To Whom It May Concern,…

To Whom It May Concern,
Please accept my comments for the Proposed Updates to the Ontario Wetland Evaluation System included below. In short, I disagree with most of the changes proposed and there should have been reasoning provided with the document explaining the larger changes, especially when large portions were being removed or added. This was not done and as such, I believe that this proposal was not shared with the proper information and therefore should not move forward and this should go through a second round of comment with this information provided.
I am not an expert in this field (wetlands, ecology, hydrology, etc.), however, I do work in the planning field and work with the data that is created through these evaluations.

The first concern I have is the removal of the MNR throughout the process, this has a very strong potential to reduce the consistency across the province in what is considered a PSW. The sections which suggest seeking advice from MNR have been removed and examples explaining how to evaluate have been removed. This will also reduce the consistency of how these evaluations occur. This is one of the examples where the removal of MNR could result in inconsistencies "Any trained wetland evaluator may carry out a full wetland evaluation; however, all wetland evaluations must be reviewed and approved by the MNR before they are considered complete and ‘official’ (i.e. the wetland status may be used to make land use planning decisions). As part of the review of a submitted evaluation, MNR may amend certain scores, information, or features contained in the submitted evaluation." Who will review these reports and make sure they are completed accurately. Not everyone "trained" in their field is doing their job for the right reasons and I have seen first hand where people will make a decision for the right kind of money opposed to the best decision for the environment or in this case preventing flooding and damage to future homes in the vicinity.

Second Concern was the removal of this section of the uses of this work:
"2. By the province as an aid to land use planning. In this regard, the wetland evaluation system serves as an essential cornerstone of wetland policies of the Provincial Policy Statement, authorized under Section 3 of the Planning Act. As well, the evaluation system may prove of value in identifying nationally and internationally important wetland features. 3. By conservation authorities as an aid in implementing regulations under the Conservation Authorities Act. Conservation authorities for purposes of public safety, natural hazard prevention and management, regulate wetlands for flood attenuation, natural storage capacities and for preventing shoreline erosion. Conservation authorities also regulate areas around wetlands that may interfere with the hydrologic function of the adjacent wetland including in general areas within 120 metres of all PSWs and areas within 30 metres of all other wetlands. Many conservation authorities evaluate wetlands; MNR retains authority to identify PSWs. 4. By conservation authorities who at the request of their municipalities or as approved by their boards may be developing a broad watershed plan or study to provide technical advice to municipalities for plan input or to direct management on conservation authority owned land. 5. By MNR to manage and conserve fish, wildlife, land and other resources and to inform stewardship and incentive programs. A wetland that has been evaluated using this system is known as an “evaluated wetland” and will have a “wetland evaluation file”. NOTE: Where there are wetland features on a site that have not been evaluated or that have not been recently evaluated, municipalities, county governments, conservation authorities, landowners, or others should not assume that the wetland is not significant. "
There are a few reasons I am concerned. The main one is that Conservation Authorities assist municipalities with mitigating potential flood issues. The City of London deal with the Thames flooding and Hurricane Hazel was the reason the Conservation Authorities were put into place. If something closer to Toronto needs to be used as an example, might I use the flooding that happened on July 8, 2013 (https://nationalpost.com/news/toronto/streets-just-couldnt-dispel-the-w…) which trapped a train in the Don Valley. I was on a team that worked closely with the Conservation Authority and Metrolinx to come up with a solution to make sure that wouldn't happen again. And the relationship with the MNR for their conservation efforts is critical.

The third concern is that no trigger has been identified for a re-evaluation. This should be identified. I do not have the expertise to state what this should be, however, this document should state what allows for a PSW to be re-evaluated. Is this something a land owner can request or is this something done by the municipality? And when the re-evaluation is completed, who is picking the “trained professional”?

The fourth concern, why were wetland complexes removed? No reasoning was provided.

The fifth concern is the removal of the Wetland Evaluation File. This should not be removed and as a minimum should have a digital format that is maintained. I could not find anywhere in this manual that referenced where this data and information would be kept and by reducing the required information that should be provided means that less information will be captured. This is a tactic that is used to empower a decision maker to make decisions against something and to reduce anyone from opposing because they will not have the data to back up their argument. This is similar to the Conservatives doing away with the Long Form Census. And if the response is that this should be up to the municipalities to determine the type of information they should be capturing, I have worked with contracts and I know that if it is not explicitly laid out in black and white, you will most likely never receive it. And if you have a novice person dealing with this who tries to use this manual after it has been gutted, they may not know they types of information they should be supplying.

The sixth concern is the examples in the Sources of Information section have all been removed. This is again another example of how this manual is not going to provide useful information for the users. This entire piece should not be removed:
“Contact with appropriate organizations and agencies, outlined below, is vital to the credibility of the evaluation and of the Special Features component in particular. One of the best methods for ascertaining the exact locations of wetlands within a study area is through a review of the following: 1. Digital data and imagery available through Land Information Ontario 2. Infrared, black & white stereo aerial photographs or ortho-rectified digital aerial imagery; 3. National Topographic Series (NTS) maps; 4. Forest Resources Inventory (FRI) maps; 5. Regulatory or watershed based maps that may be available from a conservation authority; 6. Satellite imagery (such as LandSat and SPOT) 7. Southern Ontario Land Resource Information System (SOLRIS) 8. Ecological Land Classification (ELC) mapping 9. Digital Elevation Model (DEM) & contours 10. Soils mapping 11. Surficial geology mapping 12. Other wetland or natural heritage system mapping”.

The seventh concern is again about data. The data within the section titled Completing the Wetland Evaluation Data and Scoring Record should not be removed.

The eighth concern is the removal of Section 4.1.2.1 Reproductive Habitat for Endangered or Threatened Species and Section 4.1.2.2 Migration, Feeding or Hibernation Habitat for an Endangered or Threatened Species is unacceptable. In a time when we are in a crisis and losing species could impact the ecosystem to remove these from the evaluation is showing a complete disregard for the environment and our stewardship towards it.

These are all of my concerns. I believe the MNR should not be removed from this process and the proposed changes should come with reasons for why they are making the proposed changes.
I disagree with this revised document being made final.
Regards,
Concerned Citizen in the Province of Ontario