I was certified in the…

I was certified in the Ontario Wetland Evaluation System for Southern Ontario more than 20 years ago.
I have conducted evaluations as an independent consultant, with a couple of consulting companies as well as (during a brief period) with MNRF and another with a Conservation Authority. In my current role, I have had proposals approved by Municipalities involving wetland removal and compensation, as well as those that have recommended setbacks/buffers/vegetation protection zones.

While I understand that there is a housing shortage, I do not understand how removing some of the wetland protections determined through OWES is going to make housing any more affordable. The removal of a number of phrases regarding the protection(s) of wetlands in the OWES southern manual, (e.g., that OWES aids in the protection of PSWs under the PPS and that Municipalities may determine if non-PSWs are significant at a local scale and may choose to protect them) is concerning.

I would also appreciate further clarification regarding why all reference(s) to wetland complexes is (are) being removed. Wetlands in close proximity to each other often provide 'added value' on the landscape with the group providing a function greater than the sum of individual wetland functions. This value is not solely biological. Hydrological considerations (e.g., flood attenuation and water quality) are often cumulative. Reducing the ability to group wetlands for evaluation purposes to those within 30 metres of each other interspersed with small pockets of upland forest and/or wetlands along a river or lake separated by 100 feet or less is insufficient.

As an additional comment, Appendices 5 and 6 should be made available along with the draft manual containing the proposed changes. Are we to assume they are the same as what is in the existing manual? Further, if alternate lists can be made available by the Ministry instead of Appendix 5 and 6, there should be a more fulsome description of how such lists are developed and/or where they will be posted.