Ontario’s Water Security Must Be Better Protected

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Ontario’s Water Security Must Be Better Protected

The undersigned support the recommendations of the Coalition of Ontario Water Guardians that Ontario should make significant efforts to better protect water security, and that a good place to start is to commit to meaningful consultation on the proposed amalgamation of the A Place to Grow Act with the Provincial Policy Statement.

While most of the issues described below are long-standing, many have been amplified or created by the Housing Action Plan. This includes provincially-led urban sprawl onto natural heritage and agricultural lands, often over the objection of local municipalities; carveouts from the Greenbelt, something the Province promised it would not do; and the repeal of legislation that created the Duffins Rouge Agricultural Preserve, probably in violation of an agreement with the federal government.

In spite of significant public debate on these and aligned issues, there has been almost no discussion about how long-standing issues and recent changes present a cumulative threat to Ontario’s water security - safeguarding reliable access to clean water to protect ecological integrity, public health, social equity, and economic vitality.

The key issues described below focus mostly on water for nature and not drinking water, which also needs an effort such as this. The list begins with two big issues, describes other challenges alphabetically, and concludes with threats to water security in the Far North. The list is followed by our two recommendations.

Land Use Conversion: Most of the downstream portions of South-central Ontario’s watersheds are intensively developed, and can be characterized as having highly fragmented patches of natural heritage, few remaining wetlands, impervious surfaces that can contribute to flooding, and high levels of water pollution. It is irresponsible to convert huge additional areas from natural heritage to urban use based on the same planning protocols that got us here, and may push whole watersheds past tipping points of ecological health. It is also deeply concerning that most aspects of proposed land conversion outside of urban boundaries have not been the subject of meaningful consultation with First Nations;

Watershed Management: It is hard to see how even the existing poor health of South-central Ontario’s watersheds will be maintained when the Province has abolished regional planning; narrowed the mandate of Conservation Authorities by removing their abilities to address “pollution”, the “conservation of land”, and to comment on municipal official plans; and as municipalities don’t have the expertise needed to fill the gap. Now, instead of restoring the mandate of Conservation Authorities as requested by multiple organizations, including developers, the Province may further reduce water security in its amalgamation of the A Place to Grow Act and the Provincial Policy Statement, without fulsome public consultation;

Agriculture: Agricultural production relies on the stewardship of soil health and the protection of both water quality and quantity; spans numerous trades and professions that make it the number one value-added sector in Ontario; and requires government policies that nurture vibrant agricultural communities. Unfortunately, the on-going transition of agricultural lands into urban areas, at the rate of more than 300 acres per day, threatens the overall agricultural economy while additional areas of impervious surface may result in increased flooding and reduced water quality downstream. Government initiatives should limit the loss of farmland to development while bolstering economic vitality in the agricultural sector, with co-benefits for food security, biodiversity, climate change, and water security;

Aquatic Biodiversity: Further land conversion as mentioned above will impact not only terrestrial biodiversity but also aquatic biodiversity. This is due to increased run-off and sewage effluent from expanding urban areas, which may increase both aquatic pollution and water temperature, as well as reducing the supply of terrestrial insects - the largest source of food for aquatic species. Curtailing regional planning and the role of conservation authorities to facilitate development is a prescription of disaster for aquaticspecies;

Excess Soil and Aggregate Regulations: Recent amendments to Ontario’s excess soil regulations, as well as aggregate pit regulations, will allow millions of truckloads of unwanted soil to be dumped with limited soil analysis. Some of this excess soil is contaminated, yet may be placed on top of groundwater infiltration zones that feed headwater streams and supply drinking water. This presents unacceptable risks to aquatic life and public health;

The Great Lakes: The Great Lakes Protection Act was passed in 2015 and the Canada-Ontario Agreement on Great Lakes Water Quality and Ecosystem Health was renewed in 2021. Unfortunately, action on either is relatively stagnant. On the former, no rehabilitation efforts known as Geographically Focused Initiatives have been launched in seven years, and the Great Lakes Guardian Council has not met since April of 2021. On the latter, while progress has been made to reduce nutrient flows causing algae blooms in Lake Erie, Ontario had minimal participation in the Great Lake Public Forum of November, 2022; did not have an information table at the Forum; and made no announcements. Ignoring the Great Lakes, including the agreement mentioned under Sewage below, does little to protect them;

Infrastructure in the Greenbelt: While regulations call for environmental assessments of new infrastructure projects in the Greenbelt, the assessment is only for the footprint of the project and is not a comprehensive study of its ecological outcomes, such as the impact of road salt from new and expanded roads, storm water run-off from new developments, or effluent from new sewage treatment plants. These outcomes could overwhelm the sensitive relationships between surface water, groundwater, drinking water, and aquatic life in the Greenbelt and downstream;

Provincial Water Quality Objectives: PWQOs have been established to protect our water from various chemicals and other pollutants. Unfortunately, they lack any thresholds above which action must be taken. Thus, a body of water might exceed a provincial water quality objective significantly and/or for multiple years – yet no action is required. Numerous organizations have been calling for years for thresholds that would trigger action;

Sewage: While numerous laws, regulations, and policies direct how planning authorities are to address sewage, these authorities seem to be mesmerized by the prospect of growth in the local population, economy, and tax revenue, and to leave planning for sewage to the end of the line. The worst case may be efforts to deal with expanded sewage needs in York Region and Simcoe County. After expenditures of about $100,000,000 to develop a local sewage solution that delayed billons of dollars of proposed development, an expert panel found that sending the sewage effluent to Lake Simcoe would violate the Lake Simcoe Protection Plan, as well as the rights of a local First Nation. Instead, the panel recommended that raw local sewage should be piped to and treated in Durham Region. Unfortunately, that appears to violate the Great Lakes St. Lawrence River Basin Sustainable Water Resources Agreement, of which Ontario is a signatory, which prohibits the transfer of water from one Great Lake to another. Planning authorities must not dream about growth without planning for water security;

Wetlands: Already significantly reduced in much of Ontario, wetlands seem to be a particular target of the provincial government. Three recent efforts include pursuing wetland off-setting, which permits the destruction of an historic wetland for a replacement somewhere else; changing the law to allow a minister to issue a zoning order to destroy a Provincially Significant Wetland; and amending the Ontario Wetland Evaluation System to not only make it more difficult to have a wetland declared provincially significant but to imperil that status where it exists. Wetlands offer significant ecological and flood attenuation services, and should be protected and restored rather than destroyed; and,

The Far North: While all the above refers almost exclusively to South-central Ontario, the Ontario government has stated that it intends to apply the outcome of the amalgamation of the A Place to Grow Act and the Provincial Policy Statement to the whole of the province – a significant change from how planning is currently done in the Far North, with probably less protection for freshwater ecosystems than at present. In addition, Ontario announced on March 2 that it was launching an effort to provide faster approvals for new mines, especially to expedite mining for critical minerals in the Far North. It is thus no longer just for the Great Lakes and South-central Ontario where water security may be diminished, but across the whole of the province.

Our Recommendations

The undersigned support the recommendation of the Coalition of Ontario Water Guardians for significant efforts by Ontario to better protect water security - safeguarding reliable access to clean water to protect ecological integrity, public health, social equity, and economic vitality.

We also support the Coalition’s recommendation that a good place to start is for Ontario to commit to meaningful consultation on the proposed amalgamation of the A Place to Grow Act with the Provincial Policy Statement, with far more details than were posted to the Environmental Registry of Ontario last October.