Wetlands provide several…

Wetlands provide several benefits and ecosystem services such as flood control/ attenuation, drought control, shoreline stabilization, water purification, groundwater recharge and discharge areas, carbon sequestration and habitat for diverse species (including endangered or threatened species). When protected in a connected natural heritage system, wetlands are a natural and cost-effective tool to mitigate impacts of flooding, erosion, and drought, particularly in the face of a changing climate, which put people, property and built infrastructure at risk. For all these reasons, the protection of wetlands remains critical in Ontario.

Please, consider the following recommendations:

1. Establish a “user” working group to discuss and review changes to the Ontario Wetland Evaluation System prior to finalizing changes.

2. Retain the section of the OWES Manuals titled “Wetland Complexes” as well as all references to wetland complexes / complexing.

3. Amend the proposed “Re-evaluation of previously evaluated wetland complexes” subsection to state that re-evaluation of wetland complexes may only occur through a complete re-evaluation of all units in the existing wetland complex at the same time, and that the status of a wetland complex (e.g., significant or not) may only change based on such a re-evaluation of the complete wetland complex.

4. Limited circumstances should be clearly outlined for an individual wetland – that is part of a complex – to be re-evaluated on its own to avoid confusion or misapplication of the manual.

5. Retain sections 4.1.2.1 (Reproduction Habitat for an Endangered or Threatened Species) and 4.1.2.2 (Migration, Feeding or Hibernation Habitat for an Endangered of Threatened Species) in the OWES manual to signal the high importance of these attributes when evaluating or re-evaluating wetlands. Retain or re-evaluate the current evaluation scores for these attributes.

6. Amend the OWES Manual to state that a “wetland evaluation, re-evaluation or mapping update will be considered “complete” once it has been received by a decision maker addressing a land use planning and development or resource management matter and has been submitted to the Ministry of Natural Resources and Forestry District or Area office in which the wetland is located”.

7. Clarify who a “decision maker addressing a land use planning and development or resource management matter” is to provide greater clarity on when wetland evaluations may be undertaken and who they should be submitted to, and to assist external agencies and private landowners with navigating the process of obtaining completed wetland evaluations.

8. Retain the section of Appendix 1 that speaks to “locally significant wetlands” to provide transparency of process for municipalities to designate and protect wetlands that do not meet the criteria for a “provincially significant” designation (i.e., “locally important wetlands”).

Thank you for the opportunity to comment on the “Proposed Updates to the Ontario Wetland Evaluation System” (ERO#019-6160).