Three things concern me very…

Three things concern me very much about the proposed changes.
1. Lack of control over the quality of wetland evaluations.
2. Loss of ecosystems, populations and economies. Provincially significant wetlands will be broken into such tiny pieces that they can no longer be protected under the Ontario Wetland Evaluation System.
3. Loss of information and knowledge about wetlands.

1. The proposed changes will result in poor quality, even sham, wetland evaluations.

Your stated purpose in updating the Ontario Wetland Evaluation System is to "make changes to better recognize the professional opinion of wetland evaluators and the role of local decision makers (e.g. municipalities)"

Yet, nowhere do you explain who can claim to be a "professional" wetland evaluator. At the very least the Ontario Wetland Evaluation System should establish criteria for determining when and why the "professional opinion" of self-described wetland evaluators deserves to be "better recognized".

OWES needs to make it clear to the public that the wetland evaluator whose professional opinion the public is being asked to respect deserves that respect. As the proposal stands, I could claim to be a professional wetland evaluator, even though I have never studied ecology, biology or indeed any scientific subject!!

This glaring omission is compounded by removing all effective oversight or review of the wetland evaluator's professional opinion. The proposed changes remove oversight by the Ministry of Natural Resources and Forestry and by Conservation Authorities and leave oversight entirely up to municipalities, which may, or may not, but most likely will not, have any staff with knowledge of wetlands and wetland evaluation. Many municipalities, especially smaller municipalities, are unlikely to have any staff with any scientific knowledge or background. And even if the snow plow operator once studied ecology in high school or university, there is nothing to suggest the municipality would or should ask her advice rather than relying on the municipality's planning director who rigorously avoided science throughout her entire post-secondary education and career.

It is a mistake to remove oversight and review of wetland evaluations by the Ministry of Natural Resources and Forestry and by Conservation Authorities, as these organizations have, at least currently, knowledgeable staff who could effectively review the wetland evaluator's reports.

The public needs to be assured that wetland evaluations are legitimate and done in good faith, that property owners and developers are not hiring charlatans.

The public needs to be assured that the Ministry of Natural Resources and Forestry, as "steward of Ontario’s natural resources" is taking seriously its mandate of "the protection and sustainable
management of the province’s natural heritage features, including wetlands."

The public might be partially reassured if the professional, educational, experience and/or accreditation requirements of "professional wetland evaluators" were included in the Ontario Wetland Evaluation System (OWES).

But better than simply stating qualifications -- which can document what people studied, vs what they actually learned -- OWES should call for a review of wetland evaluations by knowledgeable entities, such as Ministry of Natural Resources and Forestry staff, and Conservation Authorities staff. Though here too, there needs to be some requirement that the review is done by appropriate and knowledgeable staff. (I am thinking of a situation where Conservation Authorities, for example, lay off all their wetland experts due to provincial government cutbacks, and the financial comptroller, say, ends up doing the review of the wetland evaluation. This would tick off the box of "review by Conservation Authority" but would certainly not fulfill MNRF's mandate to protect and sustainably manage the province’s natural heritage features, including wetlands.)

If the responsibility to review the "professional opinion of wetland evaluators" is left up solely to municipalities, then there must be a requirement for each municipality to annually assure the Ministry that the municipality has the capability to understand and evaluate these professionals' reports. This capability could be achieved through its own staff or through a citizens' committee.

The bottom line is that the protection of wetlands is crucial for the province of Ontario.

As Richards Education Award winner David Hawke puts it, the arguments put forth in favour of protecting wetlands are tenfold:

1. Wetlands (swamps, marshes, bogs and fens) are home to many species of wildlife, some quite rare and unique to the area;
2. Every food chain or food pyramid has a link to a wetland dependent species;
3. Wetlands provide flood control by absorbing the vast volume of water that can be suddenly released from rainfall or snowmelt;
4. Wetlands prevent erosion of streambanks and roadsides by slowing down the velocity of this flash flood rainfall;
5. Wetlands filter out just about everything from chunky debris to excess nutrients that flow in with dirty water from parking lots and hard surfaces… the outflow water is remarkably clean;
6. Wetlands cool the water as it seeps underground before being released downstream, and cool water supports life better than warm water (high oxygen levels and no algae);
7. Wetlands recharge groundwater supply, thus ensuring wells don’t have to be drilled deeper and deeper;
8. The production of biomass (every living thing considered as one lump) within a wetland equals a rainforest: a lot of plants means lots of oxygen released to the air, and equally a lot of carbon sequestered from the air;
9. Wetlands attract human users, who pay good money to go hunting, fishing, birdwatching, paddling and to do nature photography (not just in their gear, but buying gas, staying at resorts and hotels, and picking up food). No wetland means no visitors which means no money added to local economy.
10. Wetlands are recognized for their aesthetic value to our society. They are fun places to visit, they provide a boost to both our physical and spiritual needs.

It is the Ministry of Natural Resources and Forestry's job to protect and sustainably manage the province's natural heritage areas, including wetlands.

Please do your job MNRF!

2. The proposed changes will result in lack of protection for provincially significant wetlands -- protection which MNRF is mandated to provide.

The proposed changes permit wetlands currently deemed provincially significant to be divided up into small segments. These little pieces will undoubtedly gain lower scores than the original larger wetland and thus risk being drained, filled and completely lost. The ecological cost of splitting viable species habitat into orphaned pieces is huge. It will destroy ecosystems, populations and ultimately, economies.

Splitting off and evaluating pieces of wetland separately is like cutting off fingers from a hand. It's ridiculous to think it won't matter.

It is essential that wetlands continue to be evaluated in their entirety, as a whole.

3. The proposed changes will result in the loss of knowledge and information to effectively manage Ontario's wetlands.
Just as it is ridiculous to contemplate cutting fingers from a hand, it's equally ludicrous to prevent one hand from knowing what the other is doing. Yet this is what the removal of provincial coordination and oversight will do.

The province will no longer keep wetland evaluation files and maintain significant wetland mapping, or provide information for use in wetland evaluations. This responsibility will be downloaded to individual municipalities who may not have the expertise to manage this and certainly will not have the financial or staff resources.

Do we really think that plant and animal species or watercourses know and respect municipal boundaries?

We will be left with scattered and incomplete information, at best, and conflicting approaches at worst. Just imagine one municipality working really hard to re-establish wetland habitat while across the township line the neighbouring municipality is working hard to destroy it.

It is the Ministry of Natural Resources and Forestry's job to protect and sustainably manage the province's natural heritage areas, including wetlands.

MNRF, please do your job. Maintain a role in the management of provincially significant wetlands.