The government is proposing…

The government is proposing to amend the 2014 version of the Ontario Wetland Evaluation System (OWES) by eliminating the concept of a “wetland complex” and eliminating the role of the Ministry of Natural Resources and Forestry (MNRF) in identifying wetlands as provincially significant (PSWs). Wetlands are undeniably invaluable natural features for both a natural heritage benefit and natural hazard mitigation functions.

1. Wetland Complexes have been a fundamental part of wetland protection policy since the original Wetlands Policy Statement of 1992. In my experience they have been an accepted part of wetland evaluation science since the first wetland evaluation system of 1983. Wetland Complexes also achieve another fundamental Planning Act purpose to protect ecological systems.

I do not see the justification of such changes to the OWES. Our wetlands are vital, and their protection has been supported by 30 years of successful science and policy. The effect of eliminating wetland complexes, combined with opening the door to re-evaluating existing units within such complexes, inadvertently adds costs as well as uncertainty to the development process.

The government should not make this change or otherwise at least pause this measure to undertake a science-based evaluation and full cost accounting of this proposed change to ascertain impacts.

2. Role of MNRF – the role of the Ministry for the classification of wetlands to Provincially Significant and the confirmation of boundaries should remain with the Province as these are natural features of Provincial significance and thus are of utmost interest at a Provincial level. The confirmation of boundaries and the acceptance by the Province is necessary due to the very nature of natural features, which could change over time since the initial evaluation. Removing the role of the Province to identify what is to be Provincially significant is an abdication of Provincial responsibility that becomes even more critical when wetlands cross municipal boundaries.

This change presents further challenges as many municipalities lack the expertise or capacity to take on this role. This is compounded by other proposed changes to Municipalitys' ability to rely on Conservation Authorities for this technical expertise. This could very well result in further delays to the approvals process.

MNRF’s decision based on scientific grounds has been final until now. Being that this is a science based administrative decision, it becomes unclear who would be the best final arbitrator on the boundary and could lead to unnecessary differences across the Province.

It is recommended that the government revoke this proposed change and retain MNRF’s current role in identifying PSWs.