The proposed approach to…

The proposed approach to updating the Ontario Wetland Evaluation System (OWES) demonstrates a lack of understanding of wetland science and the unique context of Southern Ontario. As a professional ecologist certified in OWES and having practised as an ecological consultant in Ontario for over 15 years, I am not in favour of the proposed changes for the following reasons outlined below. I also understand that developers (and consultants!) are frustrated at the length of time development approvals take. Many of my colleagues have ideas about how to achieve ecological protection, enhancement and restoration (as required by the Provincial Policy Statement) and increase efficiency of applications' review. To that end, I would invite the government to consult with conservation authority, municipal, and consultant task forces on this issue.

The MNRF has a proven track record of reviewing wetland evaluations and maintaining the province's wetland database, along with other natural heritage information sources. Giving municipalities the responsibility for wetland files will increase the cost and time it will take to review background information (for both consultants/developers and municipal staff), and will limit the ability of consultants to provide quick and accurate answers to developers looking for a natural heritage constraints analysis in support of property speculation. Further, municipalities do not have the staff or technical knowledge to properly review wetland evaluations. Does the government plan to provide more money to EACH municipality so that they may staff up to fulfill their duties or to outsource the task to qualified consultants? Is record keeping going to be standardized prior to changes taking effect? It seems obvious to me that it is more cost-effective and effective for a few experienced MNRF staff to review than for each municipality to do so.

Furthermore, eliminating wetland complexing is anti-science and will negatively impact wetland ecology and the ecosystem services they provide. It is well known that wetlands sequester massive amounts of carbon, contribute to ground and surface water quality, and alleviate flooding. These are all major concerns as the effects of climate change become more pronounced.

I do recognize that at times the MNRF have been overly conservative when including small wetlands to Provincially Significant Wetland complexes based solely on the 750 m proximal distance criteria alone. I suggest that in order to complex a wetland, there needs to be an additional technically defensible reason for complexing separate wetland units within 750 m of each other (e.g., hydrologic connection, significant corridor function, etc.). Wetlands should remain as open files (with MNRF as central repository for the files) so that wetland complexes with questionable elements may be reexamined. This, along with a technically defensible offsetting policy, could allow for these small wetlands oft surrounded by developable land, to be compensated for elsewhere on the landscape.