Wednesday, August 23, 2017

4-Laning MR 35 and the Multi-Million Dollar Costs of Convenience, Part 1

Hey, Greater Sudbury – I think it’s time we had a serious conversation about roads.  Specifically about how building more roads and enlarging existing roads are not meeting the needs of municipal residents.  Our City is spending a lot of money on roads projects – but there is little evidence that these projects will improve public safety, reduce congestion or greenhouse gas emissions, or help make Greater Sudbury a prosperous City in the 21st Century.  I realize that the position that I’m taking here won’t be a popular one – but it is, nevertheless one that is informed by evidence, and motivated by a desire to help improve our City and the quality of life of all residents.

I’m going to start this discussion with an example – Municipal Road 35 (MR 35) – the road that presently links Sudbury to Azilda and Chelmsford.  It’s a road that has long been identified to be “improved” by 4-laning the section between Azilda and Chelmsford (the road is 4-laned right now between Sudbury and Azilda).  Recently, our municipal Council voted to start moving ahead with the 4-laning (see: “4-lane construction on Municipal Road 35 to start in 2018,” CBC News, July 12, 2017).  The cost of this project is estimated to be $38 million, to be paid for through debt financing.

We’ve been told by our municipal officials that we have to 4-lane MR 35 to make it safer.

4-laning MR 35 will make the road less safe.

We’ve been told by our municipal officials that we have an ‘ethical obligation’ to 4-lane MR 35.

At a time when the City of Greater Sudbury is not going to grow, there is no ethical reason to 4-lane MR 35.

We’ve been told that debt financing this road will not cost taxpayers any money.

It is inconceivable that debt financing this project, or any other road project, won’t lead to real costs for taxpayers – potentially in the form of reduced services or higher property taxes.  When you add this project to the growing list of projects that our current municipal Council wants to finance through debt, the implications on our municipal budget become even more problematic.

Why Build and Expand Roads Now?

What’s going on here?  What is really motivating our municipal officials to champion 4-laning MR 35 – and to talk about new roads projects, like Phase 2 of the Maley Drive Extension, 6-laning MR 80 between Kathleen Street and Hanmer, and building the Barrydowne Extension.  All at a time when, according to the City’s own numbers, only very modest growth will occur – just 10,500 people between 2013 and 2033 (see: "Growth Outlook to 2036, City of Greater Sudbury," Hemson Consulting Ltd., May 2013).  The Ontario Ministry of Finance projects growth of less than 2,300 people for Greater Sudbury between 2016 and 2041 (see Table 14.6: Population by five-year age group, 2016-2041 – reference scenario – Greater Sudbury, “Ontario Population Projection Update, 2016-2041, Table 14: Northeastern Ontario and its census divisions, population by five-year age group, 2016-2041,” Ontario Ministry of Finance).

Municipalities usually build roads when there is an expectation that they will be required to meet future needs.  Roads are also typically widened in order to address issues related to safety or expansion brought on by additional use, often as the result of residential or jobs-related growth.  In absence of these factors to motivate building more roads and upgrading existing roads, it seems there is little reason to continue building roads.  Roads cost money.  A lot of it. If we need roads to facilitate a future economic payoff, that’s one thing.  But in Sudbury we are building roads for one reason and one reason only: convenience.

There.  I’ve said it. There is only one argument that is supported by the evidence that provides a rationale for 4-laning MR 35: convenience for motorists.  

There may be a second rationale, but it is more difficult to find quantitative evidence to support it, even though my own gut suggests that there is some merit to it.  That rationale is as follows: incumbents on municipal Council will get more votes for 4-laning MR 35 than they would otherwise if they did not move forward with 4-laning MR 35.

Let’s look at some of the reasons we’re being told we need to 4-lane MR 35 and deconstruct those, first.

An Old Promise

We keep hearing that the former residents of Rayside-Balfour were promised a 4-laned MR 35 at the time of amalgamation, because that plan was in place when the Slots at the Downs materialized in the late 1990s.  Despite hearing about this again and again, particularly from Ward 3 and 4 members of Council, there has been no actual evidence ever produced to support anything akin to a promise or commitment to 4-laning – beyond what has appeared in the 2005 Transportation Study and the 2016 Transportation Master Plan.  Those latter two documents do show that 4-laning MR 35 as being one of many roads priorities.

At times in the past, municipal Councils have prioritized road projects.  MR 35 has, for the longest time, been number 2 on that wish list, right behind Maley Drive.  So yes, from the perspective of adhering to municipal transportation planning documents and municipal commitment subsequent to amalgamation, there is a case for moving forward with MR 35.  But this notion that the City somehow owes 4-laning to the residents of the former municipality of Rayside-Balfour – there’s just nothing there.

As for those Transportation documents, I’ll be taking a closer look at the 2016 Transportation Master Plan later in this blogseries – in order to provide evidence that 4-laning MR 35 is not necessary – or necessary only from one perspective: making getting around by car more convenient for motorists.


We hear that 4-laning MR 35 (and other roads) will lead to a safer environment for motorists.  This argument is often made without the benefit of supporting evidence.  Why?  Because, generally speaking, the evidence points to how 4-laning roads actually creates a less safe environment for road users (unless contraflow lanes are safely separated from one another, as in a divided highway).

Let’s step back a moment to figure this out.  Why do we 4-lane roads?  Because we expect volumes to increase – that is, we expect the number of vehicles on a road to increase.  Or, we 4-lane a road because the road is already deemed to be over its capacity to meet current needs.  In both of these scenarios, the outcomes of doing nothing are congestion – in the first, we see congestion grow because of additional vehicles.  In the second scenario, there may be additional congestion if more users use the road, but if the status quo is maintained, it’s still congestion.

Where roads are congested, traffic tends to move less quickly than on wide-open roads that have little or no congestion.  Vehicles travelling at higher rates of speed create greater risks for all road users (see: "Speed and accident risk," Speed and Transport, Road Safety, the European Commission).  Collisions that occur at higher rates of speed are typically more hazardous to those involved, and more expensive to deal with (see: "Travelling Speed and the Risk of Crash Involvement," Kloeden CN, McLean AJ, Moore VM, Ponte G, NHMRC Road Accident Research Unit, The University of Adelaide, November 1997).  The faster the rate of motorized vehicles travelling along a road, the less safe that road becomes for all road users (see: "Everyone Knows We Have A Traffic Problem," Strong Towns, March 16, 2017).

Congested roads can be hazardous to drive on in urban settings, due to the numerous things which can sidetrack drivers – from having to read street signs, to navigating intersections, etc.  But the physical situation that exists between Chelmsford and Azilda has few of impediments.  Sure, there’s the odd driveway along the road, but generally speaking, traffic moving between Chelmsford and Azilda does so with few impediments.  It is expected that the rate of vehicular travel will increase along this stretch of road as a result of 4-laning.

Enforcement of maximum speed limits might help, but even then, it can be expected that the rate of speed will be at the maximum throughout the journey between Azilda and Chelmsford – which is mostly 80 km/h.  Lowering maximum speed limits along this stretch of road to 60 km/h, coupled with enforcement, would do more to make the road safer than 4-laning. If safety is a significant concern, these are inexpensive ways to address it (photo radar should be considered, too – but there is an up-front cost associated with that).

Clearly, all else being equal, 4-laning MR 35 will not make the road safer.

Induced Demand

But all else won’t be equal.  Based on the City’s own numbers, we can expect to see a greater percentage of the City's traffic travelling on MR 35 between Sudbury and the former Rayside-Balfour and Onaping Falls areas of the City – thanks to – you guessed it – 4-laning MR 35.  The City's Transportation Master Plan (TMP) says a 4-laned MR 35 should see as much as 20% more traffic than if the City were to do nothing to upgrade roads (see red-underlined text in Figure 1, below). It’s a phenomenon known as ‘Induced Demand’ – something like, “if you build it, they will come”.  

Figure 1 - From TMP, Rayside Balfour Peak PM Movement, Expected Results, Sustainability Focused Alternative

If you make a road easier to drive on, more people will drive on it.  Sudbury isn’t immune from this experience – even though we need to temper expectations about road use due to the lack of growth we see occurring here, along with changing demographics.  In other words, although induced demand is a real thing and we can expect it to occur on our roads, the impacts of induced demand will not be as significant as they would be if we were in a fast-growing City.  We shouldn’t expect the same thing to happen to MR 35 that happened in Houston with the Katy Expressway, for example (see: “Reducing congestion: Katy didn’t: How 23 lanes of highway induce demand in Houston,” Joe Cortright,, December 23, 2015).

So MR 35 will be widened, and traffic will move faster.  There will also be more of it.  But wait – we’re only going to experience modest growth.  The 2016 Transportation Master Plan is built on the assumptions found in the 2013 Hemson Report.  Does this mean that all of those 10,500 additional people that the City will grow by between now and 2033 will be moving to Chelmsford, adding to traffic volumes between Chelmsford and Azilda?

Inner City vs. Outlying Areas - Tensions

Well, no.  That’s not what it means.  But there are a couple of things at work here that we need to understand, while keeping in mind that we will be experiencing only very modest growth over the next 15-20 years.

Figure 2 - From the 2016 Census, Greater Sudbury CMA

The first is a trend, confirmed by the census: generally speaking, census divisions in the former City of Sudbury are losing population, while certain census divisions in the outlying areas are gaining population.  This trend means that what little growth we are experiencing is, for the most part, ending up in the outlying areas.  This is happening for a number of reasons, including the existence of a property tax regime that favours the outlying areas.  One of the biggest reasons, however, is that the City has made it so very easy and inexpensive for car owners to get around – and that’s costing us a lot of money.

That portion of the City’s budget set aside for roads is much larger than other cities - it's a full 25% of our municipal budget (see page 8 of "Moving our City Forward", City of Greater Sudbury, 2017).  In part that’s due to the number of lane kilometres of roads that a City the physical size of Greater Sudbury has to maintain.  We know that we’re already behind the 8-ball with road maintenance on existing roads (see: "City of Greater Sudbury, Financial Planning for Municipal Roads, Structures and Related Infrastructure," KPMG, July 10, 2012).  A sure-fire way to dig ourselves further into a hole is to build more roads.  But that’s just what we’re doing.

And by building more roads to the outlying areas, and upgrading existing roads to facilitate the flow of convenience traffic, we are in fact making it easier for new and existing residents to select the outlying areas as their communities of choice.  That may sound like a good thing – after all, don’t we have an interest in the health of all of our communities?

Sure we do – but in this scenario, I’ve equated population growth with health.  It doesn’t always work out that way, however.  Consider that Greater Sudbury’s population is going to grow only modestly, and you’ll see what I mean.  While population may be relocating to the periphery of the City, jobs and commercial activities for the most part are not.  In fact, we are seeing declining commercial areas in outlying communities.

And would should we expect those residents of outlying areas shop in ‘downtown’ Val Caron or ‘downtown’ Chelmsford when it’s so easy (getting easier!) to hop into a car and drive to Costco?  We shouldn’t expect it at all, and we don’t see it happening. Sure, there’s some new commercial development happening, but even in the former City of Sudbury, existing commercial areas are at threat to changing market forces.

In Greater Sudbury’s case, making it easier for people to drive means that more people will be driving.  That’s not a healthy outcome for the former City of Sudbury that is, generally speaking, losing people and vitality.  And it’s not a healthy outcome for increasingly car-dependent outlying communities.

What do the numbers in the TMP have to say about this trend?  Well, let's take a look at how many trips are made just within the former City of Sudbury at the peak PM period.  Baseline data (figure 3, outlined in green) shows a total of 14,551 trips made within the former City of Sudbury, out of a total of 27,051 trips overall (I've added all of the numbers together to arrive at 27,051).  That's 53.8% of existing trips made just within the former City of Sudbury.

Figure 3 - From TMP, Table 4, Existing Traffic Volumes, Peak PM Period
Fast-forward to the future in which the 'Sustainability-Focused' alternative of the TMP has been implemented.  Although the total number of trips within the former City of Sudbury has no grown to 15,108, the overall number of vehicular trips made within the entirety of the City has grown more quickly - up to 29,665 (see Figure 4, green outlined box - and all numbers added together).  That means that as a percentage of overall trips, those made within the just the former City of Sudbury have fallen - to 50.9%.  The distribution of trips in this 'alternative' future is one where the outlying areas continue to grow more quickly, at the expense of the former City of Sudbury.

Figure 4 - From TMP, Table 28, Sustainability Focused Traffic Volumes, PM Peak Period

Servicing Costs for Urban, Suburban and Rural Areas

The second trend has to do with servicing costs and how much we pay for the services we get.  It is a well known fact that providing municipal services to people living in denser parts of a City is less expensive than providing those same services to people living in less dense areas.  The more people there are in the same volume of space, the greater the amount of tax revenue they generate (even if not all individuals are paying the same amount of taxes as those taxpayers living in less-dense areas are).  Yes, it is true that denser areas of our cities tend to have more streets and more public service amenities – but keep in mind, these streets and libraries and museums are often providing service to many more people than just the ones who live there.  That’s why downtowns are becoming popular places for municipalities to direct people to live in again: the streets are already there, providing a service to those working, shopping and recreating downtown.  They can serve double-duty for new residents.

In the suburban landscape, that’s just not the case.  Most suburban streets are rarely visited from those outside of the suburban enclave.  They exist mostly to benefit a smaller number of property tax payers – smaller in terms of an actual overall number of people occupying the same amount of space as the urban dwellers – and smaller, too, because they are more exclusive-use.  Sure, there are some major arterials that see significant use – but most suburban and exurban roads that service residential users are extremely under-utilized.
And yet the costs of maintaining these different types of roads are generally about the same.  Sure, wear and tear is going to take a greater toll on more well-traveled thoroughfares – but the costs of snowplowing, for example, will be roughly equal.  And other costs may be determined by the physical size of our roads – something to keep in mind as you find yourself travelling down large, mostly empty suburban streets.

I know this is a hard lesson for Greater Sudbury, but it’s one that we simply have to learn: It costs more to service our outlying areas than it does the inner City.  I get it – that truth will never resonate with Valley folk who still believe that they are subsidizing the inner City when all evidence suggests otherwise.  I state these facts not to play one area of the City off against another – I state them because they are true in all other areas, and that it is inconceivable that they would not be the truth here in Greater Sudbury.  If our City ever wanted to produce evidence to measure just how much difference a taxpayer in the outlying areas is paying compared to an inner city resident, the City could undertake that study.  But the trouble is, once it’s undertaken the study, residents might expect the City to begin taking action on it.

And our City Council members, I’m sure, wouldn’t want to do that.  Because it would mean an end to Area Rating.  It would mean an end to promoting car-centric development in the outlying areas.  It would be a road map to sustainability – and voters in Greater Sudbury would likely rebel.

Sustainability - Not Growth - Needs to the Focus in a Fiscally Constrained Future

Regular readers of my blog will note that I've been writing about these urban trends for years.  I continue to believe that the City's economic prosperity is being jeopardized by municipal incentives that direct development to those parts of the City which are the most costly to service (for one example, see: "Prosperity in a Low-Carbon Economy: Greater Sudbury Should Say "No" to Costly Rural Residential Development," Sudbury Steve May, September 27, 2012).  I acknowledge that these evidence-based ideas are not popular ones, as, if implemented, may impair people's enjoyment of the unfettered use of personal vehicles.  Nevertheless, in a fiscally-constrained economy - one that is not growing or only growing modestly, and where the costs of many inputs are rising (energy and fuel costs in particular), it's been clear to me for a long while that pursuing growth for the sake of growth is irresponsible - and puts families like mine and yours at risk.

I understand that growth can, and does, create generally positive outcomes for taxpayers while the growth lasts (generally, because in situations of high growth, there can be negative social costs - something we haven't had to worry about in Ontario recently, but think of northern Alberta in the mid-2000s).  But that's not the City of Greater Sudbury's circumstance - and the forecasts all point to a stagnant or only modestly growing population base.  And even then, the City is going to get older - so the growth in population might not actually lead to much growth at all in terms of the economy, as older people tend to work less and tend to derive a larger percentage of their incomes from fixed sources, like pensions.

With this in mind, sustainability should be the focus of our City (see: "Sudbury column: Sustainability must be focus of development," the Sudbury Star, February 7, 2015).  But clearly that's not the direction that we're headed in - at least not with a Transportation Master Plan that, even with a 'Sustainability-Focused' alternative, will see a large number of new roads built and existing roads widened - all to facilitate even more vehicular movements on our roads, even as our population levels off and our economy shrinks.

The costs of widening just a short section of one existing road are likely far more than the City can afford.  Indeed, widening MR 35 between Azilda and Chelmsford has been on the books now for over a decade, and our City still can't afford to undertake this project without borrowing a significant amount of money - $38 million that taxpayers will have to pay back.  

And what will we get for $38 million?  That's something that I'll look at in Part 2 of this blogseries. The short answer is, however, nothing that helps us move in the direction of 'sustainability'.

(opinions expressed in this blog are my own and should not be interpreted as being consistent with the views and/or policies of the Green Parties of Ontario and Canada)

Tuesday, August 15, 2017

Open Letter to Greater Sudbury Council re: Kingsway Entertainment District Site and Building Design and the Need for Public Engagement

The following is an open letter to Greater Sudbury Council re: the Report to Council dated August 9, 2017, from CAO Ed Archer regarding Site and Building Design for the Kingsway Entertainment District.


I am writing today with regards to a Report to Council, dated August 9, 2017, prepared by CAO Ed Archer, with regards to the Kingsway Entertainment District and the community events centre development initiative (see:  The Report proposes that Council endorse a number of actions as part of a way towards developing lands on the Kingsway for a community events centre and a casino, including confirming a single-source contract for Cumulus Architects, described as the architect for Gateway Casinos.  The Report also recommends that Council proceed with site and building design in conjunction with obtaining land use approvals.

I strongly urge Council to hold off on issuing a single-source contract to Cumulus Architects, and to not proceed with site and building design until appropriate land use approvals for a community events centre and casino are in place.  Similarly, I also strongly suggest that Council not finalize any property purchase until appropriate land use approvals are obtained.

At this time, the subject lands are not zoned to permit a community events centre or casino.  While I understand that the Report is recommending that Council add a 'community arena' use to the zoning for lands intended to be used for a community events centre, it is not clear that this approach is in keeping with the City's Official Plan, as community facilities of this nature appear to only be permitted in Regional Centres and the Downtown (the proposed use does not appear to be contemplated for lands designated Industrial by the Official Plan).  Further, the City has already expressed a position that a land use permission for a casino in the Kingsway location will require an amendment to the Official Plan.

Site and building design are likely to be constrained by specific land use issues unique to the site.  For example, we know that there are development constraints already on the site in the form of necessary setbacks from the existing landfill area.  An analysis of site topography may also identify restrictions for development.  On an earlier (2014) application to rezone part of this property, the City of Greater Sudbury identified two other significant issues which appear to require further study, namely: the potential presence of species at risk habitat on the subject lands (blanding's turtle and whippoorwill); and issues related to traffic.  Issues related to road salt and the contamination of surface water from runoff into the Ramsey Lake Watershed - a significant source of our City's drinking water - may also lead to further development constraints.

Proceeding towards site design at this time, without first knowing whether the proposed uses are appropriate for the lands, or what development constraints may be imposed through further technical studies related to natural heritage, community safety and traffic, is akin to putting the cart before the horse.  It may also lead to the costly duplication of designs and cause the City to spend more taxpayers money to resolve issues after the fact.

The single-source contract to Cumulus is suggested by the Report due to what are perceived to be time constraints with site and building design.  The Report does not appear to take into consideration the need for public consultation and engagement.  The Kingsway Entertainment District, anchored by a new community events facility and a casino, represents a once-in-a-generation opportunity for the City.   The development of this site should not be rushed.  Development, including site and building design, should benefit from significant public engagement.  For example, we have a chance to here to create true carbon-neutral facilities, which will assist the City in meeting its greenhouse gas reduction commitments.  We have the opportunity to influence the flow of traffic along the Kingsway through the creation of high occupancy vehicle lanes.  And we have the opportunity to design the site in such a way that it is truly integrated into the physical and natural environment, including the use of bioswales and permeable hard surfaces to address stormwater runoff issues.  There are likely many other design elements that the public would like to see addressed through a comprehensive design process that truly engages the public.

The legitimacy of the entire project may be at risk if Council does not receive the public's buy-in through significant engagement. After all, it's our tax dollars that are going to be paying for this project.  Any site and building design process that does not commit to fully engaging the public will be problematic for the City to obtain the social license it needs to move this development initiative forward.

With this in mind, I strongly urge Council to reject the Report submitted, and to not pass the recommended resolutions.  Instead, I urge Council to direct staff to undertake a Secondary Plan for the entirety of the Kingsway Entertainment District, so that all land use issues, including the appropriateness of the site for the development proposed, along with planning constraints, may be addressed in a truly comprehensive manner that engages the public.  I have written to Council about the need to for a comprehensive process for this new District in the past (see: "An Open Letter to Greater Sudbury Council Regarding a Kingsway Entertainment District," July 11, 2017).  I again implore Council to consider a Secondary Plan as the only legitimate way forward for the Kingsway proposal.

At the very least, please hold off on site and building design until land use permissions are obtained.  And please ensure that significant public engagement is built into any site and building design process.

Thank you for considering these comments.

(opinions expressed in this blog are my own and should not be interpreted as being consistent with the views and/or policies of the Green Parties of Ontario and Canada)

Monday, August 14, 2017

Site Design for the Kingsway Entertainment District Must be Unfettered by Constraints, Include Public Engagement

Whoa. Hold your horses, City of Greater Sudbury! 
A report dated early August from Ed Archer, Greater Sudbury's CAO, envisions moving the Kingsway event centre and casino developments ahead via some form of 'comprehensive process'. It sounds good, but it certainly appears that the process the CAO has in mind is one that will likely shut the public out of meaningful engagement. Par for the course for Greater Sudbury.
Some things to be concerned about:
1) Although 'public consultation' is referenced as part of a "Site Design Strategy", the timeframes are short. And since the strategy is to be led by Gateway Casino's preferred architect, it's not clear at all how much of an influence public opinion might have on the shape of the buildings and the overall site (Archer's report goes to some length to indicate that many of the design elements of a casino are pre-determined - which, I'm sorry to say, is nonsense - if the province is going to invest in a building to meet the needs of our community, it ought to bloody well meet the needs, and not come in a pre-fab buildable box).
2) About that sole-source contract. Why is the City suggesting that only an architectural firm - one used by Gateway - is the appropriate vehicle for site design? We're talking about a project that is MUCH larger than a casino here. Why not tender, and let's see if we can get some interesting and innovative firms to get involved with the design of this new Entertainment District? I realize that there is a perception that "time is of the essence" - but give me a break - we are talking about a once-in-a-generation project here. Let's not rush this.
3) Public involvement must be an integral part of site and building design. I sincerely hope Council amends the Report so that it's clear that public consultation and engagement must take place throughout the process - at the beginning, pre-conception; and after a concept plan for the site is developed. The public must be involved in helping shape the direction of this development.
4) Oh, and about the desire to comprehensively develop the site? How is that going to happen when the Report also directs the City to beging a re-zoning process for a 'public arena' use? No way. The rezoning needs to be put on hold and addressed as part of a larger Official Plan process - a process envisioned by the report as necessary for the Casino use to move forward. You can't address development 'comprehensively' when you first go ahead and set out the criteria for a portion of that development through zoning - not unless you're willing to revisit zoning at a later date. And that doesn't appear to be in the cards here, and frankly would be redundant.
5) There is no need to start building roads here now - not until issues of servicing and a comprehensive site design process that plugs in the public has been completed. If you start building roads, you constrain the design process - and that's absolutely not the way to do it.
6) Purchasing the property prior to determining whether the site is appropriate for an arena is also something that our Council ought not to be doing. If zoning eventually can't be achieved, the City is going to be left with a piece of worthless, unserviced industrial property. Taxpayers need to be protected here - Greater Sudbury needs to postpone the purchase of this property until all planning approvals are in place.
So while I agree that the notion of 'comprehensive site development' is one that the City ought to strive for, clearly this Report is mostly unhelpful in moving us in that direction. Plug the public in, stop introducing site constraints, and start by providing facts to the public so that we may participate in a design process informed by this information (like, how much is servicing this site really going to cost taxpayers?).
Again, this is a once-in-a-generation project. Let's take the time we need to make sure that we get this right.

(opinions expressed in this blog are my own and should not be interpreted as being consistent with the views and/or policies of the Green Parties of Ontario and Canada)

Tuesday, August 8, 2017

It's Going to be More Difficult to 'Drain the Swamp' in Ontario

“Drain the swamp!” might have been the cry that helped put Donald Trump in the White House, but as far as preserving Ontario’s natural heritage goes, it’s really bad advice.  Swamps and other wetlands – bogs, fens and marshes – have been disappearing from the landscape at an alarming rate.  Once viewed as unproductive land that stood in the way of expanding agricultural operations and subdivisions, the movement to conserve wetlands for their ecological functions has been growing.

What Donald Trump might not understand is the very important role that wetlands play in climate change mitigation and adaptation. Northern Ontario’s vast Hudson Bay Lowlands contain some of the most extensive peatlands in the world.  These “unproductive” bogs are actually providing a significant ecological service to the planet by sequestering carbon – as much as one third of Ontario’s annual carbon emissions, according to provincial figures.  Smaller wetlands in developed urban areas can also help regulate temperatures by minimizing heat island effects.  Wetlands also stabilize soils and decrease the impacts of flooding events.

Last month, the Ontario Ministry of Natural Resources and Forestry released its much-anticipated “Wetland Conservation Strategy for Ontario”.  An earlier draft of this strategy had drawn some critical comments from environmental organizations like Ontario Nature, and Conservation Ontario – the umbrella organization for our province’s 36 Conservation Authorities.  The good news for wetlands is that Minister Kathryn McGarry seems to have listened to the advice of the conservation experts – for the most part. (see: “Help protect wetlands,” Ontario nature, November 9, 2016, and “Conservation Ontario’s Comments on “A Wetland Conservation Strategy for Ontario 2016-2030” (EBR# 012-7675),” January 9, 2017).
The new strategy includes important targets for halting the net loss of wetlands by 2025, and achieving a net gain in wetland area and function by 2030. Using 2010 as a baseline, these targets will provide a yardstick for the Province to measure the success of the strategy’s implementation.

The strategy calls for additional funding for mapping wetlands - an important starting point for the discussions that need to take place between the various level of government and governmental organizations charged with looking out for the health of wetlands.  Indeed, the the web of bodies who oversee wetland conservation sometimes appears to be as complex as a wetland ecosystem.  The strategy acknowledges the roles of all partners, and states that it wants to do better - but it seems that some gaps still remain.

The gaps are there because oftentimes wetlands are located inconveniently on private lands.  Regulating land uses on private lands isn't as straightforward than for lands in the public domain.  And that's where a lot of Ontario's wetlands have been lost.  Many of the existing tools identified in the strategy are ones that aren't being used in many cases to protect wetlands - and the toolbox itself might not be large enough.  Cut and fill by-laws might prevent wetlands from being filled in by private landowners, and municipal tree cutting by-laws might protect trees from being harvested, but there is little protection for wetland 'understory' - all of the other plant species that make wetlands wet.  Even today, authorities appear to be perplexed about how to save a significant Great Lakes coastal wetland from a private landowner bent on destroying it (see: "Sault residents react to developer's logging activity,", July 27, 2017).

Still, there's a lot of good in the strategy - from raising awareness to promoting partnerships, to a commitment to protect and conserve all wetlands deemed provincially significant in mid- and Southern-Ontario.  The strategy also calls for a review of the Ontario Wetlands Evaluations Manuals, which might strengthen wetland evaluation (see: “What will the future hold for Ontario’s wetlands?” Ontario Nature, August 3, 2017).

The strategy, however, stops well short of extending protection to all wetlands.  Only the largest, most diverse wetlands – those determined by evaluation to be provincially significant – will remain protected.  Regional and local wetlands will continue to be exposed to displacement by development.  The difference now will be that where wetlands fall victim to urban and economic development, they may need to be replaced elsewhere.

This practice is known as “offsetting” and it’s extremely controversial. On the one hand, offsetting can assist in achieving a net gain of wetlands by allowing less-productive natural wetlands to be destroyed based on a commitment to build or enhance a wetlands elsewhere.  On the other hand, the ecological services provided by smaller wetlands are not well understood, and permitting their continued destruction may lead to negative local outcomes.

Offsetting could lead to the creation of ‘Big Box’ wetlands at the expense of local diversity. And that seems to be at odds with the results of a recent University of Guelph study that determined smaller wetlands are more effective than larger ones at filtering pollutants before they enter rivers, streams and lakes (see:“Destruction of small wetlands leads to more algal blooms, Ontario study finds,” Sudbury.Com, July 23, 2017).

Ontario has already ventured down the offsetting road for species at risk habitat.  The results have been mixed.  While offsetting is a practice intended to be used as a tool of last resort, that’s not what appears to be happening , with roads like Sudbury’s Maley Drive and other infrastructure projects being pushed through the habitats of threatened and endangered species without much in the way of assessing alternatives (see: "Ontario's Environmental Assessment Process is Failing Species At Risk in Sudbury," Sudbury Steve May, April 26, 2016).

Ontarians should continue to demand the government to conserve all wetlands – not just the largest - for their natural heritage values, biological functions and the role they play in climate change mitigation and adaptation. However, even with offsetting, one thing is clear: it’s going to be harder to justify ‘draining the swamp’ in Ontario in the future, due in large part to the Province’s collaborative wetlands strategy.

(opinions expressed in this blog are my own and should not be interpreted as being consistent with the views and/or policies of the Green Parties of Ontario and Canada)

An edited version of this post originally appeared in the Sudbury Star, as "May: Getting harder to 'drain the swamp' in Ontario,'" online, and in print as "May: It's getting harder to 'drain the swamp' in Ontario," August 5, 2017 - without hyperlinks.