The stated purpose of the…

The stated purpose of the proposed OWES overhaul is to support the construction of 1.5 million new housing units over the next ten years by streamlining the wetland evaluation process. This purpose is misguided and misleading, given that a shortage of land isn’t the cause of the housing shortage, as Ontario’s Housing Affordability Task Force explained in its 2022 report. The amount of greenfield land already designated for development and added to municipal settlement boundaries, but still sitting unbuilt far exceeds what is needed to meet long range housing targets.

Bill 23, the “More Homes Built Faster Act” will not create affordable housing. It will create sprawl. It will facilitate the destruction of wetlands, worsen climate change, and endanger biodiversity. It will put people and property at greater risk from flooding and pollution.

Naturally existing wetlands help prevent flooding, purify water, recharge aquifers, support endangered species and trap and store carbon. Wetlands provide these ecosystem services for free, and when we build on wetlands, we put people and property at risk. Taxpayers and homeowners have to pay more. This makes housing less affordable, not more.

Bill 23 proposes to allow more wetlands to be destroyed with so-called “offsets.” Recent research has revealed that even the most rigorous and well-established wetland offsetting programs (i.e., the United States’ wetland offsetting under the Clean Water Act) have been unsuccessful in achieving no net loss. Wetlands are complicated ecosystems that take decades to centuries to develop. Most "restored" wetlands never reach the biodiversity of natural ones, and most species at risk can’t just move.

The attached scientific paper demonstrates how the water filtration services of *existing* wetlands in Southern Ontario is worth billions of dollars. Attempting to build offsets will cost the province billions more. This is on top of additional billions of dollars in services gained from climate mitigation, biodiversity, recreational activities, etc.

For the overall well-being and safety of Ontarians, please do not move forward with this proposal.