The proposed changes to the…

The proposed changes to the Ontario Wetland Evaluation System (OWES) are not so much about housing as they are about gutting wetland protections. The OWES has been in place since 1983 and has served the province well, providing a clear picture of which pockets of Ontario we need to protect in order to maintain a well-balanced and healthy ecosystem that can continue to provide not just fresh drinking water to millions but also the natural infrastructure necessary to sustain all life. We are a part of nature; we do not stand apart from it. We rely on it. Sometimes we need to remind political parties of this fact of life, and now is one of those times.

The proposed changes to OWES seem to arise from an erroneous assumption that wetlands are somehow a barrier to increasing Ontario’s housing supply, affordable or otherwise; therefore, encroaching on existing identified wetlands by re-assessing their status and their boundaries has become necessary.

Wetlands are not the problem. A shortage of land isn’t either. Neither are bottlenecking the supply of housing in Ontario. Ontario’s own Housing Affordability Task Force has explained as much in its 2022 report. For example: the amount of greenfield land already designated for development and added to municipal settlement boundaries (but still undeveloped) far exceeds what is needed to meet long-range housing targets. And that includes the more than 86,000 acres within the Greater Toronto and Hamilton Area alone.

One of the most egregious aspects of the proposal is the removal of Ministry oversight. To quote the exact wording, “Make changes to better recognize the professional opinion of wetland evaluators and the role of local decision makers.”

To virtually unravel any wetland oversight that currently exists is as baffling as it is ill-conceived. Is the Ministry of Natural Resources and Forestry (MNRF) actually proposing to remove itself from any involvement in Ontario’s wetland evaluation process? Will there be no central body assigned to coordinate or approve evaluations? Or to ensure that information about wetland designation is publicly accessible? And who are these new “evaluators” and “local decision makers”?

Well, municipalities for one. Offloading approval authority to municipalities is not wise. They do not and will not have the decades-long expertise or experience of MNRF staff in making assessments, offering guidance or understanding the full impact of their decisions. Combine this with the fact that due to Bill 23’s proposed limitations to the input of our 36 Conservation Authorities in matters relating to approvals, wetlands will be even more vulnerable to detrimental development.

Furthermore, if this also leads to developers bringing in their own evaluators (as would be the case for wetland units formerly part of a Provincially Significant Wetland complex but re-evaluated individually, as I understand it), is that not tantamount to inviting the fox into the henhouse? And who will be able to intervene on behalf of the public – the citizens of Ontario - regarding an evaluation of questionable merit?

The proposed changes to OWES will leave confusion and chaos in their wake thanks to the lack of coordination and oversight with no comprehensive protective plan for wetlands in Ontario, a patchwork mess that could lead to a complete failure of wetland stewardship in our province, unravelling decades of hard work by dedicated professionals.

For all of the above disturbing aspects of the proposal to revamp the Ontario Wetland Evaluation System, I would suggest that it be paused, revisited and re-evaluated. It is a devastating, damaging document that will have terrible consequences for generations to come. And it will not lead to more houses any time soon.

As for the monetary value of intact wetlands, a recent study out of the University of Waterloo (https://onlinelibrary.wiley.com/doi/10.1002/hyp.14442) has assessed just one of the free services wetlands provide: water purification. If we continue to dismiss the importance of wetlands, we will need to invest billions in alternative methods to clean water. Billions. Those Great Lakes we love so much? They rely on the health and quality of our wetlands too. I don’t think I need to mention flood mitigation as another critical reason for maintaining our remaining wetlands. This is something that we should all be well aware of by now.

I have firsthand knowledge of what it means to care for a wetland. I know that less than 30 per cent of our original wetlands remain in southern Ontario. (Where I live.) In the Niagara and Greater Toronto Area that number drops to 10 per cent. The rate of wetland loss between 2011–2015 alone (1,825 ha per year) is considerably higher than the rate of wetland loss previously assessed for the decade between 2000–2011 (615 ha per year). These statistics and others can be found on the Ontario Biodiversity Council website. Smaller wetlands not designated Provincially Significant are already disappearing at an alarming rate due to development. If we are already losing small wetlands in Ontario to development, should we not ensure that we protect all others in view of the amount of scientific evidence that substantiates their critical importance to our communities?

A study published in the Journal of Environmental Management (May 2022) recommended that “protections be strengthened for wetlands of all sizes, in turn protecting communities by retaining the important ecosystem services that are vital for biodiversity as well as human health and wellbeing, which wetlands provide.”

Ontario is clearly going in the wrong direction for the future with its proposed changes to OWES. Let us pause to consider a better way, but by working together, all citizens.

I respectfully urge the government to rethink the sweeping plan to amend OWES. It will not effectively add more “houses,” but it will seriously impair the home we all share – our province.