Comments on the Proposed…

Comments on the Proposed Updates to the Ontario Wetland Evaluation System (OWES) October 25, 2022

Background
The Province has estimated that we have already lost 72% of our wetlands in southern Ontario. For example in the southern GTA we only have about 2% of the landscape left in wetlands. Wetlands are critical to the health of our watersheds. They help to reduce downstream flood events, help to recharge our aquifers, protect groundwater, control erosion and clean our waters of pollutants. Their organic soils and vegetation store vast amounts of carbon and are critical to retain if we want to meet our climate targets. Many of the province's animals and plants, including many species at risk, are dependent on wetlands for all or part of their life cycle. Wetlands and their adjacent woodlands and meadows when protected become new public natural areas for the enjoyment of our citizens. Our existing natural areas are suffering greatly from overcrowding especially since the public has rediscovered them during COVID.

In recognition of the importance of wetlands, provincial wetland scientists developed the Ontario Wetland Evaluation System manual or OWES for short. It was first devised in 1982 and has been updated and expanded over the years as we have gained more knowledge on the ecological functions and value of wetlands. The scores for the four components that make up the manual are added up to see if the wetlands meet the provincial significance threshold. If they are provincially significant they are protected from development. Over the past 40 years thousands of wetland complexes have been evaluated, with most of them provincially significant. It is estimated that the majority of the wetlands in southern Ontario have been evaluated.

As a citizen of the Province I cannot support the changes proposed to the OWES manual. The OWES manual and its scoring system is based on sound ecological principles and on the accumulated scientific knowledge we have acquired on the ecological importance and function of wetlands in maintaining healthy watersheds and Ontario's biodiversity. All the changes being proposed are not supported by science. I recommend keeping the manual in its current form. I want our existing wetlands protected and efforts made to restore some of the wetlands we have already lost to ensure that we have healthy watersheds and more public natural areas for everyone to enjoy.

The proposed changes to the manual will in essence gut the manual. It will invalidate most of the thousands of evaluations that have been completed over the past 40 years. This is being done without consulting all the wetland experts that worked on this manual over the years. These changes will result in consultants for developers being able to downgrade most of the wetlands that are currently provincially significant so that they become non-provincial and therefore open for development.

This will also impact on all the private landowners that currently get a municipal tax reduction through the Conservation Land Tax Incentive Programme (CLTIP) for having a provincially significant wetland. With the proposed changes, an adjacent owner or developer can get a consultant to downgrade their wetland status so they become ineligible for the tax reduction. The landowner has no recourse when this happens because the Province will no longer review and approve wetland evaluations.

Specific Comments
Wetland Complexing
The current manual treats and scores a grouping of wetlands or a wetland complex as though it is one wetland. This is because wildlife research shows that numerous species visit many wetlands on the landscape, moving between wetlands and also utilizing the surrounding intervening upland woodlands and meadows. For example turtles such as the endangered Blandings Turtle will move around and utilize many wetlands over the course of a year for feeding and hibernating. Woodland frogs will breed in wetlands but then spend the rest of the year in surrounding woodlands to feed. The current manual says that wetlands within a maximum of 750 metres from each other and in the same watershed can be scored together as part of a wetland complex. This 750 metre distance covers the ability of many animals to make such movements between wetlands. The update to the manual removes all mention of wetland complexes from the manual. Sections of the manual referencing wetland complexes are removed from pages 9, 15, 16, 26, 27, 29, 32, 33, 34, 36, 38, 39 and 40. The only wetland complexing allowed in this proposed update (see page 20) is for small wetlands that are within 30 metres of each other in a woodlot or those within 30 metres of each other along a river or lake. There is no scientific basis to restrict wetland complexing to wetlands that are a maximum of 30 metres apart. This new cutoff of 30 metres will invalidate most of the thousands of existing evaluation wetland complexes that have been done over the past 40 years. The changes to the manual will allow a consultant to take out a single wetland from a complex, evaluate it on its own, and down-grade it to non-provincial status. Most wetlands on their own would not score as provincially significant unless they are very large and diverse wetlands. But because they are part of grouping of wetlands in a complex they do score as provincially significant due to the cumulative values of all the wetlands. In conclusion, it does not make ecological sense to only score one wetland in isolation. In fact, if wetlands are only going to be scored individually it would result in most wetlands not being provincially significant. The existing wetland complexing rules need to be retained.

Scoring for endangered and threatened species
The proposed update to the manual no longer scores a wetland if it supports an endangered or threatened species (see changes on page 52). The manual currently makes a wetland or wetland complex that supports occupied habitat for a Species at Risk provincially significant and gives a high score for traditional migratory, feeding and hibernation habitat used by these species. This scoring is in recognition of the fact that endangered and threatened species are facing provincial extinction if present trends continue. By scoring them in the manual you are helping to protect their wetland habitat or their traditional wetland feeding, migration or hibernation areas. The existing scoring for endangered and threatened species needs to be retained.

No standardization of wetland evaluations and no public repository for wetlands
Currently wetlands are overseen by wetland experts at the Ministry of Natural Resources and Forestry (MNRF) and in areas that have Conservation Authorities these authorities regulate wetlands. MNRF is responsible for ensuring that all wetland evaluations and wetland boundary delineations meet the standards set out in the OWES manual. The Ministry also keeps a repository of all the approved wetland evaluations that are available to the public free of charge and also keeps up to date a digital database on the Province's wetlands that is freely available on the Ministry's website. The proposed update to the manual eliminates all mention of MNRF and CAs role in wetlands. MNRF wetland experts will no longer review or approve them nor will they continue to be the repository for all evaluations. A consultant for a developer with little field experience can now take the 5-day accreditation wetland course and then evaluate wetlands on their own with no one ensuring they meet basic standards. The Ministry will no longer even get a copy of the evaluation for its public repository of wetland evaluations and will no longer be able to update its provincial wetland database. The public will no longer know what wetlands have been evaluated, what wetlands have been downgraded to non-provincial or what wetlands have had their boundaries changed or been totally eliminated because they have been filled-in and developed. The Province will no longer be able to assess the state of its wetlands (i.e. how many have we lost, how many have been restored). It will thus not be able to issue State of Biodiversity reports as required by the United Nations or know if it is meeting climate change targets in regards to wetland carbon sequestration. The Province needs to continue to review and approve wetland evaluations and boundary delineations and the CAs need to continue to regulate wetlands.