Submission to ERO Proposal…

Submission to ERO Proposal 019-6160
Proposed Updates to the Ontario Wetland Evaluation System

The regulatory impact analysis states that the impact of this proposal to business will be positive. It does not mention any negative impacts, whereas the impacts and real costs to all Ontarians will be vastly negative. Changes outlined in this proposal will put people at risk. They will impact city infrastructure including sewer backup risks, municipal building codes, clean drinking water, biodiversity, First Nations communities, agriculture, the insurance industry, fisheries, human health, and tourism.

The negative impacts far outweigh any positives; these impacts will be cumulative and ongoing, and the proposal should be scrapped.

There are more fiscally responsible and environmentally responsible ways to address the housing crisis than to develop over filled-in wetlands.

The proposed changes to wetland evaluation will weaken protection for all wetlands. The new wetland classification system may result in no provincial oversight over wetlands at all. The proposed evaluation changes will open the door for even more development and loss; the proposal is an invitation for developers to spread housing sprawl and get rid of wetlands completely.

Wetlands filter nutrients and sediment from runoff, which purifies rivers and groundwater.

To put a cost to just this one of the impacts of this proposed change, a University of Waterloo study uses economic valuation to understand the importance of Southern Ontario’s wetlands for water filtration, and the authors conclude that these wetlands provide $4,2 billion worth of sediment filtration and phosphorous removal services each year, keeping our drinking water clean and helping to mitigate harmful algal blooms in our lakes and rivers. (‘Economic valuation of suspended sediment and phosphorous filtration services by four different wetland types’, Aziz and Van Cappellen, Hydrological Processes, November 2021)

While Ontarians understand that the climate crisis is the most urgent issue of our time, this proposal ignores this entirely. The effect of this proposal will contribute to climate change and will reduce the means of mitigating its impacts.

And this is at a time when we need all remaining wetlands in southern Ontario. Southern Ontario has already lost 72% of its original wetland area.

Wetlands are critical nature-based available climate solutions. Up to 38% of potential damages and costs caused by floods in urban areas are reduced by wetlands. Wetlands reduce the severity of serious floods, control erosion. At a time when climate change is causing more frequent and intense storm events, we need wetlands more than ever.

The Insurance Bureau of Canada puts the catastrophic costs from flooding at $ billions.

Removing wetlands is like removing dams and reservoirs. Wetlands act as natural infrastructure that absorb and retain a significant volume of snow melt and rain which reduces flood levels during spring runoff and storm events. They also release this water slowly throughout the year, helping augment water levels in lakes and rivers during low flow periods, which reduces the affects of drought conditions.

During times of drought, wetlands provide water to aquifers and base flow to rivers. These benefits are particularly important where lakes, rivers and groundwater are supporting agriculture, recreation and fisheries. During drought, wetlands replenish the aquifers that farmers need and municipalities rely on to supply drinking water to their communities.

Municipalities and Conservation Authorities could never afford to build the infrastructure it would take to replace wetland functions and protect upstream and downstream communities from flooding and drought.

Wetlands store carbon. 20 to 30% of global carbon storage is accounted for by wetlands.

We need intact wetland complexes for deep carbon storage and also for their high biodiversity value. The proposed changes do not recognize integrated wetland complexes. Breaking up these complexes, and offsetting are not the answers. The wetlands near urban areas are at particularly high risk, and this is where the flooding and drought risks are.

The proposal downloads onto municipalities the responsibility for evaluating the risks, and where is the expertise coming from? Municipalities don’t have the technical expertise or capability of evaluating these risks. It is far too complex. It is impossible for municipalities or developers’ consultants to assess the far-reaching impacts.

The University of Waterloo study puts an additional cost to the filtration benefit of swamps and marshes. The study concludes that marshes in Southern Ontario contribute about 80% of the overall filtration services we benefit from at a value of $3.4 billion per year. Without these wetland services, implementing agricultural Best Management Practices to remove an equivalent phosphorous load would cost $23 billion annually, while expanding current wastewater treatment capacity to replace wetlands’ filtration service would cost $164 billion per year. (‘Economic valuation of suspended sediment and phosphorous filtration services by four different wetland types’, Aziz and Van Cappellen, Hydrological Processes, November2021)

A fundamental problem is that this proposal was tabled on October 25, the day after the municipal elections. The proposal involves changes to land-use planning affecting municipalities. This timing was planned and strategic. Across Ontario outgoing mayors and councils are disempowered, and new mayors and councils have not yet been sworn in. This October 25 timing was strategic to take the voice away from municipalities, from elected officials and the citizens they represent. This timing is a betrayal of public interest and democracy, and the proposal should be dismissed on this basis alone.