I am quite concerned about…

I am quite concerned about the proposed changes to the Ontario Wetland Evaluation System (OWES) and what those changes will mean for Ontarians and for Species at Risk.

As someone who has professional experience in this field, it is known that the evaluation of wetlands aid in the land use planning process to assist municipalities and conservation authorities in the proper planning required for development around and within wetlands. The MNRF and local Conservation Authorities are scientists that are knowledgeable and experienced in protecting and conserving wetlands. The conservation authorities currently regulate these wetlands or require a permit to develop or work in wetlands (however, with Bill 23 this will change) as wetlands under Bill 23 will no longer be regulated by Conservation Authorities.

It is curious that Bill 23 and changes to OWES have been proposed at similar times, as the Conservative Government anticipates building over 1.5 million homes in Ontario over the next 10 years and want to avoid constraints to development to quickly achieve this goal. I understand our population is increasing and that we do need more affordable housing for many Ontarians, but what I am observing currently is increased urban sprawl or estate homes being developed that are not currently assisting those who need affordable housing. I can understand that developers may be frustrated by having to go through applications, permits and appropriate mitigation measures, however that is why we have created regulations to protect and conserve the environment, which has been a long time in the making.

The new wetland evaluation system scoring system will eliminate various factors in the scoring system reducing the chance of making a wetland “provincially significant” therefore making it easier for developers to build and eliminating many of these wetlands protected under the Provincial Policy Statement under the Planning Act.

Changes noted in the Proposed Changes to OWES:
1) Wetland Complex – REMOVED
2) Threatened and Endangered Species – REMOVED
3) Consultation and Background Information with Ministry of Natural Resources and Forestry (MNRF) and Conservation Authorities – REMOVED

1. As stated in the OWES document provided for review in the Environmental Registry: (Proposed Revisions to the Ontario Wetland Evaluation System (prod-environmental-registry.s3.amazonaws.com): a wetland complex is stated as “A group of wetland units that are functionally linked to one another. The outer boundary of any one unit in no more than 750 m away from the outer boundary of one or more other units in the complex.” This means these are linked to one another and function together hydrologically and should be included together and not as single units as otherwise proposed. By removing evaluation of a wetland complex this greatly reduces the scoring system, as they will now only be considered separate units, reducing the chance that it will be considered provincially significant.

2. Wetlands are known to provide habitat for many of Ontario’s Species at Risk (SAR). Removing threatened and endangered species from the scoring system is inconceivable and should be considered an important factor in determining if a wetland is provincially significant. These are rare species that depend on wetlands and legally require their habitat to be protected. By removing these species from the OWES scoring, this will not eliminate any red tape for development. Developers would still need to following requirements under the Endangered Species Act (i.e., Completing Information Gathering Forms, Overall Benefit Permits, etc.). Therefore, I do not understand why we need to remove these species from the scoring system.

3. By removing the involvement of the Ontario MNRF and Conservation Authorities and acquiring appropriate background information in assisting in determining significance is unfortunate. This removes expert and scientific opinion of those who are most knowledgeable of Ontario wetlands. Background information they can provide regarding wetlands is invaluable.

We need smart land use planning right now regarding Ontario’s Wetlands. in Ontario’s A Wetland Conservation Strategy for Ontario 2017-2030 (see link), it states the following about wetlands; “They’re vital to the health of our province, giving us clean and abundant water, protecting us from flooding, and reducing the effects of climate change.” It also states “In Southern Ontario, wetlands act as natural infrastructure – producing at least $14 Billion in economic benefits each year for Ontarians." According to Ontario Nature: The Worth of Our Wetlands - Ontario Nature (see link): Wetlands are a nature-based climate solution and critical in responding to climate change and biodiversity loss and that is more cost-effective to protect our existing wetlands compared to other conventional land management and water treatment systems.

Please amend changes to the OWES Manual to include wetland complex’s and threatened and endangered species as part of the scoring system, and to include involvement with the MNRF and Conservation Authorities.