We are strongly opposed to…

We are strongly opposed to the MNRF's proposed changes to the Ontario Wetland Evaluation System (OWES), as they would undermine the protection of Ontario wetlands that are so valuable to all life in Ontario. We urge you not to proceed with the proposed changes to the OWES, for the reasons outlined below.
1. Proposed changes are misguided: According to the ERO posting, the purpose of the proposed changes is to support the construction of 1.5 million new housing units over the next ten years by streamlining the wetland evaluation process. The Ontario Housing Affordability Task Force has already pointed out that a shortage of land is not the cause of the housing shortage. Houses should be built on existing available land. Most of the solution must come from densification. There is no need to pave over wetlands: in fact, wetlands must be preserved because they are vital in addressing the harmful impacts of increasingly frequent and intense rainfalls and in reducing associated flood damages and financial losses. Wetlands provide very important eco-services that we cannot afford to lose. Already, in southern Ontario, we have lost 72% of our wetlands. We must not lose any more!
2. Abandoning the recognition of wetland complexes has serious consequences. Wetland complexes typically are related in functional ways: as a group, they tend to have similar or complimentary biological, social and/or hydrological functions. Much of the wildlife in the area of the complex is variously dependent upon the presence of the entire complex of wetlands, with each wetland unit contributing to the whole. Furthermore, complexed wetlands work together to provide significant services to communities. Whereas a single wetland probably couldn't protect a town against a flood, a complex would make the town more resilient to flooding impacts.
3. The proposal to no longer recognize the presence of endangered or threatened species in the OWES process is unacceptable. Wetlands provide habitat for 20% of Ontario's species at risk. These species are valuable to the web of life. If their homes are removed by development, they will die and a link in the web will be removed. Without all of the species present, working together, the web becomes weakened and the quality of life for all species, including Humans, is diminished.
4. The quality of wetland evaluations is in jeopardy with the suggested removal of the MNRF and Conservation Authorities from the process. No central agency is being assigned to coordinate or approve evaluations or to ensure that information about PSW designation is publicly accessible. The onus would be solely on the wetland evaluator who would share the information with municipalities that do not have the expertise to assess the quality of the information.
5. As a volunteer organization that is working hard to conserve our valued natural heritage, we are opposed to the many changes that are occurring simultaneously and that all will negatively impact wetlands in Ontario. The broad scope of the changes and the haste with which they are being pushed forward is limiting our ability to provide comprehensive responses. A 30 day comment period is unacceptable to us.

In summary, Ontario's wetlands play a critical role in sustaining healthy communities, enhancing climate change resilience and conserving biodiversity. Now more than ever, we need our wetlands. We urge you NOT to proceed with the proposed changes to the OWES.