I can offer a unique…

ERO number

019-6160

Comment ID

65330

Commenting on behalf of

8Trees Inc.

Comment status

Comment approved More about comment statuses

Comment

I can offer a unique perspective on both Wetland Evaluations and Development Planning, having worked as a provincial biologist-wetland evaluator for 35 years and now as a private consultant and Species at Risk expert. The wetland evaluation system was brought into place by the progressive conservative government in the early 1980s. The purpose of OWES was intended to help the local planning authorities discriminate significant wetlands from non-significant wetlands, so they can make better decisions on development planning.

The Wetland evaluation system (OWES) is science-based to remove political bias. Significance is based upon wetland functions including how they protect lands from flooding, erosion, climate change (stochastic weather events), water quality, habitat, forestry, fisheries, and rare species. To remove any one of these functions from the evaluation system would bias the outcome politically and set environmental planning backward 40 years.

The OWES system has changed over the years. Originally there were 7 categories of significance, the first being the highest level of significance and included wetlands like the Wainfleet Bog, Point Pelee, Long Point Marsh, Point Abino wetland, Willoughby Marsh, Grand River Marshes, Holland Marshes for example. And the seventh category would be small wet- naturalized areas commonly found around old ditches and abandoned farm fields. It was easy to see the difference in protecting these large significant areas over a patch of cattail in a farm field. However, when the Wetland guidelines were incorporated into the Provincial Policy Statement under the Planning Act, the original seven categories of significance were oversimplified into just two categories (significant or not significant). Over the years the OWES has been reassessed and changes made and the knowledgeable provincial biologist's role within the development planning process at the local level has been removed. This kind of expertise is also not usually available within each municipality. Municipalities now rely on the expertise provided within an Environmental Impact Study prepared by the landowner’s consultant and the review by either the Conservation Authority or Region. The Region and the Conservation Authorities rely on the Provincial Policy Statement and their regulations and policies to provide advice to the municipalities during their review. Their policies have changed now to include all wetlands for protection including the small wet areas regenerating in a farm field, and they have automatically applied restrictive buffers away from any of these wet areas. The outcome of the plan reviews has become oversimplified today and is more about checking off a list of planning boxes than applying knowledge gained from the EIS. The result is an automatic application of restrictive policies and buffer distances from all wetlands significant or not. Landowners now have to protect all “wet areas of land”, interpreted without the objectivity OWES system and the result is a loss of potentially developable land.
My recommendation is to not throw out the objective processes, which is OWES, and the EIS but to reconsider the policies that remove the actual objectivity from the land use decisions. Review the policies that no longer incorporate OWES, those that require the automatic buffering of a feature and therefore reduce developable land unnecessarily.

The OWES was recently reviewed and updated in 2018 and the Provincial Policy Statement was originally updated in 2020 and many Regional and Municipal Official plans were updated in 2022. Please, do not make a science base process the scapegoat for the housing crisis.