I am strongly opposed to the…

I am strongly opposed to the proposed changes to the Ontario Wetland Evaluation System. I view them as reckless with regard to human life and property, and showing wilful disregard for the needs of other life forms, particularly those already identified as species at risk. Humanity as a whole is the poorer when a species is lost in Ontario or, worse, is lost to the world through extinction.

I believe the proposed changes will diminish wetlands across Ontario by:
- reducing or eliminating the role of MNRF and the conservation authorities in oversight and tracking of wetland evaluations
- no longer recognizing wetland complexing
- no longer recognizing species at risk in the evaluation process
- downgrading locally significant wetlands

I do not believe the changes will assist in the construction of affordable housing close to infrastructure and accessible to public transportation.

I believe wetlands are critically important to the natural world, of which we are part and to which we owe a duty of stewardship - to migrating birds that cross the continent, to rare plants that are not able to move when habitat is lost or degraded, to our children and grandchildren and future generations that will not enjoy our unique Ontario natural heritage.

The proposed update notes that the Ontario Wetland Evaluation System has been in place since 1983. The implication is that this is an outdated document. There's no mention of updates by MNR's Wetland Evaluation Technical Team and its Biodiversity Policy Section in 1993/1994, 2002, 2008 and 2013. It is certainly incumbent on the government to keep OWES current and living. But the proposed changes will ensure it becomes increasingly detached from reality and science.

The alleged reason for the changes is to
- provide greater certainty and clarity related to how significant wetlands are assessed and identified
- allow for further streamlining of development decisions by removing the requirement for the ministry to review and confirm wetland evaluation results

Both of these reasons are spurious.

The system envisaged by the government provides less clarity, because decisions are being downloaded to municipalities while denying them the expertise of presently available from MNRF and Conservation Authorities. They will have to hire consultants at their own cost or will have to rely on the expertise of evaluators hired by development proponents, which will clearly not be independent, as is the case with MNRF and the CAs.

The idea that a decision to allow development in or near a wetland should be streamlined is alarming. Wetlands are dynamic places, the dangers they present to human occupation are many, it’s important that maximum expertise be brought to the decision-making process. There are areas of Simcoe County where insufficient caution has been exercised and residents of recently built housing struggle with flooding basements and mould. That will become more common with these irresponsible policy changes.

I oppose the practice of offsetting – there is no evidence that this is a successful strategy.

The OWES manual describes MNRF as the steward of Ontario’s natural resources, with duties that include protection and sustainable management of wetlands. Yet these changes REMOVE MNRF from that responsibility, REMOVE it from a role of oversight, and REMOVE it as a source of data. That is insane.

Species at risk – both fauna and flora are of major importance to me, and we know that wetlands are productive and essential sources of biodiversity. Their role in migration is crucial. Unfortunately the time allowed for comment does not permit me to carefully evaluate the consequences of the changes being proposed.

But I am extremely concerned. How can 30 days of public comment be sufficient for a decision of this importance? I note that the deadline for comment on a number of proposals in the Bill 23 package were extended as late as YESTERDAY, the day before the due date for comment – but not on this one, arguably the one with the longest-lasting impact on the future of our province.