Re: Proposed Updates to the…

Re: Proposed Updates to the Ontario Wetland Evaluation System
Wetlands are a crucial component of our ecosystems - they serve an important role in nutrient cycling, filter water, moderate stormflows, and provide critical habitat for threatened or endangered flora and fauna. Unfortunately, wetlands are also one of the most heavily impacted natural heritage features in Ontario with approximately 72% of wetlands lost in southern Ontario between pre-European settlement and 2002 (Ducks Unlimited Canada, 2010). Regionally, the loss of wetlands has been staggering - Essex and Kent in southwestern Ontario have lost upwards of 98% of wetlands (Ducks Unlimited Canada, 2010). As a society, we should be doing everything we can to preserve the few functioning wetlands we have left in southern Ontario. The proposed changes to the Ontario Wetland Evaluation System (OWES) do the exact opposite and will only serve to accelerate the loss of wetlands. I take issue with several of the proposed changes to the OWES:
• Approval of Wetland Evaluation (Southern Manual pg. 6) – the need for any type of oversight regarding a wetland evaluation by the MNRF has been removed and a completed wetland evaluation or re-evaluation only needs to be forwarded to the decision maker involved with the land use decision. Many municipalities and other decision makers lack staff with the necessary expertise to properly review a wetland assessment for accuracy and completeness. With the MNRF removed from the process, there will be little to no checks within the system to ensure a wetland evaluation is conducted accurately and rigorously. This opens the door to land use decisions being made based on poorly conducted wetland evaluations that mis-classify wetlands as not significant. A wetland evaluation may be insufficient because of a lack of knowledge on the part of the environmental consultant or due to the inherent conflict of interest that incentivizes them to provide a favourable wetland evaluation for the developer. Regardless of why there may be problems with a wetland evaluation, the only way to prevent poor evaluations from inflicting environmental harm during the land use decision process is to have knowledgeable oversight that provides final approvals. The MNRF provides the crucial oversight needed in the system to prevent the permanent loss of our most attacked natural heritage feature. The MNRF needs to continue providing final approvals.
• Removal of all reference to contact MNRF – the proposed document removes almost all reference about contacting the MNRF, whether it be for data or information about the OWES. I see this as a mistake because the MNRF can prevent the submission of poorly conducted wetland evaluations by serving as a contact for questions regarding the OWES. Who is an environmental consultant to contact when they are unsure of what to do or how to score a given category? Without a contact for help, you have opened the door to the submission of poorly conducted wetland evaluations. Further, we want wetland evaluations to be conducted with the most complete and accurate data available and I cannot understand why you have removed the MNRF as a data source. MNRF staff are some of the most knowledgeable people in the province regarding our natural resources because that is their job. There is no rational reason to remove all reference to the MNRF as a source of data for a wetland evaluation or information about the OWES.
• Re-Evaluation of Previously Evaluated Wetlands – it is proposed that “with the exception of closely grouped wetlands, single wetland units that are part of a previously evaluated wetland complex can be re-evaluated (re-scored and re-mapped) without requiring a complete re-evaluation of all units in the existing wetland complex”. Allowing individual units to be re-evaluated separate from the overall complex opens the door to the piecemeal destruction of a wetland complex through the gradual removal of individual units. There is no ecological reasoning why you would ignore adjacent wetland units that are ecologically and hydrologically connected to the unit under evaluation. There is a provision requiring the evaluation of close wetland systems as one unit; however, close wetland systems have a very restrictive 30 meter cut-off distance between individual wetland units. The definition of a close wetland system does not reflect how species interact and use wetland complexes. For example, amphibians regularly move amongst habitat units beyond 30 metres and are capable of traversing distances greater than 1 kilometre (Smith and Green, 2005). Turtles are also capable of long-distance movements (Millar and Blouin-Demers, 2011). The original OWES definition of a wetland complex (wetland units within 750 metres) was more consistent with the ecology and should stand. It is clear the proposed reduction in wetland complex protection is an attempt to save developers money during the environmental assessment process and provide a loophole for the slow destruction of wetland complexes. Wetland removal is permanent, and we all lose when the ecosystems functions wetlands provide are lost from the landscape. Any evaluation of a wetland unit within a complex (i.e., within 750 metres of each other) should automatically result in the whole wetland complex being evaluated because that is the ecological context within which the wetland unit operates.
• Wetland Evaluation File – a wetland evaluation file should continue to be submitted to the MNRF for archiving and public access, regardless of what oversight role MNRF has in the wetland evaluation process. Wetlands are a crucial natural heritage feature and the information that is used to justify their destruction should be deposited in a centralized location. Under the current proposal, a wetland evaluations will be submitted locally preventing any sort of broadscale quality control or analysis to inform later policy development and decision making at the provincial level. This is just poor planning by the current government, and it is clear the government is trying to make it difficult to closely track wetland evaluations in the province.
• Removal of the Reproductive Habitat for Endangered and Threatened Species and Migration, Feeding, or Hibernation Habitat for Endangered and Threatened Species sections – the proposal removes the scoring of a wetland based on whether an endangered or threatened species uses the wetland for reproduction, migration, feeding, or hibernation. The endangered and threatened species scoring was included to help ensure that a wetland supporting an essential life function for an endangered or threatened species is preserved. The vast majority of species are endangered or threatened because they lack the essential habitat needed to support a thriving population. The government has clearly signaled that they care little about preserving the biodiversity of Ontario because they are happy to directly contribute to the extirpation of endangered and threatened species for a few homes that could very well be built on less ecologically important land. The proposal does capture endangered and threatened species in with Provincially Significant Animal and Plants Species scoring; however, the protection afforded to wetlands that support endangered and threatened species are much less as a result. The scoring for the reproductive, migration, feeding, and hibernation habitats of endangered and threatened species needs to be restored.

Wetlands are not some sort of “red tape” for you to remove for development. Instead, they are an integral component of our ecosystem that provide much needed ecosystem services we take for granted everyday. We have destroyed most of our wetland ecosystems in Ontario and now we need to do everything in our power to preserve what we have left.
I ask that you please reconsider your proposal for the OWES because it does not serve Ontario’s best interest. Our wetlands deserve better.

References
Ducks Unlimited Canada (2010). Southern Ontario Wetland Conversion Analysis. Accessed from: https://longpointbiosphere.com/download/Environment/duc_ontariowca_opti…
Millar, S. and G. Blouin-Demers (2011). Spatial ecology and seasonal activity of Blanding’s turtles (Emydoidea blandingii) in Ontario, Canada. Journal of Herpetology 45(3): 370-378.
Smith, A. and D.M. Green (2005). Dispersal and the metapopulation paradigm in amphibian ecology and conservation: are all amphibian populations metapopulations? Ecography 28(1): 110-128.