The Ontario Provincial…

The Ontario Provincial Government and the Ministry of Natural Resources and Forestry (MNRF) are proposing changes to the Ontario Wetland Evaluation System (OWES) procedure.

The proposed changes have been summarized on the Environmental Registry of Ontario (ERO), as follows:
• add new guidance related to re-evaluation of wetlands and updates to mapping of evaluated wetland boundaries
• make changes to better recognize the professional opinion of wetland evaluators and the role of local decision makers (e.g. municipalities)
• other housekeeping edits to ensure consistency with the above changes throughout the manual

I have reviewed the changes to the OWES procedure and provide the following review and comments.
Summary of changes:
• removal of third-party oversight, assistance, or expertise
• removal and re-evaluation of wetland complexes
• reduction of functionally-linked wetland complexes (750m)
• new closely grouped wetlands (30m)
• wetlands less than 2 hectares will no longer be evaluated
• protections around Provincially Significant Wetlands (PSWs) reduced
• species at risk removed from wetland scoring

My concerns with the proposed changes, are as follows:
1. The loss of third-party oversight and assistance with wetland evaluations has the potential to be detrimental to future wetland evaluations. There have already been weaknesses in the interpretation of wetlands under the OWES.
2. Wetland complexes generally consider functionally linked wetlands within 750 metres of each other. Removing wetland complexes greatly reduces the holistic nature of wetland ecosystems and is likely to have negative unintended consequences to biological function and wildlife corridors. The proposal does not compensate for a degradation of biological function.
3. I am interpreting “closely grouped wetlands” as a replacement to wetland complexes. Where closely grouped wetlands are defined as within 30 metres of each other. Therefore, closely grouped wetlands are 25x smaller than wetland complexes. This provision has the ability greatly reduce the amount of wetland areas in the province. No consideration is given to biological function.
4. Without wetland complexing, wetlands less than 2 hectares in size may not receive the appropriate protections. 
5. The quantity of PSWs and the protections around PSWs are being greatly reduced. By removing Species at Risk in Ontario as a scoring factor, the amount of PSWs will be reduced. The removal of wetland complexing will also reduce the amount of PSWs. A reduction in the regulation area from 120 metres to 30 metres will not provide adequate protections for wetland function and biodiversity.
6. I agree that wetland scoring using Species at Risk in Ontario (threatened and endangered) presents some challenges with development and maintenance work on existing infrastructure (i.e. bridge, chimneys, etc.). However, by removing species at risk as a major component in wetland scoring, we are in turn de-evaluating some wetlands biologic function.

Wetlands provide many important functions such as water filtration, flood mitigation, carbon sequestration, increased biodiversity, and ecosystem support during dry periods. In Ontario, wetlands are some of the most biodiverse natural features on our landscape and deserve much more protection and understanding then they received. Wetlands should not be considered an impediment to developed, but should be celebrated and protected.

Established in 1983, the OWES has been useful in evaluating and managing wetlands throughout Ontario. However, it was not the only system prepared at the time. Three systems were prepared and the current system was selected. Since 1983, wetland evaluations have been carried-out all over North America using a myriad of different systems.

My recommendations to the review team are simply:
1. Refrain from dismantling the current system;
2. Review and assess existing wetland evaluation systems across North America; and
3. Consider Species at Risk in Ontario and biological function as major components when evaluating wetlands (i.e. keep the ecosystem component in wetland assessments).

In closing, at the end of the day we all need and want to see an increased protection of wetlands and the ecosystems they sustain.