Thank you for the…

Thank you for the opportunity to comment on proposed updates to the Ontario Wetland Evaluation System as outlined in ERO 019-6160 and as related to Bill 23, the proposed More Homes Built Faster Act.

As noted in our November 16th submission to the Legislative Assembly of Ontario, Standing Committee on Heritage, Infrastructure and Cultural Policy on Bill 23, the Ontario Public Health Association (OPHA) fully supports the need for Ontario to find more affordable housing opportunities for its residents and create healthy, equitable and climate-resilient communities. At the same time, it is vital that these processes, including legislative changes, are undertaken in a manner that reduces the risk of inadvertent harms and inequities to the health and climate resiliency of communities.

Public health agencies have long recognized the connections between healthy environments and population health, and thus the importance of healthy public policy across all sectors to strengthen health protection and equity. This includes policies related to housing, the built and natural environment, land-use planning, climate-resiliency including mitigation and adaptation, and ecosystem protection.

OPHA supports action to create more rental and ownership types of housing that prioritizes affordable, healthy and environmentally sustainable housing. This encompasses housing that is resilient to the impacts of climate change through measures such as wetland protection. Increasing housing supply through actions such as intensification, higher density and transit-oriented development can be health and equity promoting, without compromising other vital attributes required for healthy and equitable communities including: protection of wetlands, access to, and protection provided by, parkland and other greenspace; access to affordable, sustainable and active transportation; and healthy, energy-efficient housing units.

OPHA urges the Government of Ontario to pursue affordable housing opportunities through measures other than changes to wetland protection, and to:

1. Refrain from weakening the Wetland Evaluation System process. This is a misguided effort to increase housing supply.
2. Maintain wetland protection as a means to protect current and future housing stock from natural and climate related hazards including flooding.
3. Allow additional time for municipalities, conservation authorities and other stakeholders to thoroughly review and provide meaningful feedback on changes to the Wetland Evaluation System.
4. Rely on the scientific evidence that has established the vital importance of wetland units of all sizes, and as part of wetland complexes, to Ontario’s natural heritage system, human health and climate-resiliency.

OPHA is extremely concerned that the Government of Ontario is considering changes to wetland protections as a means to increase housing supply. Wetlands are part of the natural ecosystem and perform vital services that are essential to human health including regulating air and water pollution, flood protection, erosion control, carbon sequestration, provision of nutritious food and clean water, surface temperature regulation, and several cultural, recreational, physical and mental health benefits.

OPHA does not support changes to the Wetland Evaluation System that weakens wetland protection. This will have negative impacts from a climate resiliency and health perspective, increasing health risks and disproportionately impacting equity-deserving groups who have less adaptive capacity to flooding and climate-related risks. The proposed changes to wetland and other natural heritage policies that emphasize growth expansion and rural residential development will result in the loss of diverse and mature ecosystems. This will have immediate and long-term environmental impacts. In addition, a decrease in the amount of wetlands represents a decrease in the amount of impervious services, putting direct and immediate strain on municipal stormwater management infrastructure, increasing flood risks and increasing exposure to climate-related health hazards.

OPHA is concerned that the short 30-day ERO opportunity for comment does not allow adequate time for the public, agencies and other stakeholders to consider the implications of changes to the Ontario Wetland Evaluation System, and how these changes may weaken wetland protection in terms of environmental and human health protection. For example, removing statements from the Ontario Wetland Evaluation System text that acknowledges that “certain information, particularly about the presence of rare species and about hydrological functions, may be lacking even after the evaluation is completed”, and the subsequent recommendation that “more information should be obtained before making decisions about the types of land uses in the vicinity of evaluated wetlands” seriously risks the ability of municipalities, conservation authorities and other stakeholders to make evidence-informed decisions for ecological protection and health protection. This can have the added consequence of increasing financial liability when wetland degradation leads to climate-related flood impacts.

As noted in the Independent review of the 2019 flood events in Ontario report commissioned by the Government of Ontario the first core component of emergency management is prevention, which includes “… actions taken to prevent flood-related emergencies or disasters from occurring, and includes land use planning and regulatory restrictions to keep development out of the floodplains and other hazardous areas. While we cannot prevent flooding from occurring, keeping people and property out of flood-prone areas helps ensure naturally occurring flood events do not result in local emergencies.” With clear evidence that climate-related heavy rainfall events will continue to increase, it is counter intuitive to remove wetland protections that allow development to occur in these sensitive areas.

OPHA is also concerned that changes to the Ontario Wetland Evaluation System related to wetland complexes will further erode ecosystem protections for human and environmental health. Given that wetland complexes are a group of wetland units that are functionally linked to one another, it is important that re-evaluation of single wetland units considers the entire wetland complex. OPHA is very concerned that the definition of “wetland complex” is proposed to be removed from the Ontario Wetland Evaluation System, and that smaller, vital wetlands will lose their protection.

Recent research examining wetland loss and stormwater management ponds in southern Ontario found that many lost wetlands have been replaced with stormwater management ponds of smaller total area and with reduced overall ecological function, pointing out that the latter “are designed to manage urban stormwater and contaminants, but only provide limited ecosystem services.” Given their critical ecosystem function, including flood mitigation, this study emphasized the need for greater protection for wetland ecosystems in urban and peri-urban areas, and to conserve wetlands that still exist in growing municipalities, especially smaller wetlands.

OPHA does not support the proposed removal of wetland complexing or the inability to re-evaluate existing complexes. These changes would expose provincially significant wetlands and wetland complex lands into consideration for urban boundary expansion. Partnered with the described, but not yet outlined, changes to the Provincial Policy Statement, the proposed changes could significantly exacerbate local flooding, erosion issues and biodiversity loss.

Greater consideration of the scientific evidence, including direct and indirect human health impacts, must be incorporated into the decision-making process affecting natural ecosystems including wetlands. These essential natural features work together to promote the development of healthy and complete communities; protecting natural heritage, water, and agricultural systems; and promoting a culture of conservation. They can help the province meet its climate change targets by providing a carbon sink and helping buffer against flooding.

OPHA urges the Government of Ontario to take action to increase rather than water down wetland protection, and to use current scientific evidence to effectively assess this protection. This evidence includes the importance of wetland units of all sizes, and as part of wetland complexes, to Ontario’s natural heritage system, human health and climate-resiliency. We encourage the province to prioritize building in existing designated development areas and increasing density to increase housing stock more effectively with co-benefits for health, environment and economy.

OPHA appreciates efforts to encourage the supply of affordable housing including affordable rental housing; however, this must not be at the expense of wetland protection. This is counter to the equity-promoting and environmental justice measures that Ontarians expect from climate adaptation planning, and the government of Ontario’s commitment to strengthen the province’s resilience to the impacts of climate change and keep communities healthy and safe.

Thank you for considering our concerns and recommendations with respect to proposed changes to the Planning Act as outlined in ERO 019-6160. We would welcome the opportunity to meet with the government to discuss the proposed changes and solutions that address concerns related to this proposed legislative change.

i EcoHealth Ontario resources. https://www.ecohealthontario.ca/resources
ii https://files.ontario.ca/mnrf-english-ontario-special-advisor-on-floodi…
iiiOntario Wetland Evaluation System.vs 3.2. 2013 https://dr6j45jk9xcmk.cloudfront.net/documents/2685/stdprod-103924.pdf
iv Birch et al. 2022. Trends and predictors of wetland conversion in urbanizing environments https://www.sciencedirect.com/science/article/pii/S0301479722002961
v Ibid
vi https://news.ontario.ca/en/release/57998/ontario-launches-first-ever-cl…

Sincerely

John Atkinson
Executive Director
Ontario Public Health Association

More about the Ontario Public Health Association
OPHA has established a strong record of success as the voice of public health in Ontario. We are a member-based, not-for-profit association that has been advancing the public health agenda since 1949. OPHA provides leadership on issues affecting the public’s health and strengthens the impact of those who are active in public and community health throughout Ontario. OPHA does this through a variety of means including advocacy, capacity building, research and knowledge exchange. Our membership represents many disciplines from across multiple sectors.
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