Revised November 24, 2022…

Revised November 24, 2022

Proposed changes to Ontario Wetland Evaluation System are a dramatic shift away from historic wetland protection. Damage to wetlands is not easily reversible. I ask that the principle of wetland complexes be retained, that the scoring criteria be retained, and that an arms length adjudicating body be put in place in wetland classifications.

In Ontario, wetlands are very important for flood control, water filtering, and groundwater recharge and discharge. When there is a lot of rain or snowmelt, wetlands absorb and slow flood waters, helping to alleviate property damage and even save lives. In the face of climate change, these wetlands are ever more important as we experience more extreme storm events.

Wetlands are diverse and delicate ecosystems that provide important habitats for plants and animals. These include many familiar species, such as great blue herons, turtles, muskrats and beaver.
Currently, Ontario’s wetlands are scored for importance through the Ontario Wetland Evaluation System. Wetlands that receive a higher score are considered provincially significant and are heavily protected. In the Nottawasaga watershed, for example, these include the Minesing Wetlands, Osprey Wetlands, Wasaga Beach Wetland Complex, Midhurst Wetland Complex, Silver Creek Wetlands and Copeland-Craighurst-Guthrie Complex.

The Ontario government's proposed changes to the evaluation system in support of Bill 23, the More Homes Built Faster Act, fail to recognize the importance of the interdependence and
interconnectedness of wetland bodies within a complex. Like any a complex organism, destroying its discreet components will significantly weaken the organism as a whole, with dire consequences.

In the proposed changes, some scoring criteria have been removed, 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 have the potential to be slated for development.
Many wetlands in Ontario are grouped together in complexes — this includes wetlands big and small that are less than 750 metres apart. This is important for fish and wildlife that live in wetlands, as the entire complex makes up their habitat.

The proposed legislative changes will no longer allow wetlands to be grouped together, treating each wetland as its own entity. Smaller wetlands will most likely not meet the criteria to be provincially significant and may be open for development.

It is important for wetland evaluations to be reviewed by arm’s-length agencies with an objective view. The proposed legislation is not allowing the Ministry of Natural Resources and Forestry or conservation authorities to review wetland evaluations, leaving it to municipalities.

If municipalities are responsible for development, as well as preserving natural heritage like wetlands, where do they find the balance? Many wetlands cross municipal boundaries. How will the different municipalities determine the level of importance for the wetland?

Ontario has legislated habitat-protection laws for good reason. Since the 1970s, waterfowl populations have bounced back thanks to wetland protection. Species that did not enjoy the same habitat protection, such as grassland birds, have seen a significant decline within this same period.
How an important Orillia wetland was ruined.

Moreover, in the context of the climate emergency, with more frequent and severe weather events, flooding and erosion protection afforded by wetlands is more important than every. Yet these proposed changes will only reduce the increasingly important environmental services provided by wetland complexes.

It takes generations for wetlands to become viable, sustainable and ecological communities. The removal or damage to wetlands is not easily reversible, and many species may not be able to recover from this loss.

I urge the government to bolster protections of wetlands so that the new housing it plans to facilitate will be both protected from flooding and other hazards while fostering healthy communities that include respect for nature.