The Ontario Wetland…

The Ontario Wetland Evaluation System (OWES) and associated manuals have been around and in development for several decades now, gradually improving over time as knowledge accumulates. I would consider the current manual to be a fairly high quality document. Could it use some review and improvement? Sure, there is always room to improve and clarify processes when new information becomes available. The proposed changes to this document and the OWES system would in my opinion be a major regression in the quality of this document and the OWES.

Reading through these proposed changes it seems to me like no one with an ecological or wetland science background had much if anything to do with the suggested changes.

It is also fairly obvious what these proposed changes are designed to do, which is not to improve the process of wetland evaluation (and subsequent management and protection) in Ontario at all but to make it much harder for wetlands in Ontario to be evaluated as provincally significant. With reduced protections, it will make it easier for these features to be negatively impacted and/or lost through development activities.

I think it is an important point to note that despite all of the rule's, regulations, etc., that are in place to protect and limit development within or in close proximity to wetlands, the loss of wetland area in Ontario is not a thing of the past. Slowed in recent years due to the protections we have put in place, probably. Reversed, no.

The major themes that I see in these proposed changes to OWES are: 1. removal of MNRF from the process of administering the program. 2. Nearly complete removal of reference to wetland complexes and complexing as a concept and and a wetland property that has any bearing on the scoring of a wetland. 3. A great reduction in the need to document the process of wetland evaluation, reference to field data sheets and the need to document work seems to be for the most part removed, with only the need for digital mapping data clearly remaining. 4. Removal of Endangered or Threatened species as a scoring factor in determining a wetlands significance.

Starting with the first paragraph: “As stewards of Ontario's Natural Resources, one of the MNRF's mandates is the protection and sustainable management of Ontario's natural heritage features, including wetlands.” How is the Provincial Government's total removal of the MNRF's involvement with administering and overseeing OWES going to help accomplish this? To me this is major shirking of responsibility and counter intuitive. This needs some explaining. Is MNRF still going to have involvement in training wetland evaluators? Currently one cannot be acceptably considered a wetland evaluator unless they have recieved the training from MNRF sanctioned sessions.

Who will the responsibility of officially identifying provincially significant wetlands be downloaded to? It is not entirely clear with these proposed changes. It looks like MNRF and Conservation Authorities (the two current governmental entities with the most qualified staff to complete these assessments of wetland evaluations) are proposed to be removed from involvement in the process. Based on the proposed changes it looks like the responsibility would/may possibly go to municipalities but it also appears that anyone who is trained (again, who will they be trained by in the future?) could determine the signficance of a wetland (provincial or otherwise). Would a municpality be in charge of assessing and accepting evaluations? Do they have staff to do this? Allowing anyone qualified to evaluate wetlands could be very problematic if allowed, as many of the trained people who would be doing this evaluation work are consultants directly working for development proponents. Without a relatively impartial third party evaluating their work, the potential for improper assessment and evaluation would unfortunately be greater.

The striking out of all of the sections on wetland complexes and reference to the concept of wetland complexes is a little disturbing, and detached from the reality of the form and function of many wetlands on the landscape. It is a sound and well accepted ecological concept that not all wetlands consist of only a contiguous wetland unit, and that closely spaced wetland units function together hydrologically and ecologically as a single larger wetland. But it seems that these proposed changes to OWES would mean that each discrete wetland unit would need to be evaluated separately for significance (except for in some narrow, but poorly defined circumstanes, see further comment below), greatly reducing a wetlands scoring potential with reduced size and complexity being attributed to a single wetland unit and not the entire wetland complex. Whether we choose to use the word complex, as we have in the OWES, or another word used to describe grouped items is not important, but the concept is.

Then, a section is added on page 20 under the “Wetland Edges Bordering Lakes and Rivers” section (why is it placed specifically in this section when it applies to many wetlands that do not border on lakes and rivers?) that acknowledges that some wetlands can be composed of multiple closely spaced units (which could be called a complex). It is obvious the removal of complexing as a concept from the OWES would make it next to impossible for many of the smaller units in a wetland complex to be scored as provincially significant, even though they hydrologically and ecologically contribute to the function of the wetland. The complexing section should simply not be removed. Potentially it could be updated, the complexing process clarified, rules for complexing strengthened, but any changes should be based on the best available, scientifically gained knowledge. For example OWES currently uses 750 m for the cut off distance for consideration of complexing units together, if a change to this distance is suggested it should be based as much as possible on defensible background research and data. There are already criteria to consider such that not every wetland that occurs within 750 m of another wetland or wetland complex is automaticlly considered to be a part of that wetland complex.

I don't think there is much to say about the removal of much of the reference for the need to record field data, keeping a wetland evaluation file (obviously under the proposed changes the file wouldn't go to MNRF), etc., other than it is baffling. Environmental assessment work should always be well documented for the basic need of defending a conclusion on a features significance, etc., in the case of legal challenges, etc.

Removal of Endangered or Threatened species from scoring? Why? These species are Endangered or Threatened for a reason, with habitat loss or degradation usually being one of the major factors in a species decline. Obviously, any habitat that is important in the life cycle of a END or THR species should be considered significant. I am not sure what the logic or point of removal of this is from how we assess wetlands under OWES (other than another way to make it very hard for a wetland to be scored as signficant). What is the reasoning or alternative suggestion here? I know END and THR species are not a part of the assessment of Signficiant Wildlife Habitat, as they generally receive some protection under the Province's Endangered Species Act, but to me they are still an important part of determining a wetlands signficance. Removal of END or THR species as a scoring factor in OWES would need to be defended by some logical reasoning that will not be detrimental to both the species at risk and the habitats that support them. I don't know what that reasoning could be.

There are other things proposed for removal that don't seem to bear much on how a wetland would be scored but are still hard to understand. The removal of several recomended background sources of information and removal of a table that recommends the basic field equipment you would need to complete wetland evaluation work. Scratching out things like taking mapping out to when conducting evaluation fieldwork? Why?

The re-evaluation vs closed file aspect of new proposed OWES rules. The way it reads is that a wetland can be re-evaluated (i.e. under these new proposed rules) but then it is a closed file. Under the current system a wetland evaluation is really never “closed”. Wetland evaluation files are meant to remain open because often a wetland cannot be fully evaluated in one go due to access limitations, etc. To me seems obvious what the tactic is here, make it way harder for a given wetland unit to be evaluated as significant under these proposed changes, you can re-evaluate a previously identified provincially significant wetland unit under these new rules, which will in many cases lead to a new evaluation of “not provincially signficant” for a given unit, then it is a closed book on that wetland unit.

I agree it would be good to more fully clarify the determination protocol in regards to the presence of wetland in the wetland-agricultural land interface. In a logical way, backed by as much research and evidence as is available.

I agree with harmonizing some of the section of the OWES that deal with wildlife habitat features with the specific relevant Significant Wildlife Habitat Ecoregion Criterion Schedules.

Reference to PPS seems to be removed from the OWES manual with these proposed changes. Are changes coming to PPS Section 2.0 Wise Use of Resources/2.1 Natural Heritage? I can only imagine what these would look like. I can't support any change in policy that would reduce protections for our significant natural features. Two of the major environmental crises the entire planet faces, rapid biodiversity loss and climate change will not be positively impacted by easing the occurence of negative impacts to, and loss of area of these natural features.

The MNRF, “Stewards of Ontario's Natural Resources” “MNRF's mandates is the protection and sustainable management of Ontario's natural heritage features, including wetlands” abandoning involvement with OWES , hard to understand. This is the government agency that has always done this, now trying to absolve itself of this responsibility with no clear (or practical?) alternative. I realize that government agencies can shift and change responsibiliites with the whims of whatever administration is in at the time but this just seems, as said before, like a major dereliction of duty. Not even a clear transfer of this responsibility somewhere else.

Appendix 1 – “The ministry has determined that a wetland is provincially signficiant when it has been identfied as such using this manual”. Which ministry will this be?

Appendix 10 “The Wetland Plant List may be updated from time to time and any such updates will be made available on a website” which website, hosted by what agency?

I think a positive change that could be made to OWES, not suggested in these proposed changes, would be the incorporation of a more statistically defensible method of determing presence of a wetland via the vegetation cover and 50 % relative cover rule. For example point intercept vegetation sampling methods.

I request that details of the authorship and technical consultation process for suggesting these proposed changes be made public, qualifications of those consulted, etc.