I understand and support the…

I understand and support the need to build more housing in Ontario in a mix that will be accessible to, and meet the needs of, all Ontarians. However, the value of housing to Ontarians is more than just a place to sleep; it is a place to live, work, and grow supported by the amenities of a healthy community, including the critical essentials of access to clean water, local food supply, transportation, sewage and flood control, and natural spaces for recreation and leisure, the ongoing cost of which is inseparable from purchase price when determining housing affordability. Bill 23 and the proposed updates to the Ontario Wetland Evaluation System contain alarming regulatory changes and rollbacks that will further the destruction of critical natural areas in a time of climate crisis, while also failing to deliver the urban transformation – or the affordable housing – that Ontario needs.

Approving housing development in areas currently recognized as provincially and locally significant wetlands would subject not only the new housing units but existing housing in nearby areas to frequent flood risk and climate change related disaster mitigation costs. Wetlands provide many critical water management services naturally and without added cost or active management. A short list of these vital services includes: providing a home to wetland dependent species, which form a part of every food chain or food pyramid that underpin local and global food supplies; provide flood control by absorbing the vast volume of water that can be suddenly released from rainfall or snowmelt; prevent erosion of streambanks and roadsides by slowing down the velocity of this flash flood rainfall; filter out all manner of materials, from large debris to excess nutrients, that flow in with dirty water from parking lots and hard surfaces, providing an outflow water that is remarkably clean; cool the water as it seeps underground before being released downstream, which supports life better than warm water (high oxygen levels and no algae); recharge groundwater supply, thus ensuring wells don’t have to be drilled deeper and deeper; provide carbon sequestration, production of oxygen, and production of biomass equivalent to that provided by rainforests, helping to mitigate the effects of climate change; attract human users who pay into local economies to enjoy the benefits of hunting, fishing, birdwatching, paddling, and to do nature photography; and provide cultural, historical, and aesthetic value to our society that nurture both our physical and spiritual needs.

The proposed updates to the OWES remove most of the detailed technical guidelines that are necessary for the OWES to function as a rigorous and comprehensive evaluation system. The updates are furthermore destructive to the continued existence of wetlands in Ontario and the safety of housing in adjacent areas in three major ways: (1) some scoring criteria, such as the Special Features category, the ability to group wetlands into complexes, and the ability to identify locally significant wetlands have been removed from the Ontario Wetland Evaluation System, yet wetlands must still meet the same score to be considered provincially significant. This makes it much harder for wetlands to reach provincially significant wetland status, meaning many of the wetlands have the potential to be slated for development despite no material changes in their importance as natural features in the landscape. (2) shifting of oversight and authority for wetland evaluations from arm's length agencies with an objective view to the parties most interested in wetland destruction. The Ontario Ministry of Natural Resources and Forestry has been responsible for ensuring that OWES evaluations are completed by trained professionals, including providing training and certification in the OWES method and maintaining the records about each evaluated wetland. Responsibility for use of the OWES appears to be downloaded to municipalities, which lack the resources and experience to run OWES training courses and validate evaluation files, lack the funds to cover the associated costs, and lack the knowledge and coordination to make determinations where wetlands cross municipal boundaries. This also represents a very real conflict of interests for municipalities who will simultaneously be responsible for planning development and for protecting natural resources that limit development. Furthermore, the wetland evaluator will only be accountable for the objectivity and accuracy of the wetland evaluation to the person paying for it, meaning that a property owner or developer seeking to remove a significant wetland designation will be the only authority determining if the wetland evaluation is valid. (3) the introduction of "re-evaluations" will permit already-evaluated Provincially Significant Wetlands to be re-classified using the new scoring system with its degraded criteria. OWES files have always been considered open and subject to updates, but the addition of a "Wetland Re-evaluations and Mapping Updates" section lays the groundwork for sweeping reviews of already evaluated wetlands regardless of whether there has been any notable change in their conditions. This is an obvious contemplation of applying the newly deteriorated criteria to strip protected status from wetlands that would previously have been preserved from development. 

It takes generations for wetlands to become viable, sustainable, and ecological communities. The removal of or damage to wetlands is not easily reversible, cannot be effectively mitigated through "offsetting" or replacement programs, and many species may not be able to recover from the loss. With wetland loss rates already sustained in excess of 85% in many areas of southern Ontario (DUC. 2010. Southern Ontario Wetland Conversion Analysis), any changes to the Ontario Wetland Evaluation System that would result in a further loss of protected wetland area would be a fiduciary breach of duty on the part of the provincial government for all of Ontario's current and future residents.  As identified in the OWES, "As a steward of Ontario’s natural resources, one of the Ontario Ministry of Natural Resources and Forestry’s (MNRF) mandates is the protection and sustainable management of the province’s natural heritage features, including wetlands." This proposal represents, at the least, a highly irresponsible and incautiously injurious attempt to speed housing development and, at the worst, deliberate negligence of the role of steward of Ontario's natural resources quoted above, to the short-term profit of developers at the long-term expense of the public. The proposal should be rejected.