Thank you for the…

Thank you for the opportunity to comment on the proposed changes to the Ontario Wetland Evaluation System (OWES).

The OWES has been an important tool in identifying significant wetland features throughout the Province of Ontario. We note that the proposed iteration of this system would devalue these wetlands in all instances except as part of the municipal planning process (Page 4, paragraph 6).

Based on the consultation guide provided, we have significant concerns with the changes proposed. These concerns include the following:

1. It is unclear who the ultimate approval authority will be for changes to wetland designations and boundaries under various pieces of legislation (Planning Act, EAA, ARA, NEPDA, etc.). We strongly recommend that this role remain with MNRF.

2. It is unclear who the ultimate holder of the wetland data will be. We strongly recommend that this role remain with MNRF or another appropriate Provincial service.

3. It is unclear how many times a wetland can be re-evaluated and which re-evaluation is the appropriate one.

4. This new system removes the watershed lens and may result in impacts that extend outside of a municipal boundary, with no Provincial or conservation authority oversight to review the bigger picture. We are opposed to this change in governance for the systems and believe that it will have negative consequences for natural hazard and natural heritage management in Ontario.

5. The removal of the wetland complex concept will serve to dramatically reduce wetland features on the landscape, increasing flood and drought risk, and reducing habitat, biodiversity and ecosystem services. We are opposed to this change and believe that it will have negative consequences for natural hazards and natural heritage in Ontario.

6. It is unclear if the guide is suggesting that the recent or future elimination of a wetland for agricultural purposes (Page 9) would cause a wetland to not be considered such any longer. It is also unclear if such changes would allow for the removal of wetlands in advance of Planning Act applications under the guise of agriculture.

7. MNRF has a long history of natural resource management. It is unclear why the consultation guide is proposing to remove all references to MNRF as a source of data for undertaking wetland evaluations. We are opposed to MNRF being removed from a role here as it will negate decades of experience and corporate knowledge.