1. Establish a “user”…

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

The Ministry of Natural Resources and Forestry (MNRF) is proposing updates to the Ontario Wetland Evaluation System (OWES) in support of Ontario’s Housing Supply Action Plan 3.0. A number of key changes are identified, including, but not limited to: changes to how wetlands are re-evaluated and how wetland boundaries are updated,
the ability to evaluate wetland complexes, changes in scoring criteria and attributes, and administration of the OWES.

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.

I am are concerned that many proposed changes will result in fewer wetlands being evaluated and designated as provincially significant. Further, proposed changes would allow for wetlands previously designated as provincially significant to be re-evaluated (particularly those part of previously identified wetland complexes), which may result in a gradual fragmentation and loss of provincially significant wetlands.

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

Under the current OWES (2014), wetland complexes are recognized as groupings of wetlands that are commonly related in a functional way and tend to have complementary biological, social and/or hydrological functions. OWES currently provides that, where a wetland complex is recognized, evaluators must score the entire complex as one wetland, and ensure that all individual wetland communities in the complex are mapped. The ability for evaluators to consider wetland complexing is significant, as considerations such as the “topography of the landscape in which these wetlands occur, the short distances between some of the wetlands, and the density of wetlands per unit of areal landscape may be so complex that delineation of the wetland units into individually recognized wetlands would not be an ecologically or functionally sound process” (OWES 2014, p. 39).

The proposed changes to the OWES manual would remove the section titled “Wetland Complexes”, as well as all references to wetland complexes / complexing (except for a new section titled “Wetland Re-evaluations and Mapping Updates”). If the proposed changes are finalized, wetland evaluators would no longer be able to evaluate an entire wetland complex as a single wetland. This will result in wetland units being evaluated individually, without consideration to their values across a network of interconnected features. This change may result in lower scoring wetlands, with fewer achieving scores to designate them as provincially significant.

Consideration of wetland complexes is a significant tool to mitigate potential impacts from natural hazards, as all individual units in a wetland complex may work together to provide services such as flood control/attenuation or shoreline stabilization.

I believe the section titled “Wetland Complexes” as well as all references to wetland complexes / complexing should remain in the OWES manual, to continue to require evaluators to score the entire recognized complex as one wetland.

Removing the ability to evaluate wetland complexes will result in many wetlands remaining unevaluated, resulting in a potential loss of protections for these wetlands (through a provincially significant or locally important designation).

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. 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.

Under the current OWES (2014), the “Special Features” component brings together certain biological and ecological attributes of wetlands for consideration, such as the geographical rarity of wetlands, species occurrence and habitat quality. Under the “rarity” subcomponent, consideration for habitats of endangered or threatened species, specifically, reproductive habitat (4.1.2.1) and migration, feeding or hibernation habitat (4.1.2.2), is provided. Scores for wetlands that provide such habitats for endangered or threatened species are high, with wetlands containing reproductive habitat for such species automatically receiving the highest value possible for a component of the OWES (250 points). The inclusion of high values for attributes such as endangered and threatened species habitat signal the importance of these attributes when evaluating wetlands. It should be noted that a score of 200 or greater in the “Special Features” component meets the requirements for designation as a PSW.

The proposed revisions to the OWES manuals include the removal of sections 4.1.2.1 and 4.1.2.2, signaling that reproductive, migration, feeding or hibernation habitat for endangered or threatened species would no longer be considered when evaluating a wetland in Ontario.

I urge consideration for these attributes as part of the “Special Features” component of the OWES be retained.

I believe its important that the province maintain the considerations for habitats of endangered and threatened species in the OWES, and review (and if needed, re-evaluate) the evaluation scores to effectively capture the values of wetlands that support endangered or threatened species in Ontario.

5. 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”).

Under the current OWES (2014), Appendix 1 speaks to the definition of and process for determining a wetland as “provincially significant”. In this Appendix, it is noted that some municipalities may choose to determine that other wetlands (not deemed provincially significant) are significant on a local scale and may decide to protect them. “Locally important wetlands” include wetlands that are evaluated and are not identified as provincially significant, and/or partially evaluated and unevaluated wetlands that have been confirmed as wetland habitat and mapped using the OWES methodology or interpretations of remote-sensing imagery.

The proposed revisions to the OWES manual includes the removal of all references to locally important wetlands, as well as the removal of this portion of Appendix 1.

I feel that references to locally important wetlands, including this section in Appendix 1, should be retained in the manual to allow municipal governments to protect non-PSWs and to provide clarity and direction on how these locally significant wetlands should be consistently identified.

Given that many of the proposed changes may result in lower scoring wetlands, it is important to retain references to “locally important wetlands” in the OWES to signal the importance of all wetlands and the ability of a municipality to protect non-PSWs.