In reviewing the proposed…

In reviewing the proposed updates to the Ontario Wetland Evaluation System, I was deeply concerned by the removal of numerous passages in the draft. Specifically, I am troubled by:

- The removal of all mention of Conservation Authorities and working with such authorities in assessing wetlands. Local authorities would, by definition, have a better understanding of local water systems; information that would be useful in evaluating wetlands.

- The removal of re-evaluation criteria when new surveys are conducted near, or overlapping with older evaluations. As the draft itself notes, wetlands are constantly changing. Re-evaluation should be a normal procedure to reflect this fact.

-The removal of contact with other agencies as a normal part of the evaluation process. Specialized agencies and the information they can provide would only enhance the quality of a wetland evaluation. to limit consultation with such specialized bodies is to degrade the work carried out under the OWES.

- The removal of all reference to wetland complexes. Water systems are, by nature, complex. It is logical that wetlands should be considered part of the wider complexes they form, particularly as changes in one part will affect a whole system. The removal of wetland complexes as a term in the draft suggests that the new version will promote the piecemeal evaluation of wetlands without considering them in their proper context, and thus allowing the gradual dismantling of larger (and thus more ecologically important) wetland complexed.

- The removal of assessment criteria for "Reproductive Habitat for Endangered or Threatened Species," as well as for "Migration, Feeding or Hibernation Habitat for an Endangered or Threatened Species." Are these species no longer a concern of the Ministry of Natural Resources and Forestry? As these species rely on wetlands, including these considerations in the assessment criteria is vital.

- The removal of locally important wetlands from the assessment terminology. Much like the removal of local conservation authorities and wetland complexes, this omission seems to strip wetlands of their immediate context. A wetland in isolation from a complex, is just as misunderstood as a wetland divorced from its local importance.

Ultimately, these removals paint a picture of an evaluation criteria that has been significantly undermined. Local consultation and relevance has been removed. Consultation with other agencies or the consideration of migratory species has been removed. The context of complexes or local dynamics have been removed, as has the possibility of accounting for change over time. All of these omissions serve to limit the data available in the Wetland Evaluation System. It seems likely that these omissions will result in wetlands with far lower OWES scores than they would receive under the original criteria, and thus, far fewer "significant" wetlands to conserve. What is the purpose of such evaluation criteria, if it is designed to be ineffectual?