Commentaire
Poorly though out legislation on many levels.
1. The ESA is not perfect, removing SAR scoring will lead to habitat loss and species decline.
2. OWES was written with complexing in mind, removal of complexing without updating the scoring system will cause many PSWs to lose protection (I'm pretending this isn't primary goal of these changes). Could, at the very least, increase points for number/size of nearby wetlands to compensate for the change.
3. Removal of MNRF review is going to cause drift in how evaluations are conducted. Which isn't fair to the wetlands that get under evaluated, or to developers that will get less consistent results between evaluators.
4. No mention of how data will reach LIO now that there is no submission to MNRF, is it up to the evaluators to submit spatial data post evaluation? The municipalities? Is the province going to stop maintaining wetland information? How will developers know what has been evaluated in the future? This ambiguity will not "streamline development".
Soumis le 8 novembre 2022 8:47 PM
Commentaire sur
Proposition de mises à jour du Système d’évaluation des terres humides de l’Ontario
Numéro du REO
019-6160
Identifiant (ID) du commentaire
63624
Commentaire fait au nom
Statut du commentaire