In Southern Ontario, we’re very fortunate to have approximately 560,800 hectares of wetlands. These important natural heritage features are home to a wealth of species such as fish, birds, mammals, amphibians and insects – including many species at risk.  Wetlands also act as filters to clean our drinking water by absorbing excess nutrients like phosphorus. They also act like natural pieces of our infrastructure in protecting properties from flooding as they soak up and slowly release stormwater runoff.

Despite their ecological and hydrological importance, the protection of wetlands in Ontario is often at odds with urbanization, agriculture, and other types of development.  Since pre-settlement time, we have lost 72 per cent or 1.4 million hectares of the wetlands in southern Ontario. Historically, wetlands were viewed as wastelands and were drained for other land uses such as crops, livestock pastures and urban development.  Unfortunately not much has changed today.  In 2010, Ducks Unlimited Canada released a report, Southern Ontario Wetland Conversion Analysis, which showed that wetland loss is continuing at an alarming rate.

While there are some policies in Ontario aimed at protecting wetlands, there are many loopholes that need to be fixed.  For example, the Provincial Policy Statement (2005) restricts development and site alteration in provincially significant wetlands designated by the Ministry of Natural Resources.  Unfortunately, this protection only applies to wetlands that have been evaluated and designated, and many remain unevaluated.  Even if a wetland is designated as provincially significant, the Provincial Policy Statement allows municipal drains and infrastructure like wastewater and water systems, highways, and roads to be built within its boundaries.  Local conservation authorities also regulate development and site alteration in and around wetlands, regardless of their significance, to protect life and property from flooding and erosion hazards.  Unfortunately, provincial funding to conservation authorities has not increased since the 1990s, which severely constraints their ability to maintain existing levels of flood protection and to deal with emerging threats like climate change.

Today is World Wetlands Day – the date on which the international Ramsar Convention on Wetlands was signed in 1971.  The treaty is a framework for countries to conserve and plan for the “wise use” of all the wetlands in their territories and designated Wetlands of International Importance.  Canada is a signatory to this convention and eight Wetlands of International Importance are located in Ontario. Aichi Biodiversity Target 5 under the International Convention on Biological Diversity, to which Canada is also a signatory,  calls upon governments to reduce the rate of loss of all natural habitats at least in half and where feasible, close to zero by 2020. In my recent special report, Biodiversity: A Nation’s Commitment, an Obligation for Ontario, I identified that the constitutional responsibility for meeting the Aichi Biodiversity targets lies with Ontario and the other provincial governments.  Today, and every day, we should remember how valuable Ontario’s wetlands are.  The provincial government should ensure that the small fraction of wetlands that remain in southern Ontario are conserved and protected and that the rate of loss is reduced or eliminated altogether.

Last year I had a thoughtful read of Richard Heinberg’s book “Blackout – Coal, Climate and the Last Energy Crisis.”  It’s a good and necessary read for those of us who seek perspective on the coming combined conundrum of peak fossil fuels and climate change.  There was something about his final chapter that has been haunting me.

On the face of it, the argument presented in that chapter is logical and persuasive.  He lays out three scenarios of policy and action that the world might follow in the next 30 years and projects and predicts the outcomes into the future.  Scenario One is coined “The Maximum Burn Rate” which he describes as a projection of   present consumption and depletion trends with no mitigating policies being implemented.  The outcome of Scenario One is predictably devastating, ending in the collapse of civilization which he terms “Blackout.”  Scenario Two is “The ‘Clean’ Solution,” governments make massive investments in technology to store carbon, introduce cap-and-trade, etc. so they can keep our current technological structure alive longer.  Although slightly more viable Heinberg lays out the arguments to show that by 2040 this course too ends in Blackout.  Scenario Three, the “Post Carbon Transition” a challenging restructuring of our energy use and economy, is the only option that leads to any kind of sustainable future for our society and, therefore, is the only logical path.

Of the three scenarios, Scenario Two is clearly a characterization of what the clean coal and other lobbies are proposing currently for the way forward.  Heinberg’s thesis is to show that this thinking is flawed and that only a much more radical set of policies rapidly applied will allow us to escape disaster.  Scenario One is provided as a business-as-usual reference case.  Heinberg implicitly assumes that no one would actually propose Scenario One as a way forward.

Yet that is what has been haunting me these months, even more so since the US mid-term elections.  It seems to me that the trajectory we are on is Scenario One.  We talk the Scenario Two talk, some of us propose or wish for Scenario Three solutions, but the Scenario Oners are clearly carrying the day.  As I pondered this it occurred to me that the name “Oners” might be a useful characterization of those that so vigorously pursue and defend this dangerous course.  But that name sounded somewhat familiar.  And then it occurred to me.  Not “Oners” but “Once-lers” were the entrepreneurial family that extirpated the Truffula Trees in the Dr. Seuss environmental classic book “The Lorax” from 1971.

For those of you that haven’t had the pleasure, a quick précis of the book is as follows. (You can also watch the video here.)  The story opens in a polluted and barren land where a brave boy ventures to find the mysterious hermit called the Once-ler in order to hear the story of the Lorax.  The Once-ler, once bribed, narrates the tale that began long before with his arrival to this land which then was occupied by a rich forest of Truffula Trees brimming with wildlife.  Said trees had much economic value because they could be cut down and turned in Thneeds (a seemingly useless item that people thronged to buy).  A creature called the Lorax emerges from a stump to be the advocate for the trees and all the forest animals as the Once-ler recruits his extended family to establish an ever-expanding Thneed manufacturing complex.  The Lorax pleads with the Once-ler as the trees disappear and the air and water become polluted.  The Once-ler has some sympathy for the resulting loss of forest creatures but he is driven by the imperative that “business is business! And business must grow.”  At the climax of the story the Once-ler loses all patience with the Lorax and angrily lashes out at him yelling that he (the Once-ler) has his rights and he will keep on “biggering” his business, implying that the Lorax had no right to complain or interfere.   Just at that moment however, the very last Truffula Tree is felled and the Once-ler’s source of raw material is forever lost.  You will have to read the book to find out how it ends.  Suffice to say it is not a happy ending, but it does leave the reader with hope.

The startling thing about this childrens’ story is how accurately it presents both the flawed economic model that demands relentless limitless growth based on finite resources, and the way the Once-ler is so captured by the growth paradigm that he overrides his love of the forest and the creatures that dwell there.  He is not cast as an evil character but rather a deeply tragic one.  You never see the Once-ler’s face in this illustrated tale.  He is no one and perhaps everyone.

And so it seems that after 40 years we are living the Dr. Seuss story line in many respects.  The Once-lers are in charge and they have every intention of continuing to do what they do.  And just as in the book, some within the Once-ler community are angry and lashing out at those who point out environmental problems.  I just hope that doesn’t mean we are getting to the end of our story.

Gord Miller
commissioner@eco.on.ca

Good morning. It is my pleasure to be with you again to present the 2006-07 Environmental Commissioner’s Annual Report to the Legislative Assembly.

This year’s report is entitled “Reconciling Our Priorities” because, in standing back and taking a broader view of the environmental issues related to our plans for growth and development in the province, it becomes evident that we (as the expression goes) are trying to have our cake and eat it too. For that reason, this year I have structured the report a little differently. The report begins with two larger more comprehensive analyses. The first deals with the challenge of creating sustainable communities in Southern Ontario. The second looks at the need for a sustainable planning system for Northern Ontario.

The Southern Ontario sustainability analysis first focuses on the Greater Golden Horseshoe Growth Plan (GGH Plan) and considers how appropriate the projected growth is, relative to the carrying capacity of the landscape ecosystem to accommodate that growth. It concludes that the planning system of the province puts the cart before the horse. Population projections imposed on some communities for economic growth reasons exceed the available local water supply and the natural limits of the rivers to receive and assimilate the treated sewage.

Laudably, the Growth Plan seeks to improve the density of future development and improve transit opportunities in the growth areas. But, the targets are too weak. Where the target densities have already been achieved in past development, we have not seen a substantial move away from an automobile based lifestyle. Without a change in the car-based culture, we are going to see a million more cars trying to use the roads of the Greater Golden Horseshoe, and these will only spawn more congestion, more pollution and the unceasing demand for more roads, which will consume even more of the limited green space remaining on this crowded landscape.

Some of that threatened green space is wetlands. So I looked at wetland protection policies as a measure of the sustainability of the Southern Ontario landscape, and found that all is not well. Provincial policies purport to protect wetlands but in reality the policy system is failing. MNR is supposed to classify important wetlands, designate the ones that are provincially significant and see that these wetlands are identified and protected in municipal official plans. This is simply not happening to the extent required, and important wetlands continue to be drained and bulldozed.

The overall conclusion of this look at Southern Ontario planning and development is that the planning and approval processes that we use were designed for a former simpler time and are no longer adequate. They do not include an a priori discussion of the need for any given project. Nor do they permit a similar public debate about the conflicting consumptive uses of the land versus the natural heritage priorities involved. They are weighted in favour of extractive and destructive uses of the land, and they are deterministic in nature. They start society down a path toward approving a proposed undertaking without sufficiently considering whether Ontario should be on that path in the first place.

With regard to a comprehensive sustainable planning system for Northern Ontario, there simply isn’t one. In Northern Ontario, over 80% of the province is Crown Land, and that land is coming under increasing development pressure from expanded forestry, mining, hydroelectric projects, transmission lines and recreational uses. Yet most of the Crown Land isn’t subject to any kind of planning regime at all. My analysis concludes that the ministries involved in the North, – Natural Resources, Northern Development and Mines, Energy and Environment – all operate in isolation with little effort to co-ordinate or integrate the impacts of their approvals and activities.

It’s important to understand that there are actually three major planning zones in the North. The most southern portion is commonly known as the Area of the Undertaking (AOU). It gets its name from terminology in the Environmental Assessment Act because this area has undergone an environmental assessment review which means that it is legal to conduct industrial forestry in that area. By default, the Crown Forest Sustainability Act is the dominant planning mechanism on this landscape. This is also the area where the Ontario Living Legacy process identified and set aside 12% of the land in ecologically representative parks and conservation reserves.

Immediately north of the AOU is the area described as the Northern Boreal Initiative. I have written about this several times before. Not much has changed. Forestry still can’t be legally practiced there. There still is no area wide planning or review process to assess natural heritage features and lands that should be set aside. The one patch of land within this zone that has a plan, the Whitefeather Forest and Adjacent areas Community-Based Land Use Strategy, still awaits approval and implementation.

North of the Northern Boreal Initiative is a huge tract of land with considerable development pressure from mining and energy initiatives, that simply has no planning framework at all.

We need to plan our use of the land, and the development of its resources, for the socioeconomic needs of northern communities which are under so much stress at the present time. And we also have to appreciate that the vast forests and tundra of Northern Ontario have ecological significance on a continental if not global scale, and we have an obligation to manage and sustain those ecological values.

And, we haven’t got the tools and resources in place to do so. In the report I recommend a good starting point is to consider reforming the Public Lands Act to create a comprehensive piece of legislation that would set out detailed planning requirements and provide protection for ecological values.

Again this year I can report some positive developments in public policy relating to the protection of the environment and natural heritage. I commend the Ministry of Natural Resources for the Provincial Parks and Conservation Reserves Act. While not flawless, this legislation moves Ontario back to the forefront of protected areas law in Canada.

The Ministry of Municipal Affairs and Housing is commended for the Planning and Conservation Land Statute Amendment Act, a package of improvements in municipal planning and OMB reform.

The Ministry of the Environment brought forward the Clean Water Act, the last big piece of the drinking water reforms called for by Justice O’Connor in the Walkerton Report. It is a major step forward in protecting drinking water in the province and may also help safeguard the ecological integrity of aquatic systems.

Flowing from the applications we receive from the public, I have again this year highlighted some of particular interest. There was a request to review the need to eliminate the exemption from Environmental Protection Act requirements for road salt applications. I have made a recommendation to develop a province wide road salt management strategy because I think the time is right. Certainly the Ministry of Transportation has implemented some quite remarkable road salt management initiatives and technologies on the 20% of the roads they are responsible for. These need to be expanded across the remaining 80% of the road network, which is serviced by municipalities.

The results of a long awaited review of the aggregate resources program were reported this year. The review confirmed that there are problems in the regulation of the industry, especially with rehabilitation of old pits and quarries, and laid down the bases for reforms to be implemented.

Strangely, the MOE denied an application which asked for a review of the standards governing the quality of sewage biosolids. It is odd that they would refuse to consider having a category of pathogen free sewage sludge like the USEPA does, in light of the difficulty finding suitable utilization sites for sewage biosolids

And, an application regarding the Portlands Energy Centre was received. It highlighted the problems that occur when the MOE approves a new air pollution emitter in a highly urbanized area already burdened with the accumulating effects of neighbouring existing emitters.

Thank You

This 2006/2007 ECO annual report was submitted to the Speaker of the Legislative Assembly on December 4, 2007. You can read the report online here, and find out more information, and download the report and associated materials, here.