The proposed updates…

ERO number

019-6160

Comment ID

69728

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Individual

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Comment

The proposed updates indicate the removal of the Ministry of Natural Resources as a resource and final determiner of wetland significance across Ontario.
The updates look to replace the MNR’s role with vague terms such as “decision maker” and “ministry”, which leaves the position for who has the final determination of their significance up to interpretation by the reader. We find these concerning because it indicates that wetland significance will be a planning decision, made by individuals with little education on wetland significance and ecosystem function. It also opens the evaluation process to for profit consulting firms who would be evaluating wetlands, while simultaneously creating the development plans. This is extremely dangerous will lead to the erasure of wetlands from our environment.

The proposed updates implies that the only purpose for evaluating wetlands is to inform the municipality for city and county planning purposes.
Wetlands need to be evaluated for understanding ecosystem integrity, function, and conservation management, in addition to flood mapping, forecasting, and prevention. Greater weight is given to the evaluator’s judgement, and scientific rigour has been removed from the system. Wetlands are known to be some of the most complex and important ecosystems for the environment. They act as water filters and sponges and are integral to the health of all aquatic and terrestrial ecosystems in Ontario, which in turn means that they are integral to the health and wellbeing of all Ontario citizens.

The removal of wetland complexes means that many wetlands that fall into this category will no longer be recognized as Significant or even as Wetlands.
Wetlands are irreplaceable and irreplicable. Only 5% of wetlands remain from what existed pre-contact. The current systems we have in place to safeguard and protect these natural wetlands exist because of the short-sighted decision making of early settlers, and politicians alike. These wetlands, deemed significant or not need to be protected, conserved, and their place in our society needs to be maintained indefinitely for generations to come.

Proposed changes are reducing the relevance of rare and endangered species and hydrologic functions of wetlands, which are a key component of any wetland’s value, regardless of the status as Significant or not.
Changing the definition of what is classified as a wetland, and what is classified as a significant wetland will not change the role that they play in our lives, and will not change the fact that without them, thousands of homes will be flooded during large rain events, and eutrophic algae blooms will decimate lakes, their aquatic communities, and our sources of drinking water. Any proposed changes should only be made through intensive, evidence based, research and consultation with the Country's top scientists in wetland ecology, species at risk recovery, and habitat conservation.

The removal of re-evaluation based on species status change will undermine the Ontario Species at Risk Act, as will removing breeding evidence of Species at Risk and element occurrences of Species at Risk.
Wetlands are dynamic, they be and flow, they shrink and grow. With these changes comes the potential for Species at Risk to return to wetlands for habitat. A wetland which was not habitat to Species at Risk plants, animals, insects, birds, etc… could become habitat for them over time through natural succession, and through restoration efforts. These wetlands must be open for re-evaluation in order to protect the most vulnerable species in our province. We are in a global species extinction crisis, and the removal of re-evaluation will only intensify it.

Wetland evaluations can no longer be used as a tool for the MNR to manage and conserve fish and wildlife based on the information collected through the evaluation process.
This will dramatically affect the conservation of important game hunting and fishing species such as moose, deer, and popular fish species like Walleye, Lake Trout, Ling, Salmon, Rainbow Trout, and many others. All of which the province of Ontario receives large revenues from every year.

The document changes appear hurried, with much vagueness and no clear replacements for items that have been removed, particularly the MNR as resource.
There is also sloppiness, switching from imperial to metric, which further gives the impression of haste and carelessness in making the changes. Which further illustrates the governments true intentions of short-sighted interest in development, with little regard for long-term sustainability of the planet.