The proposed changes to the…

The proposed changes to the OWES brings the following five concerns to light.
1. Wetland complexes no longer to be recognized or considered
The OWES is the official procedure to identify PSWs and determine their boundaries, based on
a scoring system that takes into account biological, social, hydrological and special features.
Identifying wetland complexes has been integral to the evaluation and scoring process, based
on the understanding that many wetlands are interconnected with complementary biological,
social and/or hydrological functions that contribute to the health and significance of the whole
(i.e., the complex). Dividing complexes up into individual units for assessment “would not be an
ecologically or functionally sound process.” (OWES – Southern Manual, p. 39)
MNRF is proposing to no longer consider wetland complexes as part of the OWES. Yet,
wetland complexes have been a major factor in designating wetlands – especially smaller ones
– as PSWs. If MNRF proceeds with the proposed changes, very few new PSWs will be
designated in the future and many existing PSWs will lose that designation and the protection it
affords.
Ontario Nature @ Centre for Social Innovation, 720 Bathurst Street, Toronto, ON M5S 2R4
T/ 416-444-8419 1-800-440-2366 F/ 416-444-9866
info@ontarionature.org ontarionature.org
CHARITABLE REGISTRATION #10737 8952 RR0001
Ontario Nature @ Centre for Social Innovation, 720 Bathurst Street, Toronto, ON M5S 2R4
T/ 416-444-8419 1-800-440-2366 F/ 416-444-9866
info@ontarionature.org ontarionature.org
CHARITABLE REGISTRATION #10737 8952 RR0001
2. Endangered and threatened species no longer to be recognized
MNRF is proposing to no longer recognize the presence of endangered or threatened
species in the OWES process, a criterion which is a key factor in determining provincial
significance. Currently, the presence of endangered or threatened species automatically
qualifies the wetland as provincially significant. But with the proposed changes, species at
risk will be considered only as “provincially tracked species,” worth far less in the evaluation.
This major change would affect the scoring of most wetlands in Ontario, leaving many of
them, and the significant species that rely on them, vulnerable to development.
3. Provincial government oversight and coordination to be removed
MNRF is proposing to remove itself from any involvement in Ontario’s wetland evaluation
process, despite the deep and valuable expertise of ministry staff who have overseen the
process for decades. No central agency is being assigned to coordinate or approve evaluations
or to ensure that information about PSW designation is publicly accessible. Consultation with
MNRF will no longer be an option. 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). Instead, the onus would be on the wetland evaluator (working in most cases for the
development proponent) to inform the municipality and landowners in writing about the
outcome of the evaluation or re-evaluation. MNRF would 1) be unaware of wetland evaluations
and outcomes; 2) no longer ensure wetland evaluations were accessible to the public through
Land Information Ontario; and 3) have no authority to intervene on behalf of the public
regarding an evaluation of questionable merit.
4. Timing of proposed changes
The proposed changes to the OWES are going forward at the same time as Bill 23 and other
proposed law and policy amendments that will negatively impact wetland conservation in
Ontario. The broad scope of the proposals and the speed with which they are being pushed
forward mean that public’s ability to comprehend and respond is severely compromised.
5. Inaccurate and misleading analysis of the regulatory impact on the ERO
MNRF’s description of the anticipated impacts of the OWES overhaul is misleading and far from
comprehensive. It mentions only the impacts on business which the ministry anticipates will be
positive or neutral. It says nothing whatsoever about the significant negative environmental,
social or economic impacts related to wetland loss that would arise from the changes to the
OWES system. It would appear either that MNRF has given no thought to these impacts or that
it simply does not care.
Ontario’s wetlands play a critical role in sustaining healthy communities, enhancing climate
change resilience and conserving biodiversity. Together, we must do our utmost to ensure that
MNRF does not proceed with the proposed overhaul of the OWES