Please find attached…

Please find attached detailed comments from Save Ontario Wetlands pertaining to ERO 019-6160. Below is a summary of key concerns and recommendations:

On behalf of the over 70 Ontario aquatic scientists and practitioners that joined the Save Ontario Wetlands grassroots initiative, we submit comments pertaining to the proposed changes to the Ontario Wetland Evaluation System (OWES). For the record, these comments and recommendations were completed under a remarkably short review period (30 days), and thus are mainly focused on key proposed changes that we are most concerned about.

Summary of main concerns and recommendations:

The proposed changes to OWES described in the ERO posting # 019-6160 undermine the wetland report card in 6 key ways:

1. Insufficient review timeline (30 days) to assess, evaluate, and comment on the extensive proposed changes to OWES.
We recommend extending the review and comment period until at least Dec. 30th, 2022 to allow a robust review and consideration of all the implications of these proposed changes.

2. Removal of key oversight responsibilities of the Ontario Ministry of Natural Resources and Forestry (OMNRF) in the OWES process.
We recommend that related OMNRF staff maintain an integral role in wetland evaluation and assessment to ensure wetland expertise and sufficient oversight is part of the evaluation process.

3. Creation of a piece-meal and under-resourced wetland evaluation process by apparently downloading this important work to municipalities with little to no wetland expertise on staff and no additional resources.
We recommend OMNR remain the custodians of OWES files and continue to train professionals in the implementation of OWES. Amendments must retain clear lines of responsibility and afford validation and quality control of OWES evaluation files to protect the integrity of the evaluation process.

4. Removal of counting the value of a wetland for threatened and endangered species in the Special Features category.
We recommend that wetland value as habitat for threatened and endangered species remain in the Special Features category. Alternatively, the scoring thresholds for consideration as Provincially Significant should be dramatically lowered. Given 32% of species at risk in southern Ontario rely on wetland habitat and yet 60-90% of historic wetlands have already been destroyed, it is a safe assumption that all wetlands remaining in southern Ontario provide significant support for species at risk.

5. Removal of wetland complexing in spite of the mountain of scientific evidence that geographically isolated wetlands are ecohydrologically connected and interdependent.
We recommend that wetland complexing remain in the OWES to allow interconnected wetlands to be evaluated as an integrated whole.

6. The introduction of “re-evaluations” of previously evaluated and designated Provincially Significant Wetlands (PSW).
We recommend that the amendments concerning “re-evaluations” be removed from OWES given the process already treats evaluations as “open files” and encourages updates. The addition of “re-evaluations” is redundant and wasteful given only a fraction of the wetlands remaining in Ontario have undergone a single OWES evaluation.