Thank you for the…

Thank you for the opportunity to submit comments on the ‘Proposed Updates to the Ontario Wetland Evaluation System’ as posted on the Environmental Registry of Ontario (ERO # 019-6160) related to the omnibus Bill 23 ‘More Homes Built Faster’ Act.

I am deeply concerned about the tremendous changes proposed to the scoring, rules and oversight of wetland evaluation in Ontario. Evaluation is the primary tool affording protection to wetlands under the Provincial Policy Statement and in the planning process. I provide comments here as both a certified wetland evaluator and as someone who teaches wetland evaluation skills at the post-secondary level.

My main points are outlined below with reference to the 64-page supporting documentation posted with ERO # 019-6160 entitled Proposed Updates to the Ontario Wetland Evaluation System 2022-10-25.

1. Removing Species at Risk Scoring Elements from OWES (p. 51-52 of Proposed Updates)
Wetlands provide habitat for at least 20% of Ontario’s at-risk plants and animals (Kip, 2022). The current scoring system recognizes the major importance of this by providing 250 points to evaluated wetlands hosting threatened or endangered species, safeguarding habitat through protections afforded to Provincially Significant Wetlands. Given the recent undermining of Ontario’s Species at Risk legislation, wetland status designation is a critical means of protecting the habitat of at-risk species such as turtles, mussels, wetland-dependent birds, plants and insects.

Removing the recognition and scoring for wetlands providing reproductive, migratory, feeding or hibernation habitat for threatened and endangered species will result in many fewer wetlands achieving Provincially Significant status. Further, many existing PSWs could lose their designation upon re-evaluation. In a province with less than 30% wetland habitat remaining, this spells disaster for the natural areas that sustain us!

I do not support the removal of scoring elements related to threatened and endangered species and urge the government to rescind the proposed updates. To refer to these changes in the ERO posting as ‘housekeeping’ edits highlights an egregious lack of transparency on the part of the government.

2. Removing Wetland Complexes from OWES (p.7 of Proposed Update)
Removing the wetland complexing rules and allowing complexes to be re-evaluated as separate wetland units will exacerbate wetland loss and degradation in Ontario. Wetlands are functionally and hydrologically linked across the landscape, and we ignore this for the sake of housing development at our peril. The flood control, habitat and clean water benefits of wetlands have consistently been valued as more efficient and effective than human-built solutions. Recent research at the University of Waterloo valued the sediment and phosphorus filtration services of wetlands in Southern Ontario - those at most risk from the proposed changes related to OWES changes - at $4.2 billion (Aziz & Van Cappellen, 2021).

Recognizing and evaluating wetlands as complexes is critical to ensuring that wetlands can continue to function and provide these key ecosystem services.

I strongly recommend re-instating the wetland complexing rules as outlined in the current (2013) Southern Ontario OWES manual.

3. Removing provincial oversight of the evaluation process (p.7 of Proposed Update)
The sober second look that provincial government staff provide to wetland evaluations ought not to be removed from the OWES system. Government staff provide added value to evaluations: they have access to records, in-house aerial imagery expertise, institutional history of past restorations or development pressures, and knowledgeable senior staff. Moreover, a central agency (i.e. MNRF) is required to coordinate evaluations and ensure that information about wetland evaluations is made public.

Wetland evaluators are typically employed at environmental consulting firms. While they are generally impartial, consulting staff may be influenced by clients towards certain outcomes for a wetland, or unduly constrained by time and finances in their wetland evaluation research due to the bidding process inherent in consulting contracts. Removing provincial government oversight of the evaluation process opens the field to errors, oversights and potential bias.

In summary, I urge the government to revoke the proposed changes as outlined in ERO posting # 019-6160 and maintain the current scoring, rules and oversight of wetland evaluation in Ontario per the Southern Ontario Wetland Evaluation System manual (2013). Wetlands are our best nature-based climate solution, offering carbon storage, flood protection and water quality purification services. I would like my government to focus on the protection of these natural habitats and their species rather than dismantle the protective systems currently in place to safeguard wetlands.

Thank you for the opportunity to comment.

References
Kip, J. (2022, April 14). The Worth of Our Wetlands. Ontario Nature blog. https://ontarionature.org/the-worth-of-our-wetlands-blog/

Aziz, T., & Van Cappellen, P. (2021). Economic valuation of suspended sediment and phosphorus filtration services by four different wetland types: A preliminary assessment for southern Ontario, Canada. Hydrological Processes, 35( 12), e14442. https://doi.org/10.1002/hyp.14442