While several concerning…

While several concerning changes have been proposed to the OWES, the two most striking are 1) the removal of government oversight or availability for consultation, and 2) the removal of wetland complexes.

In the revised OWES, most, if not all, text has been removed that refers the evaluator to the MNRF and/or MECP. The previous version encouraged the evaluator to contact these Ministries if they had any questions or uncertainties about an evaluation. By removing this text, it can be assumed that evaluators no longer have the option to discuss OWES with said Ministries. If that is the case, then there is no longer an avenue for consultation between evaluators and the provincial government. Evaluators would no longer be able to ask questions or receive guidance on difficult to assess wetlands. There would be no avenue for communication between those who evaluate the wetlands and those who regulate them.

The removal of any language about wetland complexes is the most concerning change to the OWES. The concept of a wetland complex reflects a common feature in landscapes. Often a large area of a landscape functions as a wetland, even though it consists of a mosaic of wetland and more upland areas. The previous version of the OWES considered units within 750 m of each other to be part of the same wetland complex. The revised OWES has lowered that distance to 30 m. This can be expected to decrease the area of a wetland complex, allowing for the re-evaluation of individual wetland units as stand-alone wetlands. An individual unit may not provide the same function as the wetland complex as a whole, and will likely be assessed as having lower significance than it otherwise would. In other words, the whole is greater than the sum of its parts. These changes to the criteria for wetland complexes are inaccurate, and ignore the reality of wetland hydrology and function.

The purpose of revising a protocol is to improve upon it. The proposed changes to the OWES will make it less accurate, less reflective of reality, and lead to the degradation of Ontario’s wetlands. It is clear that the proposed changes are not based on science.