Ontario Wetland Evaluation…

ERO number

019-6160

Comment ID

73216

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

Ontario Wetland Evaluation System (OWES) assessments are critical tools to identify and designate Provincially Significant Wetlands (PSWs). Designation as a PSW results in a high level of protection for wetlands under provincial law and policy.

If the proposed changes to the OWES are realized, very few wetlands would be deemed provincially significant in the future. Additionally, many (if not most) existing PSWs could lose that designation. In future, very few of Ontario’s wetlands would benefit from the protection that PSW designation currently provides.

The most urgent concerns about the proposed changes to the OWES are:

1. Wetland complexes will no longer be recognized or considered - The OWES evaluation process currently recognizes the interconnectedness of wetlands in close proximity to one another. This interconnectedness contributes to the overall health, functionality, and significance of the entire wetland complex. No longer recognizing the importance of maintaining intact wetland complexes will result in a loss of protection for sensitive wetland habitat.

2. Endangered and threatened species will no longer be recognized - Currently, the presence of endangered or threatened species automatically qualifies a wetland as provincially significant and affords it protected status. The proposed changes to the OWES will diminish the importance given to the presence of endangered or threatened species, leaving both the species and wetlands that they rely on vulnerable to development.

3. Provincial government oversight and coordination will be removed - It is proposed that the MNRF will remove itself from any involvement in Ontario’s wetland evaluation process. Additionally, no central agency has been proposed to coordinate/approve evaluations or ensure that information about PSW designation is publicly accessible. Instead, it appears that approval authority will be downloaded to municipalities, many of which have little expertise and would no longer be able to consult with conservation authorities (due to proposed Bill 23 amendments to the Conservation Authorities Act). The onus would instead be on the wetland evaluator (working in most cases for the development agency) to inform the municipality and landowners in writing about the outcome of the evaluation or re-evaluation.

The stated purpose of the OWES overhaul is to streamline the wetland evaluation process in order to construct 1.5 million new housing units over the next 10 years. This purpose is misguided and misleading, given that a shortage of land isn’t the cause of the housing shortage - this was stated by the Ontario’s Housing Affordability Task Force in its 2022 report. The amount of greenfield land already designated for development within municipal settlement boundaries, but still sitting unbuilt, far exceeds what is needed to meet long range housing targets.

Ontario’s wetlands play a critical role in sustaining healthy communities, enhancing climate change resilience and conserving biodiversity. I am therefore opposed to the proposed overhaul of the OWES.