Comments on Proposed…

Comments on Proposed Revisions to the Ontario Wetland Evaluation
I was a member of the committee that created the original Ontario Wetland Evaluation System. I am not, however, up-to-date on recent information sources and methods. Nor have I used the system for many years. My comments should be considered accordingly.
I recognize that the changes include helpful editing and updates.
My concerns are:
Throughout: references to MNR as a source of information, an approval agency, and a user of the results are deleted. I disagree with this distancing. Is it because of lack of staff or funding? I hope at least all evaluation data is collected and stored at MNRF.
Throughout: almost all references to wetland complexes appear to be removed. Since complexes are common in many areas, e.g., moraines, I disagree with this change and do not understand how those situations will be addressed.
Throughout: I am not clear on how some of the changes will affect the total score and if the threshold for PSW will be altered. I see that Ontario Nature has raised a concern about far fewer designated PSWs: without seeing the proposed scoring, I cannot comment on specifics but I am alarmed if their concern is correct. As the climate crisis deepens, wetland ecological functions and values to society will only increase in importance. I see no reason to reduce the number of PSWs.
p. 4. I disagree with the removal of the caution that the evaluation not being a complete inventory. I feel it is important distinction.
p. 5. I feel the proposed uses of the Evaluation are much too restricted, appearing to omit all provincial and Conservation Authority planning. I feel these levels bring valuable insights. I realize this might be reflecting other recent changes in various planning policies, changes I disagree with.
p. 9 – 13. There are several deletions that I disagree with or least don’t understand the rationale for their removal. These deletions are: the checklist of Evaluation file components; the guidance on adding information; and data sources.
p. 15. Good idea to add non-evaluation trained experts as assistants.
p. 15. I disagree with the removal of the “open file” discussion since both new data and wetland changes can occur.
p. 51/52. If I’m correct in assuming 4.1.2.1 and 4.1.2.2 re reproductive, migratory, feeding and hibernation habitat of endangered or threatened species is being included in 4.1.2.3 and 4.1.2.4, shouldn’t the latter two sections’ scores be increased accordingly?
p. 61. Section 5 on Documentation of Features not Included in the Evaluation: I appreciate this might be a streamlining change, but I question if it will really save any time if it’s just a matter of noting data the evaluator has run across anyway, especially if the data could prove useful for other applications.
p. 63. I feel that guidance to municipalities about locally significant wetlands (proposed to be deleted) can be useful especially if they are the main planning authority since other changes appear to cut out MNRF and CA input to planning. And all the more so if Ontario Nature’s warning of the scoring system changing to shift some PSWs to locally significant. So, unless guidance is offered to the municipalities elsewhere, I oppose the deletion of this guidance.