The City of Burlington…

The City of Burlington recognizes the importance of a systems-based approach to planning for natural heritage and key features. Wetlands are a vital component of the functional connections between aquatic and terrestrial systems. The ecological, social, and economic benefits of wetlands are substantial and provide for some of the most productive and biologically diverse habitats in Ontario. Since the 1980s, a substantial amount of southern Ontario wetlands have already been lost to encroaching land uses and development. The conservation and protection of the remaining wetlands is of more importance than ever.

From a natural heritage planning perspective, the proposed changes to the complexing of wetlands does not represent a systems-based approach to planning for the natural environment. This direction is not supported by a science-based ecological understanding of natural systems. Advances in mapping and modelling over the past 10 years have resulted in a better understanding of hydrological connections of wetland complexes and more efficient delineation processes. Removal of the complexing approach to wetland assessment is not a direction that is supported by the current policy or guidance provided by the Provincial Policy Statement (2020) or the Natural Heritage Reference Manual. This direction is likely to result in:

• An inconsistent approach to wetland evaluations;
• Challenges to recently assessed wetlands;and,
• A net loss of overall natural heritage system within municipalities.

These changes would be opposite to Provincial direction regarding proper accounting for ecosystem services. As noted in A Place to Grow (2020) wetlands provide numerous benefits including water storage and filtration, cleaner air and habitats, and support pollinators, carbon storage, adaptation and resilience to climate change. These benefits may be cost prohibitive to replicate with traditional infrastructure or services if the features supporting ecosystem services are lost; at expense to the municipality. It is likely, due to the wording of the proposed changes, that municipalities will seek their own OWES evaluator to either review completed evaluations, or to proactively evaluate wetland features deemed important to the City’s natural heritage system in order to deliver on several identified matters of provincial interest.

Next Steps:
There is general support for the modernization of OWES and for additional clarity on the complexing of wetlands. However, permitting an individual component of a larger system to be assessed in isolation from that system is a significant departure from accepted ecological principles and a departure from principles enshrined in the Provincial Policy Statement (2020), A Place to Grow (2020), and the Natural Heritage Resource Manual. The opportunity to have a more open and productive dialogue on modernizing OWES would be preferred and some innovative consideration may include:

• update to include conclusive minimum size criteria for wetland units.
• OWES scoring for SAR/THR/Rare species could be modified to better reflect some of the inconsistencies in the process.
• Creating a scoring cap.
• Applicability where species status lists are current and available.

Currently, OWES recognizes the ecological complexities of wetlands. These complexities, such as the interaction of groundwater and surface water inputs, is part of what makes a wetland such a valuable feature suited to providing important ecosystem services. While the type of studies that may be required to assess these interactions can be both extensive and expensive, the general goal of revising OWES should focus on making the process transparent and replicable rather than disposing of important evaluative concepts.

Finally, It is unclear what role municipalities will have in the wetland evaluation process. Clarity should be provided regarding whether a municpality has the ability to retain their own OWES evaluator where there may be a dispute in the evaluation process. Additional clarity is also sought regarding at what level oversight occurs. In general, having no or unclear oversight of the matter of wetland evaluation opens the process to abuse and potential conflicts of interest and the potential of undermining of certain matters of provincial interest enshrined in the Planning Act. It is suggested, in-lieu of an appeal mechanism, and removal as MNRF as arbiter, that it be clarified what recourse is available where there are conflicting evaluations or where there is a dispute regarding conclusions.