I am an ecologist for an…

I am an ecologist for an environmental consulting firm with a background in terrestrial and
aquatic ecology. I have over six years of experience as a biologist, with current experience
providing advice to housing developers on project design, including recommendations to
mitigate environmental impacts.
I am deeply disappointed in Ontario's proposed approach to housing development and am
looking for your help.
The provincial government is overhauling policies related to the development of housing to
make the process more streamlined amidst the current housing crisis. I agree that solutions are
needed to address this crisis, but the province’s approach is not the right path forward.
Rather than promote vertical growth and urban intensification/densification, or expedite
processes related to construction, the province proposes to diminish standardized criteria used
in evaluating wetlands. In our province, wetlands are evaluated using the Ontario Wetland
Evaluation System (OWES), a science-based ranking system that determines wetland
significance based on values to humans and wildlife. Wetlands that are evaluated as provincially
significant receive special protections under the Provincial Policy Statement. Wetlands are
subject to evaluation and associated protections because they provide a vast array of important
environmental services and are complex, unique ecosystems. These services benefit not only
biodiversity but also humans through economic functions (e.g., wood products, furbearers,
commercial baitfish), social functions (e.g., recreational activities, education, landscape
aesthetics), and hydrological functions (e.g., flood and stormwater attenuation, water quality
improvement, pollution uptake, carbon sink functions, erosion control, and protection of
drinking water sources).
Under Bill 23, two critical components of OWES that contribute to the designation of
provincially significant wetlands would be slashed: 1) consideration of habitat for endangered
and threatened species, and 2) wetland complexing, such that wetland units are considered in
isolation rather than interconnected features with similar or complementary functions.
Removal of these components from OWES has significant implications for future development
applications. Currently, OWES scoring heavily weighs the presence of critical habitat for
endangered/threatened species, and the presence of such habitat automatically deems a
wetland provincially significant separate from other scoring criteria. OWES would not consider

this under Bill 23. In terms of wetland complexes, many wetland units that have provincially
significant status as part of a larger complex are unlikely to qualify as provincially significant on
their own if re-assessed in isolation. This opens a tactic to remove wetland units from
provincially significant complexes in re-assessments so that they can be individually developed.
Under Bill 23, future wetland evaluations are unlikely to meet criteria for provincial significance
and associated protections since only smaller pockets of wetland will be considered (not
complexes), and habitat for endangered/threatened species will not be addressed. When
municipalities and regulators consider each loss in isolation, it may not seem significant.
However, I am particularly concerned about the cumulative effects, which would not be
considered and are likely to result in significant wetland losses. The functions of wetlands that
benefit Ontarians are completely overlooked under Bill 23. With climate change it is expected
that we will experience an increase in the frequency and intensity of floods and removing
wetlands will only exasperate that.

As you are aware, the provincial government recently slashed regulating authority and
stewardship activities led by Conservation Authorities. Bill 23 involves further disempowerment
of Conservation Authorities yet is tasking them with leading future wetland evaluations instead
of the Ministry of Natural Resources and Forestry, who currently oversees this. This suggests
that the regulation of wetlands will be further weakened.

Ultimately, the province is attempting to make it easier to build in wetlands, risking the loss of
the valued functions they provide, and counteracting efforts to prevent the extirpation of
vulnerable species that inhabit wetlands.

I am requesting Bill 23 is not passed/approved for the reasons I outline above, along with
many others related to proposed changes to the municipal planning process and the
Conservation Authorities Act.

Thank you for your time and consideration.