This proposal is anti…

This proposal is anti-science and anti-wetlands. I fully support the comments and recommendations submitted by Save Ontario Wetlands. Regarding the removal of oversight of the MNRF: what does this Ministry even do anymore? other than shill for extractive industry??

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

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.

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.

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 resourcing.

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.

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.

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.

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.