. Furthermore, it has been estimated that only 50,000 new homes of these single-family homes may be built within the next decade, which is certainly not enough to solve Ontario’s current housing shortage. Therefore, the Ford government should commit to building higher-density housing that is more cost-effective in using existing infrastructure than facilitating building more low-density housing. This is unaffordable to many Ontarians and would now destroy various wetlands. They cannot be replaced once lost.


Scientists and economists quantify the world’s value of ecosystems and natural capital

U.S. Environmental Protection Agency fact sheet on the economic benefits of wetlands

Study commissioned by the Ontario Federation of Anglers and Hunters (OFAH) and the Canadian Sporting Arms and Ammunition Association (CSAAA) quantifies the economic benefits of their activities

Ducks Unlimited study quantifies the impacts of wetlands loss

Ducks Unlimited and University of Guelph professors examine water quality effects of wetland loss and restoration

Academic paper examining the wetlands, flood control and ecosystem services in a drainage basin

Report on how to structure municipal financing to better support density

University of Waterloo study valuing southern Ontario’s ecosystem system services

The value of watershed ecosystem services in Lake Simcoe basin

Severe Weather in 2021 Caused $2.1 Billion in Insured Damage

The biodiversity recovery and transformation impacts of wetland restoration efforts

Environmental Defence statement and analysis of Bill 23

CMHC report on Canada’s housing supply shortage

Swiss Re working with the Nature Conservancy and Mexican authorities to protect coral reefs

News report about more extreme rainfall according to Environment and Climate Change Canada