From: The Ottawa River…

From: The Ottawa River Institute (www.ottawariverinstitute.ca)
Date: November 24, 2022
Subject: ERO number 019-6160, Proposed updates to the Ontario Wetland Evaluation System (in the context of various changes to the Conservation Authorities Act and the Planning Act proposed by Bill 23)
Our group, Ottawa River Institute, takes actions to foster sustainable communities and ecological integrity in the Ottawa River watershed. Our president co-authored the widely-cited journal article, Riparian Forests as Nutrient Filters in Agricultural Watersheds, and had a 28-year career as a federal scientist working on forest ecology and biodiversity conservation.
The policy changes proposed in ERO number 019-6160 must be viewed in the wider contest of proposed legislative amendments to the Conservation Authorities Act (Schedule 2) and Planning Act (Schedule 9).
Ducks Unlimited Canada says these proposed amendments threaten to accelerate the loss of wetlands and their associated ecosystems, including impacts on water and other climate mitigation and adaptation service benefits.
Our group missed the deadline to comment on Bill 23, but we fully support the submission from Ducks Unlimited Canada.
The proposal summary for ERO number 019-6160 says that the proposed wetland evaluation policy changes would “remove duplicate requirements and streamline the evaluation process” in support of construction of 1.5 million new housing units.
But this so very, very wrong.
Just as Bill 23 will not improve the housing supply situation in Ontario, neither will the proposed policy changes in ERO number 019-6160. In fact, increased housing supply is the wrong goal. The goal must be to develop sustainable communities. Focusing solely on suburban housing construction is short-sighted in the extreme.
Wetlands are a critical part of our developed landscapes. Water is life. By retaining and filtering water, wetlands make human communities sustainable. They are biodiversity hotspots.
People with ready access to biodiversity-rich green spaces such as wetlands lead healthier, happier lives.
Our group has compiled information about wetlands in the County of Renfrew on our Renfrew County Nature Notebook. We are proud that the County, and eastern Ontario in general, remain rich in wetlands, given the vast loss of wetlands in southern Ontario.
Many of our wetlands exist as complexes, such as the Killaloe Swamp or the Muskrat Lake Complex. Many are designated as provincially significant. Some, such as the Snake River Marsh, Conroy Marsh and Westmeath Bog are protected as conservation reserves. Our group has led many outings in the County of Renfrew’s wetlands.
We understand the consequences of wetland loss. Drainage of the Upper Osceola Marsh and channelization of the Snake River upstream of its point of discharge into Muskrat Lake has caused serious pollution of that water body by agricultural runoff. People in Cobden get their drinking water from Muskrat Lake. We have worked with other groups such as the Muskrat Watershed Council to mitigate the impacts of wetland loss.
We understand the benefits of wetland creation. In the City of Ottawa, portions of the formerly channelized Carp River are being restored. Life is returning. Local residents are enjoying the trails along the shoreline. School groups are studying the return of life.
Another good example of the benefits of wetland creation in the City of Ottawa is the series of stormwater retention ponds along Sawmill Creek in the city’s south end. Heavily-used trails along these ponds provide major recreational benefits.
Retaining wetlands in proximity to housing – not destroying the ecosystem services they provide – makes communities sustainable. Ecological integrity and sustainable communities go hand-in-hand.
The province of Ontario should be enacting policy changes to increase the supply of wetlands.
Wetland complexes function as a unit and must be retained in their entirety. The 150-meter buffer zones around wetlands (whose importance has benn demonstrated through extensive research work) must be retained.
MNRF and Conservation Authority staff, who are the experts in wetland hydrology and biodiversity, must retain their powers to designate additional wetlands as being of provincial significance. Many wetlands in the County of Renfrew that currently lack designation as provincially significant but are worthy of that designation (the Little Lakes wetland complex near Beachburg is but one example).
We see no merit in the proposed policy changes in ERO number 019-6160.