As a Conservation Ecologist…

As a Conservation Ecologist with over 19 years of experience, I am gravely concerned about the proposed changes to the Ontario Wetland Evaluation System (OWES). Ontario’s wetlands play a crucial role in our environment and our lives. As green infrastructure, they act as flood attenuation and storage areas that protect people and property; they are recharge areas for groundwater, which provides a drinking water source for many Ontarians; they protect water quality by filtering nutrients and pollutants; and they provide wildlife habitat for a vast number of species, including those designated as at-risk by the Province. Our wetlands also support tourism and recreation. Anglers and hunters use these areas, and their adjacent habitats as key resource areas. And the tourism industry benefits from people who visit natural areas with wetlands to witness the beauty and fascination of nature.

Should these proposed changes to OWES be implemented, existing Provincially Significant Wetlands will lose their status and un-evaluated wetlands are unlikely to meet the standard for additional protection. This will result in wetlands being destroyed and lost, along with all the benefits they provide. This means a loss wildlife habitat and reduction or loss of wildlife populations, decreased flood attenuation and storage, increased erosion, poorer water quality, and the decreased of tourism and recreation, and the revenue those activities bring to communities.

To be clear, Ontario has a housing supply crisis, but does not have a shortage of developable land. Affordable housing is needed and important, but that is possible without removing environmental protections that make Ontario a great place to live in the first place. Gutting the OWES will result the destruction and removal of the remaining wetlands in Ontario. Southern Ontario has already lost at least 70% of historic wetlands and we cannot afford to lose any more. These proposed changes are not supported by science and will erode decision makers ability to protect wetlands and their functions.

Specifically, I am concerned about the following elements of this proposed changes:
1. The removal of the MNRF as an oversight body:
• This leaves no oversight system in place and no replacement identified.
• There will be a significant loss of knowledge since the MNRF has been the administering body for this system since its inception. This will result in a significant need for additional resources and administration capacity that will be lost.
• Unclear who will oversee OWES evaluator training and certification.
• Unclear who can be contacted for further details and support.
• Unclear who will be responsible for making final decisions or determining outcomes if there is a disagreement between evaluators.
• Unclear who will be responsible for training and certifying evaluators.
• Unclear who will be responsible for overseeing wetland files and how this will be done.

2. Addition of “A Complete Evaluation” section.
• Unclear who a ‘decision maker’ is and how they will be looking at evaluations.
• Unclear who will be responsible for updating and maintaining the provincial wetland database and mapping information.
• Complete once it has been received’ provides no oversight to ensure that the evaluation was completed properly.

3. The removal of Conservation Authorities from the manual. Conservation Authorities require tools and data including the information generated through OWES to continue to focus on natural hazard management and fulfill their core mandate.

4. Changes to enable re-evaluations and mapping updates, and the removal of wetland complexes.
• Unclear what ‘closely grouped wetlands’ means.
• Wetlands do not function independently of one another, they collectively provide significant ecological functions and services, and need to be complexed in order to protect these functions. Removing wetlands from the complexes in which they have been identified fails to recognize how wetlands function on the landscape. It will result in the vast majority of wetlands not meeting significance criteria and becoming unprotected.

5. Removal of 4.1.2.1 Reproductive Habitat for Endangered or Threatened Species and 4.1.2.2 Migration, Feeding or Hibernation Habitat for an Endangered or Threatened Species
• Wetlands are a vital ecosystem for many of Ontario’s Species at Risk. Wetlands support these species by providing breeding, nursery, foraging and overwintering habitat for residents, as well as migratory species. Without the wetlands that support them many of these species will become at risk of extirpation and even extinction. The removal of these scoring criteria will result in the vast majority of wetlands not meeting significance criteria and becoming unprotected.

I strongly urge you to reconsider this Bill:
• The role of the MNRF in the administration of OWES be retained.
• The complexing of wetlands be retained.
• The scoring of Endangered and Threatened species be retained.
• The province engage with a multi-stakeholder working group to determine the unintentional negative implications of these proposed changes, and develop scientifically sound alternatives, prior to proceeding with the current proposed amendments.

If these changes are adopted the very essence of Ontario will be threatened. I fear that the consequences of this proposal will be far-reaching and cannot be undone once wetlands are drained, filled and developed.

This is a province of varied and rich ecosystems and natural resources, and these changes undermine the very foundation of what makes Ontario special. We can achieve more, affordable housing without destroying our ecosystems, and I implore the province to protect our environment.