Comment
I am extremely concerned about the proposed changes to the Ontario Wetland Evaluation system and I urge the government to reconsider before proceeding with these changes.
Firstly, I am concerned about the change that would see small individual wetlands evaluated separately rather than as complexes. As an ecologist, I am attuned to the interactions amongst all parts of our environment, and the study of ecology has proven time and time again that we cannot truly understand the value and functions of an organism, population, or even ecosystem (such as a wetland) in isolation - rather, we must look at each element in the context of the broader whole. Treating small wetlands individually when they are clearly connected to other nearby wetlands, both in terms of hydrology and ecology, completely disregards that wetland complexes are more than the sum of their individual parts. This will lead to devaluing of wetlands and the loss of biodiversity and valuable ecosystem services such as climate change adaptation and flood mitigation, to the detriment of the people of Ontario.
Furthermore, I am concerned that the province and even local municipalities will no longer play a meaningful role in reviewing and approving wetland evaluations. This introduces clear bias into the evaluation system when evaluators are only accountable for their evaluations to clients who often have motives that would not support the protection of wetlands. I am concerned that the province is also relinquishing its duty to maintain files, mapping and information on wetlands, as these are extremely valuable resources for the conservation of wetlands and their biodiversity and are used by many stakeholders working for the protection of wetlands in the province.
Finally, I am concerned by the potential to move away from the protection of wetlands and towards offsetting. While offsetting can be useful in certain circumstances, restoration should not be used to justify destruction of habitat or an abandonment of conservation. My training in ecology and practical experience in ecosystem restoration, along with a vast quantity of scientific literature have shown that restored ecosystems very rarely replicate original ecosystems in terms of their biodiversity and functions and even if they do achieve true restoration, this occurs on long time scale - too long to sustain species that have lost habitat in the meantime and communities that rely on their functions! Given the importance of wetlands for maintaining water quality, flood mitigation and numerous species at risk, assuming offsetting will replace naturally occurring wetlands is not a gamble worth taking!
I am grateful for the ability to provide my feedback on this matter and I urge the government to truly consider this feedback and that of many concerned citizens before moving forward with these changes.
Submitted November 24, 2022 6:30 PM
Comment on
Proposed Updates to the Ontario Wetland Evaluation System
ERO number
019-6160
Comment ID
72927
Commenting on behalf of
Comment status