Stop this politically-driven…

Stop this politically-driven unscientific legislative destruction of wetlands.

After reviewing Ontario's adjustments to the provincial Wetland Evaluation System, it is clear this government continues to REFUSE to recognize science-based assessments. Wetland assessment is a job for qualified scientists, such as are hired by Conservation Authorities, while Ontario once had very reputable forestry and wetland scientists and hydrogeologists on staff at the Ministry of Natural Resources. Instead of relying on science, this government wants politicians and municipal planners to assess wetlands,

Municipal planners understand where to place buildings AFTER the Conservation Authorities identify areas where flooding and erosion will occur. Conservation Authorities are the agencies who MUST CONTINUE to identify floodplains where roads and buildings should NOT be built. Wetland evaluation is not a job for municipalities, especially when wetlands and floodplains cross municipal boundaries. There has been significant flooding in the west end of Toronto since the City of Vaughan has paved so much of its landscape, thereby transforming wetlands and floodplains into fragments.

From the human perspective, wetlands are very important for flood control, water filtering, and groundwater recharge and discharge. They also provide ideal habitat for animals and fish who depend upon wetlands for the natural food web, represented with myriad systems of aquatic life.

Let's consider the REAL value of wetlands, and why they should receive priority attention from Conservation Authorities and scientists who are able to advise politicians who lack such qualifications.

Wetlands benefit communities by helping to mitigate floods, purify drinking water, control erosion, sequester carbon, provide wildlife habitat and much more. A 2009 study commissioned by the Ministry of Natural Resources and Forestry conservatively valued wetland benefits at over $161,000 per hectare per year in urban settings. In 2022, that translates into $217,350, and their increasing scarcity will only drive those costs higher. With over 72 percent of wetlands already destroyed in southern Ontario, we simply cannot afford to lose any more.

Governments must make the effort to understand how watersheds work because water always flows from the upper portion of the watershed down to the lowest level; as an example, let's consider the water from the Duffins Creek, which enters Lake Ontario at Duffins Marsh in Ajax, though Pickering decided to terminate Ajax's participation in negotiations regarding the MZO issued to the developer. How could Ajax be excluded from talks when it will clearly be impacted by this huge new development?

This is the folly of politically-motivated site-by-site approvals, instead of proper science-based watershed planning. This creek's tributaries include Stouffville Creek, Reesor Creek, West Duffins Creek, Wixon Creek, Mitchell Creek, East Duffins Creek, Major Creek, Whitevale Creek, Urfé Creek, Brougham Creek, Ganatsekagon Creek, and Millers Creek. Count how many municipal boundaries are crossed in this case.

A fundamental principle of watershed science and planning is that upper watershed wetlands, and middle watershed floodplain areas, provide critical storage of rain and snowmelt, thereby slowing the flow of water moving downstream, thereby assisting in the retention of sediment and nutrients, as they provide a natural filtering service. When politically-motivated decisions remove or damage such wetlands and floodplains, or disconnect them from associated streams or tributaries, we lose their natural storage capacity. As a result, run-off moves swiftly downstream, in turn producing elevated and flash flood peaks. These degraded conditions already exist across much of the GTA and contribute to many of southern Ontario's more frequently-occurring and expensive water management problems. There have been enough recent cases of serious flooding, thanks to unwise filling and paving of landscapes in the upper levels of Lake Ontario's surrounding watersheds in York, Durham, Peel and Halton Regions

I was stunned when your Ministry "worked with" (against?) the Ministry of Natural Resources and Forestry and the Pickering Council to circumvent policy protections for two large wetlands within the provincially significant Lower Duffins Creek Wetland Complex, when issuing an MZO and seeking to downgrade the status of the wetland complex. I believe a court case brought by Ecojustice against that MZO in July 2021 resulted in the return of protections for this wetland complex:
https://ecojustice.ca/pressrelease/lower-duffins-creek-wetland-is-final…

MMAH and MNRF must recognize that wetlands in the upper parts of a watershed may form in low-lying spots on the land. These wetlands capture, store, and slowly release runoff from rain and snowmelt. Not all of them may always look like ONE large integral wetland, though several may form a single Wetland Complex —they may be wet in the spring and dry by late summer—and often, they might not even appear to be connected to streams or rivers, but their connections are critical. Individually, these wetlands may appear to be small and 'disconnected', but they can and do form a significant local wetland complex together. As such, they retain a lot of water, slowing the rate of flow, and allowing the water to permeate into the ground. This reduces erosion and flood peaks and helps protect downstream roads and neighborhoods.

Wetlands in the middle portion of a watershed form along rivers and creeks, giving their banks room to accommodate the swell of higher water flows during storm events. They are most commonly known as floodplain wetlands.

Finally, the waters from the upper watershed reach wetlands in the lower parts of a watershed, such as Ajax's Duffins Marsh, where rivers empty into a larger body of water, such as Lake Ontario. Where rivers flatten out, the current disperses, and the river drops its cumulative load of sediments and nutrients. This makes the water entering the lake cleaner and clearer, and that means better fishing, swimming, and boating -- not to mention the replenishment of nutrients for various aquatic and dependent species in the wetland food complex.

This foolishly-issued politically-motivated non-scientific MZO would have put all of this watershed's ecological services at risk, which are already threatened by so much encroaching politically-motivated urban development. Those who accept the responsibility of government have an obligation to either learn the science of watersheds, OR accept the findings of science-based assessments done by Conservation Authorities. In this case, I would accept the TRCA's science-based decision over Ontario's politically-motivated desire to please yet another developer who is a generous donor to conservative political campaigns.

Let's not forget that 72% of southern Ontario's wetlands have already been drained, and it certainly shows up in all the costly flooding events that occur, even during periods of relatively normal rainfall, though climate change has been exacerbating and strengthening storms.

Since Ontario seems to be lagging in assessing the real value of its wetlands since 2018 under this Conservative government, let's look to some older examples from the USA where the US-EPA found in 1990 that the Congaree Bottomland Hardwood Swamp in South Carolina, removes a quantity of pollutants that would be equivalent to that removed annually by a $5-million waste water treatment plant. Another study of a 2,500-acre wetland in Georgia, indicated that it saves $1-million in water pollution abatement costs annually. What would those same savings be worth in 2020 dollars?

As for the size of a complete wetland complex, consider the US-EPA's finding that: "In addition to improving water quality through filtering, some wetlands maintain stream flow during dry periods; others replenish groundwater. Many Americans, of course, depend on groundwater for drinking. The Floridian aquifer system, for instance, is one of the more productive ground water sources in the United States. It occurs ACROSS THE ENTIRE STATE of Florida, and INTO southern Georgia, and portions of South Carolina and Alabama. This huge subsurface reservoir produces some of the cleanest water in the nation. Its primary source is rainwater that filters through hundreds of feet of sand and rock. One calculation for a 5-acre Florida cypress swamp recharging groundwater was that, if 80 percent of swamp was drained, available ground water would be reduced by an estimated 45 percent." Think of all the human activities that rely on groundwater for drinking, agriculture, fishing -- we cannot afford to lose such services.

When Ontario's government dismisses the value of wetland complexes, such as it did in Vaughan to allow the bull-dozing and paving of a large area for yet another warehouse, this time for a WalMart Distribution Centre, Ministers at MMAH, MNRF, and the Premier obviously had NO IDEA what was being obliterated because they cannot see the totality of the complex, much of which remains in unseen 'underground' connections. So many ecological services are at work below the ground and out of sight.

The risks of flooding in the city of Toronto are very real, and they were studied and explained by engineering researchers at UBC and the University of Windsor in 2017, then published in the Journal of Cleaner Production in 2018, https://doi.org/10.1016/j.jclepro.2017.11.066

The engineering team found that urbanization has profoundly altered the Toronto's land cover.

Urban catchment basins have very low permeability and high rainfall runoff conversion rates. These changes affect the hydrology that determines flood hazard. Drainage infrastructure capacity, type and condition are other key factors influencing the occurrence of pluvial floods.
Urban drainage infrastructures are composed of two sub-systems: minor and major systems.
The minor system refers to an underground sewer network while the overland flow route is called the major system. These infrastructures have to be in good condition and perform according to their design requirements to prevent pluvial flooding. Therefore, not only design capacity has
to be considered in flood vulnerability assessment, but also the current condition and performance.

Here is ONE of the conclusions from the study:

"Understanding the main cause of basement flooding in an area is a crucial step towards flood risk mitigation and adaptation planning. In this study, a novel approach using GIS applications and
Bayesian Belief Network-BBN is proposed to diagnose the main factors influencing basement flooding and to predict Flood Variability Index - FVI. The case study revealed that climate variations have the least impact on the disproportional number of basement floodings reported by different areas across Toronto. Whereas, population density followed by land cover related parameters are the most influential factors.

Therefore, the city of Toronto should focus their resources on land cover related parameters to improve the water retention capacity of the soil and decrease impervious areas. This can be achieved by promoting green development like green roof constructions, encouraging the use of pours pavement materials that allow water infiltration, increasing proportion of green areas in new development projects and so on.

The main advantage of the proposed methodology is that it can be adopted in any urban area, based on its characteristics and data availability and it has the ability to quantify uncertainty in the decision-making process."

NOW, note the Insurance Bureau of Canada is promoting wetlands as "natural infrastructure".

IBC insists a Real Estate Climate Risk Score must be instituted across Canada by 2025, to indicate a property’s susceptibility to catastrophic loss based on known risk factors. The Index would form the basis for managing and reducing household, community and municipal climate risk.

Craig Stewart, V.P., IBC Climate Change and Federal Issues, stated: “We simply can’t wait until 2050 to be climate compatible in the housing sector. Immediate action must be taken to protect homeowners and communities, or catastrophic loss to homes and communities will continue to increase in severity and cost, year after year.”

Withdraw Bill 23 and reinstate scientific oversight responsibilities to the Conservation Authorities.