November 24, 2022 RE:…

November 24, 2022
RE: Proposed updates to the Ontario Wetland Evaluation System (ERO:019-6160)
As a Wetland Biologist with over 17 years of professional experience, I have a number of concerns with the proposed changes to the Ontario Wetland Evaluation System (OWES). Ontario’s wetlands play a critical role as a natural filter of nutrients and pollutants protecting water quality, as flood storage areas that protect people and property from floods, as recharge areas for groundwater, and in providing habitat for wildlife including many Species at Risk. Ontario’s wetlands also provide an abundance of tourism and recreation opportunities. If the proposed changes to OWES are implemented, existing Provincially Significant Wetlands will lose their status and un-evaluated wetlands are unlikely to meet the standard for additional protection. This will lead to wetlands being destroyed and lost, resulting in loss of habitat and numerous species, decreased flood storage and increased erosion, poorer water quality in our rivers and lakes, and the loss of tourism and recreation.
Ontario has a housing supply crisis, not a shortage of buildable land. Access to housing that is affordable is necessary and important, but that is possible without making changes to the OWES that would remove environmental protections and encourage the destruction and removal of the remaining wetlands in Ontario. The proposed changes are not supported by science and will erode decision makers ability to protect wetlands and their functions.
My specific concerns with the changes include:
- The removal of the MNRF, and its varied and essential roles, from the manual.
o This leaves no oversight system in place and no identified replacement.
o This will result in a significant loss of knowledge base since the MNRF has been the administering body for this system since its inception. This will result in a significant need for additional resources and administration capacity that will be lost.
o Unclear who will be responsible for administering OWES.
o Unclear who will oversee OWES evaluator training and certification.
o Unclear who can be contacted for further details and support.
o Unclear who will be responsible for making final decisions or determining outcomes if there is a disagreement between evaluators.
o Unclear who will be responsible for training and certifying evaluators.
o Unclear who will be responsible for overseeing and housing wetland files and how this will be done.
- Addition of “A Complete Evaluation” section.
o Unclear who a ‘decision maker’ is and how they will be looking at evaluations.
o Unclear who will be responsible for updating and maintaining the provincial wetland database and mapping information.
o ‘Complete once it has been received’ provides no oversight to ensure that the evaluation was completed properly.
- Conservation Authorities removal from the manual. Conservation Authorities require tools and data including the information generated through OWES to continue to focus on natural hazards management and fulfill their core mandate.
- Changes to enable re-evaluations and mapping updates, and the removal of wetland complexes.
o Unclear what ‘closely grouped wetlands’ means.
o Wetlands do not function independently of one another, they collectively provide significant ecological functions and services, and should continue to be complexed. Removing wetlands from the complexes in which they have been identified fails to recognize how wetlands function on the landscape. It will result in the vast majority of wetlands not meeting significance criteria and becoming unprotected.
- Removal of 4.1.2.1 Reproductive Habitat for Endangered or Threatened Species and 4.1.2.2 Migration, Feeding or Hibernation Habitat for an Endangered or Threatened Species
o Wetlands are an incredibly important ecosystem for many of Ontario’s Species at Risk. Wetlands support these species by providing reproductive, feeding and hibernation habitat for residents as well as migratory species. Without the wetlands that support them many of these species will become at risk of extinction. The removal of these criteria for scoring will result in the vast majority of wetlands not meeting significance criteria and becoming unprotected.

I recommend that:
• The role of the MNRF in the administration of OWES be retained.
• The complexing of wetlands be retained.
• The scoring of Endangered and Threatened species be retained.
• The province engage with a multi-stakeholder working group to determine the unintentional negative implications of these proposed changes, and develop scientifically sound alternatives, prior to proceeding with the current proposed amendments.