As a certified Ontario…

As a certified Ontario Wetland Evaluator and wetland scientist with many years of experience evaluating wetlands and delineating wetland boundaries in Ontario, I am left dumbfounded by the currently proposed changes to the current OWES manual and instructions.

The proposed changes represent a complete disregard for wetland science and best available knowledge and progress made on the conservation of wetlands.

I need not explain here the numerous and proven benefits of preserving wetlands on the landscape. There is NO argument contrary to this fact.

The section of the OWES Manuals titled “Wetland Complexes” as well as all references to wetland complexes / complexing must be retained in the manuals. To remove complexing would certainly spell disaster for wetlands in Ontario and wetlands which do not meet the scoring criteria to be considered significant on their own. These smaller wetlands would surely be destroyed by development without provincial protection without any sort of cumulative impact analysis taking place. The implications of this change have most certainly not been fully considered, and the implications of this change have most certainly not been fully and transparently communicated to the people of Ontario. As far as I can interpret, the 700m distance for complexing is being replaced with a much smaller 30m distance. The risk of this change is considerable, particularly in areas where small wetlands dominate the landscape and development pressures are high.

Furthermore, the removal of consideration of the breeding habitat for species at risk in scoring is absurd. Species at Risk in Ontario benefit from wetland conservation and preservation and in many cases rely on wetlands for their continued survival in Ontario. These habitats are already rare causing these species to be rare. Species at Risk habitat must be considered a valued function of wetlands in Ontario and must contribute a significant portion of the scoring of a wetland under OWES. Conservation of landscapes, ecosystems, species, and ecological function depends on legislation, mechanisms, and tools that overlap and have redundancy. Removal of this redundancy is a step backwards.

A working group must be established that includes wetland scientists and OWES practitioners that have actual experience applying the OWES manual. These are the people that should be suggesting potential changes to the manual. Not people who have no idea of the ramifications of their proposed changes to the manual.

In conclusion, I do not agree with the proposed changes to the OWES manual. Once again, the changes appear to be made in favour of development in Ontario at the expense of existing wetlands and the existing people of Ontario.

At what point does the science saying 'climate crisis' get taken seriously? It is time to think about future generations instead of benefitting ones self today.