To Whom It May Concern: …

To Whom It May Concern:

Thank you for the opportunity to provide input on the proposed updates to the Ontario Wetland
Evaluation System (OWES). The City of Brampton has reviewed the proposed updates outlined
through this posting and offer comments and recommendations below.

City Response:
The proposed changes to the OWES, including the removal of wetland complexes and the re-evaluation of previously evaluated wetlands, will lead to a more fragmented and degraded wetland
system. Wetlands play a critical role in Ontario by providing protection from impacts such as
flooding, drought and other effects of climate change while also providing rich, biodiverse features
for local fauna and flora. The loss of smaller wetlands, previously captured under the wetland
complex or as provincially significant wetlands, will result in a significant loss of functions and
services, leading to degraded water quality, more flooding, loss of species, habitat and
biodiversity, etc. These changes may exacerbate future climate change impacts. The proposed
changes to the OWES may also result in the loss of species, particularly endangered and
vulnerable species. Based on the new evaluation, the number of points designated for the
presence of endangered species has been significantly reduced, making it easier to remove the
wetland.

The City has concerns around the lack of oversight and changes to the wetland evaluation
process. Previously, the Ministry of Natural Resources (MNR) was responsible for leading and
providing oversight of the OWES. With the removal of MNR and Conservation Authority
involvement, as well as limiting the ability for municipalities to review completed documents, there
are concerns around the lack of oversight, expertise, and quality control of these evaluations,
particularly when consultants (hired by the developers) are conducting wetland evaluations. As
noted in the proposal, once the evaluation is submitted to the municipality, it is ‘deemed complete’,
removing all ability for the municipality to comment on or provide oversight to the
evaluation. Additional comments pertaining to the evaluation process include:

Consultants will not be required to stake the entire wetland, raising concerns that the
evaluation will not accurately capture its significance.
There will be no proper standard or limit for re-mapping of a wetland, allowing re-mapping
to be triggered for any reason. This can lead to abuse of the process, purposeful impact
to the wetland system, and wasteful use of resources.
Municipalities do not have expertise to provide the technical review required that was
previously undertaken by the CA’s and MNR. Municipalities will need additional resources,
funds and policy support to be able to undertake the proposed changes in Bill 23.
Based on the proposed changes to the OWES, there are concerns over a lack of a
centralized file system previously completed by MNR. Without a centralized system to
store wetland evaluation files, this may limit the information available to the City on
wetlands and would make it more difficult to have access to the information.

Overall, the proposed changes will result in a reduction in protection of provincially significant
wetlands and other wetlands in Brampton. The changes will remove any oversight of the wetland
evaluations and standardizations, relying on developers and their consultants to conduct the
evaluation and submit what is assumed (without basis) to be appropriate and reliable
documentation. It downloads the remaining responsibilities to municipalities. These changes will
result in a conflict of interest for consultants and more work, time and effort for municipal staff to
oversee. These changes will require additional staff in the City who are knowledgeable in
technical matters with regards to biology, ecology and hydrogeology.

Recommendations:
To address these concerns, we recommend the following amendments to the proposed
legislation:
Appoint a Conservation Authority or municipality as the approval authority for
assessments;
Allow approval authorities to review and comment on assessments once complete;
Require mandatory credentials for those undertaking assessments to ensure quality
control;
Provide a transition period to allow municipalities the time to adjust to these changes;
Commit to developing a policy statement that clearly states there will be no net loss of
wetlands in Ontario;
Maintain wetland complexes to ensure smaller wetlands are maintained and protected;
Provide guidelines on when remapping of PSW wetlands is appropriate; and
Rescind the reduction of points for endangered species to ensure that provincially
significant wetlands are protected.

The City of Brampton would like to thank the Province for the opportunity to provide feedback
and comments on the proposed changes.

Sincerely,

Steve Ganesh, MCIP, RPP
Commissioner (A),
Planning, Building & Growth Management

Michael Won
Commissioner (A),
Public Works & Engineering