Overall we find the numerous…

Overall we find the numerous changes to this 'manual' will weaken the professional discretion of Certified Wetland Evaluators for both the Southern and Northern Ontario versions and their ability to perform acceptable, comprehensive and fair assessments.

As a consequence of downloading the notification to affected land owners of any given evaluation result solely onto Evaluators, and the numerous strike outs of MNRF as a reviewer and custodian of expertise will potentially result in untoward pressures on individual evaluators from any land owner objecting to their findings. In extreme cases it could subject the evaluator to outright intimidation.

The clauses regarding "re-evaluations" are completely retrograde and open many wetland classifications to complete incremental removal. This would appear to be the real intent of these changes, and can not be considered 'updates'.

The complete striking out of the Wetland Files section is abhorrent, bad scientific process, irresponsible and detrimental to sound government decisions on land use.

Striking out the section on assessment of breeding habitat for endangered species is a further blow to the efficacy of the Endangered Species Act and Regulations.

In total the changes give the impression that these 'updates' in whole are an attempt to neuter the effectiveness of wetland classification and make more acreage available for land speculation and infills.

Ontario can not afford the loss of any more wetland area. The province's civil infrastructure is increasingly exposed to degradation and collapse resulting in costs far outweighing the economic gain resulting from deconstructing environmental evaluation and classification.

Leave the OWES as is prior to this proposal.