As a certified wetland…

As a certified wetland evaluator, I agree that the manual and evaluation methods need to be revised. The manuals are out of date and there is some ambiguity when it comes to evaluation criteria. What I don't agree with is how these proposed updates and Bill 23 plan to go ahead with it.

Removal of Species at risk from consideration: We are all well aware that much of Southern Ontario is full of degraded and fragmented habitat. Wetlands are more than just the plants on the ground and the water that they protect. These fragmented PSW's are some of the last natural areas and refuges in cities. By removing the inclusion of species at risk from wetland protections we are missing a big piece of the picture. I could easily name 20-30 wetlands that will lose their PSW designation because they are too small and are solely protected due to species at risk being present. These are places that have been fragmented by roads and subdivisions and otherwise poor municipal planning decisions. This is the habitat of Jefferson Salamanders, Blanding's turtles, Musk turtles, and Spotted turtles. Without the species at risk inclusion, these wetlands would not meet the criteria for provincial significance and would lose their protections.

Third Party Review: If the MNRF is no longer reviewing these submissions, then who will be? Removing the MNRF reviews and the Conservation Authority reviews will result in big discrepancies across municipalities on what is considered 'a good report'. Although some municipalities have a team of environmental planners on staff, many do not (such as the City of Brantford). Development planners are not equipped with the tools nor the knowledge to assess wetland evaluations reports. There should be a competent and qualified third party that is reviewing these submissions. Developers and their consultants are known for pushing the envelope, omitting information, and submitting poor reports to support of their proposals. I have personally seen this happen and this problem has only grown exponentially over the past few years.

Wetland Scoring: If criteria for wetland evaluations is being removed or modified, then we should also be adjusting the scores accordingly. A wetland that is 2 hectares in size is only practical in low development regions. In Southern Ontario, this could easily be decreased to half a hectare in size.

Wetland Complexes: This part is unclear and needs to be re-written. I can see how this could be interpreted in both ways. Either 'wetland complexes' are now considered a single wetland or that they are now considered several different wetlands. Clearer guidelines on how fragmentation plays into these decisions should be included. A road that passes through a wetland which creates a berm would have a different effect than one that has culverts/bridges or watercourses that connect nearby wetlands.

Lastly, the current OWES manuals do not effectively address wetlands being turned into farmland. Developers have realized that the easiest way to get their subdivision project built is to have their wetlands removed via farming practices first. As there are not currently any laws or regulations that protect wetlands from farming (i.e. planting crops, or installing tile drains), wetlands are removed, farmed for a few years, and then re-assessed. Once the vegetation has been removed, the areas is no longer considered a wetland (as per OWES) and they are free to develop the lands. If we are updating the manuals and evaluation criteria, there should be new methods for addressing wetland degradation and removals. If left to naturalize, many of these areas could easily be turned back into wetlands and provide wetland functions within a few years.