As a certified provincial…

As a certified provincial wetland evaluator I recognize the importance of wetlands and their need for protection. The current OWES protocols due have some clarity issues. Some of the proposed updates, such as clarity around wetland boundary updates and reviews, as well as recognizing the professional opinion of wetland evaluators is a positive step. However, any of the other proposed changes hold cause for concern and do not represent the best interest of protecting provincially significant wetlands in the province.

Removing species at risk habitat scoring from the special features section is a worrisome proposed change. Species at risk habitat is critically important for protection. Many smaller wetlands, especially urban wetlands, would lose there provincially significant status if species at risk scoring was taken away. This is not in the interest of wetland preservation. Simply scoring them under significant other species/rare species will not score the same points, or offer the same protection. I would not suggest this removal

Removing the ability to complex wetlands and the verbiage around them is equally worrisome. Many wetlands, especially ones in southern ontario, have become fragmented due to human activity. What remains on the landscape are smaller wetland pockets that are disjointed, but still operate in tandem across the landscape. Losing the ability to complex wetlands together is not in the best interest of wetland preservation. Many smaller urban wetlands would be broken up and lose status, paving the way for development and loss of these critical features.

Adding the ability of non-certified people to conduct wetland evaluations is a worrisome step. Although the shortage of wetland evaluators is understood, more effort should go into bringing back additional certification courses, rather than simplifying field protocols. Simply having a certified evaluator review work conducted by another individual will lead to the potential for errors and incorrect evaluations. This also leads to the potential for wetland loss due to inexperienced and non-qualified individuals as a certified evaluator may not be able to catch these mistakes if they were not out in the field with them. Wetland evaluators should need to be in the field when any work is being conducted and have been the one to collect the data, although assistance in field is a reasonable permission.