I am quite concerned about…

I am quite concerned about certain omissions from the OWES manual that will impact the integrity of wetlands in the future. Particularly, the revisions downplay the need for thorough evaluations informed by expert knowledge. Excluding expert knowledge will lead to poor-quality evaluations with missing data. Decisions based on poor quality evaluations will therefore be misinformed.

Several amendments also clearly open up wetlands for potential land use changes. This prioritizes implementing destructive land use changes over making informed decisions about land use changes based on a thorough understanding of a wetland's ecology. This will result in long term, irreversible impacts to the ecological integrity of wetlands and adjacent natural areas that will cost the province billions of dollars in damages and lost ecosystem services.

Wetlands are land cover types with the highest per hectare values in the ecosystem services they provide, including erosion control and clean water provision. Please see the attached article which assigns monetary value to ecosystem services.

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Please see below some specific omissions of concern and my comments. These omissions are those which are striked-out and in blue font in the "Proposed Updates" document:

Page 4: Nevertheless, the evaluation is not a complete biophysical inventory and certain information, particularly about the presence of rare species and about hydrological functions, may be lacking even after the evaluation is completed. If this is determined to be the case, then more information should be obtained before making decisions about the types of land uses in the vicinity of evaluated wetlands (particularly those deemed to be provincially significant).

Concerns: this omission suggests that the possibility of rare species and/or additional hydrologic functions should be ignored, and additional inventories should not be conducted if needed (e.g. if a wetland is to be developed). This prioritizes implementing destructive land use changes over making informed decisions about land use changes based on a thorough understanding of an ecosystem. This will impact ecological integrity of wetlands and adjacent natural areas.

Page 5: 2. By the province as an aid to land use planning. In this regard, the wetland evaluation system serves as an essential cornerstone of wetland policies of the Provincial Policy Statement, authorized under Section 3 of the Planning Act. As well, the evaluation system may prove of value in identifying nationally and internationally important wetland features.
3. By conservation authorities as an aid in implementing regulations under the Conservation Authorities Act. Conservation authorities for purposes of public safety, natural hazard prevention and management, regulate wetlands for flood attenuation, natural storage capacities and for preventing shoreline erosion. Conservation authorities also regulate areas around wetlands that may interfere with the hydrologic function of the adjacent wetland including in general areas within 120 metres of all PSWs and areas within 30 metres of all other wetlands. Many conservation authorities evaluate wetlands; MNR retains authority to identify PSWs.

Concerns: The revisions suggest that results of wetland evaluations will not be used by the province or conservation authorities to inform land use planning. This suggests that significant wetlands are not important to the province for consideration in land use planning, and opens these spaces up to development. Building on wetlands will impact our water quality, flood and erosion-control abilities, and potentially place new development in hazardous areas (which would have been advised by conservation authorities). These impacts are long lasting (some irreversible), and will cost the province billions of dollars in damages and lost ecosystem services in the years to come.

Page 6: If an evaluator is uncertain how to proceed with or interpret any component of this evaluation system, they should contact the appropriate MNR District Office for clarification. In addition to having knowledge about local natural heritage features and functions, the local MNR biologist/ecologist has access to experts in a variety of disciplines who can assist in answering natural heritage questions. Where disagreements about an evaluation occur District MNR staff may seek additional input from the MNR’s Provincial Wetlands Program. Any such advice obtained should be noted/included in the wetland evaluation file.

Included text: This manual sets out guidance for assessing wetlands. Evaluators should rely on their observation, data collection and research and use their professional judgement and expertise in applying the OWES.

Concerns: MNRF staff are expertly trained in wetland evaluations and should be consulted upon uncertainty. This amendment does not specify that evaluators need to be experts to conduct evaluations either. This revision downplays the need to consult experts to effectively conduct wetland evaluations, which may lead to lower-quality evaluations missing critical details such as thorough species lists and documents of other important ecological functions.

Page 8: A wetland evaluation, re-evaluation or mapping update will be considered “complete” once it has been received by a decision maker addressing a land use planning and development or resource management matter.

Concerns: nowhere is it stated that the decision maker need be an expert in wetland ecology.