As stated in the proposal…

As stated in the proposal details for ERO 019-6160, one of the key purposes for the proposed updates to the Ontario Wetland Evaluation system is to "make changes to better recognize the professional opinion of wetland evaluators." As a certified wetland evaluator under the Ontario Wetland Evaluation System (OWES), I have several concerns about the proposed changes to Ontario's Wetland Evaluation Manual, that I ask the Ontario Government to take into consideration.

Removal of MNRF as the administrator of the Ontario Wetland Evaluation System

Many of the proposed changes to the Ontario Wetland Evaluation Manual are focused on removing MNRF's role as the administrator, source of technical expertise and interpretation, and reviewer/approver of wetland evaluations. With no alternative, objective body identified to fill these roles, the proposed changes will significantly reduce certainty and clarity related to how significant wetlands are assessed and identified, which is counter to the stated intention of the proposed updates. I have several specific questions and concerns as to how the wetland evaluation program will be implemented moving forward without MNRF filling these roles.

Training of new wetland evaluators: In the past, most of the instructors for the wetland evaluation course have been MNRF employees. If MNRF no longer has a role in administering the wetland evaluation system, who will be responsible for delivering the course? If private consultants are brought in to teach the course, who will cover the cost of hiring these individuals? If no new wetland evaluators are trained, this will prevent the evaluation (or re-evaluation) of wetlands that may or may not be provincially significant, particularly under proposed changes to the system.

Consistent application of the system: The OWES system is based on scientific criteria, however there is significant room for variation in interpretation amongst evaluators, depending on Natural Heritage and other information available at the time an evaluation is completed, and judgement calls of the individual evaluator. If there is no regulatory body responsible for reviewing and approving wetland evaluations, and evaluators are not encouraged to confer with their local MNRF office for the most up-to-date information, this will lead to significant inconsistencies in how the manual is applied across the province.

Interpretation of updates to the wetland evaluation manual: With significant changes proposed to the wetland evaluation system, it can be expected that evaluators will have questions about how to interpret and apply the newly updated manual. If MNRF is no longer the authority on the wetland evaluation system, it is unclear who an evaluator can turn to for advice on how to interpret and apply changes to the manual.

Technical information and expertise: MNRF district offices have in the past been an important source of information on natural heritage, social, and economic values associated with wetlands. As they are no longer listed as a recommended source of information, this will make it more challenging for evaluators to obtain all the information needed to adequately evaluate the significance of a wetland, while maintaining professional integrity. Counter to the stated intention of the proposed changes, this may lead to delays in development decisions, as evaluators struggle to compile all the information needed to complete the evaluation without support from MNRF.

Removal of Wetland Complexes from the Ontario Wetland Evaluation System

The manual has also been updated to remove wetland complexes from the evaluation system. As described in the current version of the Southern Ontario Wetland Evaluation Manual:

"Wetland complexes are commonly related in a functional way, that is, as a group they tend to have similar or complementary biological, social and/or hydrological functions. Much of the wildlife in the area of the complex is variously dependent upon the presence of the entire complex of wetlands, with each wetland unit contributing to the whole."

The manual is clear that not all closely grouped wetlands should be treated as complexes, only those that, when considered together, have a cumulative importance in functions such as ground water recharge, water quality improvement, flood attenuation, and erosion control.

As such, removal of wetland complexes from evaluations moving forward, and the proposed change to allow individual wetland units to be re-evaluated without considering other units within the complex, may have significant consequences for ground water recharge, water quality, flood attenuation, and erosion control, as well as the wildlife that depend on wetland complexes in their entirety such as provincial Species at Risk including Blanding’s Turtle. The potential for development to impair the function of wetland complexes will introduce new sources of liability for municipalities, developers, and the province, and uncertainty for prospective homebuyers about the safety and sustainability of new homes built in the vicinity of any wetlands, if this and other proposals related to Bill 23 are approved.

In addition, the proposal lacks the background documentation to explain the move away from evaluating complexes to instead only considering grouped wetlands that occur within 30 metres of each other or within 100 feet or less along a river or lake. The absence of supporting ecological and scientific rationale for this change does not inspire confidence in the proposed updates, when compared to the comprehensive reasoning within the existing manual.

Change to “Documentation of wetland features not included in evaluation"

While this change succeeds in reducing the workload associated with producing a wetland evaluation, the loss of continuity is worrisome and far outweighs the potential benefits. The documentation of wetland features ensures continuity of information going forward and replicability of results if professional opinions are ever challenged or requested. Loss of this documentation may bring professional judgement into question, while inclusion ensures the information can be built upon and referenced in the future.

Removal of "Habitat for Threatened or Endangered Species" from the Ontario Wetland Evaluation System

The significance of some wetlands as habitat for certain species at risk is recognized in the current version of the wetland evaluation manual by automatically providing very high scores to wetlands that provide reproductive habitat for an endangered or threatened species, and high scores for wetlands that provide feeding, migration, or hibernation habitat for endangered or threatened species. As no rationale is provided for removing these sections, in seems at face value that the primary intent of this update is to ensure fewer wetlands meet the threshold for Provincial Significance.

Summary
Overall, it is disappointing to see MNRF propose such sweeping changes to the wetland evaluation manual that have no clear ecological or scientific basis. This proposal shows blatant disregard for the importance that wetlands provide to biodiversity, flood attenuation, and social and cultural values. The intent is clear: to limit oversight, reporting, and the ability for wetlands to achieve PSW status, in order to facilitate development in these provincially sensitive habitats.