ERO #019-6160 Southern…

ERO #019-6160
Southern Ontario has already lost 85% of its original wetlands. The revisions to the Wetland Evaluation System put forward in Bill 23 will result in significant losses to those that remain. By allowing each individual wetland in a wetland complex to be evaluated separately, we will doom the entire complex over time. Each loss makes the entire complex less able to perform its functions. According to the Niagara Peninsula Conservation Authority, proposed changes could result in the demise of all of its protected wetlands (Hamilton Spectator, Nov. 2, 2022). Ontario Nature states that, because of the proposed changes, “many if not most existing Provincially Significant Wetlands (PSWs) could lose that designation” and be subject to development.

Wetlands are rich ecosystems that support a host of species including invertebrates, amphibians, reptiles, birds and mammals – many of which are already on the endangered species list. Allowing these changes could also result in the extinction of these species.

Where the option to destroy wetlands exists, it will be used by the development industry. The plan to “offset” the loss of a wetland is disingenuous – no amount of compensation can replace the complex ecosystem that will be destroyed. Orillia naturalist Bob Bowles, who used to evaluate wetlands for the province, said the proposed changes to the scoring system will significantly reduce environmental protections for those ecosystems. He also noted that some unevaluated wetlands could be provincially significant and as it can take up to three seasons to fully evaluate a wetland, the new scoring system will make it difficult for such wetlands to become protected moving forward (OrilliaMatters.ca).

According to this posting, the proposed changes are intended to “provide greater certainty and clarity related to how significant wetlands are assessed and identified.” However, the significant removals and changes proposed reduce the amount of detail and clarity surrounding procedures and criteria for determining and identifying significant wetlands and their boundaries. (CELA.ca)

When combined with the diminished role of conservation authorities that is also being proposed as part of Bill 23, this could lead to development in natural hazards with resulting higher property damage costs, risks to human health and safety, and increased burdens on municipal partners, who may not have the technical expertise and experience to make informed decisions related to wetland evaluation (as well as other natural heritage systems).

As the Canadian Environmental Law Association notes in their submission to this posting, this review of the OWES system has also missed an opportunity to address equity concerns: “Land use decisions have and continue to play a role in creating and perpetuating discriminatory practices against low-income, vulnerable, and disadvantaged communities.” For example, a recent study found that “the overall flood risk is higher in Indigenous communities than in other Canadian communities” and since Ontario’s wetlands play a critical role in enhancing resilience to climate change and flood risk (through soil stabilization, water filtration, flood mitigation and carbon storage), I agree with CELA that it is important for the Ministry of Natural Resources and Forestry to apply an equity lens when making decisions related to wetland conservation and protection. This must include direct consultation with Indigenous groups.

For these reasons, I do not support the proposed updates to the Ontario Wetland Evaluation System.