I do not agree with the…

I do not agree with the proposed changes to the OWES system. As a wetland evaluator practitioner I do not believe the proposed changes will have a negative impact on the province.

Given the current state of wetland throughout the province particularly southern Ontario, many of our wetland system are heavily fragmented and subject to development pressures prior to the proposed changes to OWES. Based on the proposed changes, many of the wetland in southern Ontario will lose the current protections. The proposed approach fails to take into account that a landscape context is needed when evaluating a wetland. It is critical to evaluate a wetland in terms of its proximity to other features as many wildlife species including species at risk rely on a multitude of different upland and wetland habitats throughout the year. Many smaller wetland features are critical to provide habitat and refuge for these species as the move through the landscape. The value of many wetland come from the fact that size and composition varies within individual wetland units and it is this diversity in size and community composition and allows

Based on the proposed changes it is apparent that many wetland will loose their status of significance and will likely be subject to development pressure and degradation without the PSW classification. Wetlands big and small are a critical component of climate change mitigation and flood mitigation. We should not be undervaluing what is left for the sake of short-term gains for a select few individuals. Wetlands are critical when considering carbon sequestration and mitigating many of the effects of climate change including droughts and flooding. It is well documented that wetlands assist in buffering the impacts of flooding and allow watercourse to continue flowing during droughts. We are already seeing the impacts of these events such as the 2018 Brantford floods and they will only worsen in the coming years. With fewer protections to wetlands, the impacts of these events will only worsen.

Municipalities do not have the capacity or experience to undertake wetland evaluation. Many of our municipal staff, particularly those from smaller municipalities, do not have the breadth and depth of knowledge that our conservation authority and ministry staff possess. I fear that the loss of this understanding, breadth of experience, and knowledge will result in errors and misclassifications that will further erode our natural heritage systems. The added task of evaluating wetlands will also come at a cost to municipalities. Many municipalities do not have planning ecologist on staff that have the ability to properly re-evaluate wetlands and will either have to subcontract out work or hire additional staff. These costs will ultimately fall on tax payers. It seems both fiscally and environmentally irresponsible.