Creating a single provincial…

Creating a single provincial regulation that ensures clear and consistent requirements across all conservation authorities while addressing local differences is valuable, however, I have several major concerns about the proposed changes described in the consultation guide. I summarize my concerns and propose solutions to these problems below.

1) Updating the definition of “wetland”

Restricting the definition of a wetland as written is irresponsible and harmful given how wetlands benefit Ontario. Wetlands provide many critical economic, social, and environmental services (Whiteley and Irwin 1986, Zedler and Kercher 2005, Yang et al. 2016). Wetlands improve water quality via water filtration and reduce financial and social costs to homeowners and the government by flood prevention and securing groundwater for human use. A recent study estimated that the wetlands in the Credit River watershed reduce insurable claims for a single flood event by 46% and reduce property damages 17 to 29% (up to $3.5M, the wetlands in the Laurel Creek watershed reduces insurable claims for a single flood event by 18% and reduce property damages 38 to 51% (up to $53M) (Moudrak et al. 2017). Wetlands have never been more important with climate change increasing the frequency of severe weather precipitation events. Ontario should maintain a broad definition of wetlands and must not limit wetlands to where vegetation is “dominated by” hydrophytic plants or water tolerant plants. Rather the definition should mirror the more general definition adopted by the US Department of Agriculture “Land that (1) has a predominance of hydric soils; (2) is inundated or saturated by surface or groundwater at a frequency and duration sufficient to support a prevalence of hydrophytic vegetation typically adapted for life in saturated soil conditions; and (3) under normal circumstances does support a prevalence of such vegetation”.

2) Updating the definition of “watercourse”

Restricting the definition of a watercourse to something where “flow of water regularly or continuously occurs” increases financial risks to Ontario residents. Ephemeral and temporary streams can reduce overland floods by moderating hydrological flow (Todd et al. 2006, Buttle et al. 2013). These features have never been more important with climate change increasing the frequency of severe weather precipitation events. It is therefore beneficial to residents, municipalities, and Ontario to maintain a broad definition that includes permanent, ephemeral, intermittent, and temporary water within the definition of both watercourse and waterbody.

3) The definition of “Hazardous land”

Consider removing “naturally occurring” from the definition to recognize the fact that nearby development changes flooding and erosion risk (e.g., via restricting water infiltration) and needs to be considered when permitting additional developments. A

4) Improved coordination between Improved coordination between Conservation Authorities Act regulations and municipal planning approvals

I do not support exempting developments authorized under the Planning Act from requiring a permit under the Conservation Authorities Act. The two Acts serve two different roles – both of which benefit Ontario residents. The actions undertaken by a municipality can impact downstream residents and must therefore be considered within the broader context of conserving, restoring, developing and managing of natural resources in watersheds (Conservation Authorities Act Purpose).

Buttle, J. M., Boon, S., Peters, D. L., Spence, C., Van Meerveld, H. J., & Whitfield, P. H. (2012). An overview of temporary stream hydrology in Canada. Canadian Water Resources Journal, 37(4), 279-310.

Moudrak, N., A. M. Hutter, and B. Feltmate. 2017. When the Big Storms Hit: The Role of Wetlands to Limit Urban and Rural Flood Damage. Intact Centre on Climate Adaptation

Todd, A. K., J. M. Buttle, and C. H. Taylor. 2006. Hydrologic dynamics and linkages in a wetland-dominated basin. Journal of Hydrology 319: 15-35.

Whiteley and Irwin. 1986. The hydrological response of wetlands in southern Ontario. Canadian Water Resources Journal 11: 100-110.

Yang et al. 2016. Examining water quality effects of riparian wetland loss and restoration scenarios in a southern Ontario watershed. Journal of Environmental Management 174: 26-34.

Zedler and Kercher. 2005. Wetland resources: status, trends, ecosystem services, and restorability. Annual Review of Environment and Resources 30: 39-74.