Proposed Updates to the…

Proposed Updates to the Ontario Wetland Evaluation System ERO 019-6160

More housing at the expense of the environment is extremely short sighted and will result in a worsening quality of life for the people of Ontario. These amendments will benefit developers that happen to own property with a provincially significant wetland on it. Then an MZO which many people disagree with won't have to be handed out. What about the costs associated with the loss of wetlands? What about the costs associated with flooding events or the loss of ecosystem services that wetlands provide?
Clearly some of the ERO's of Bill 23 relate very closely. For some wetlands with some protection and offsetting and to follow the requirements avoid, mitigate and then offset, I would predict most developers would go straight to offset and that most municipalities would allow it. With climate change and biodiversity loss as extreme as it is, I believe offsets should not be used as the habitat for the species that depend on that wetland would be lost. Some species may be able to move to a new location but many would die out. Habitat loss is one of the main factors driving biodiversity loss. Not only do we not have the time to wait for a "new" wetland elsewhere to build biodiversity, apparently they don't function to the same degree as the original.
Wetland complexes should remain in the OWES to determine Provincially Significant Wetlands. Most wetlands are complexes. So if you remove complexes from the OWES, the majority of wetlands remaining will not be considered provincially significant and will have little protection. The Mer Bleue Bog in Ottawa is a wetland complex as well as the Oak Hammond Marsh in Manitoba and are recognized as having international significance under the Ramsar convention. Even in the original version of the OWES, it states that "delineating of the wetland units into individual ones would not be an ecologically or functionally sound process" and it also speaks of wildlife being dependent upon the entire complex. Apparently, complexes can contain a wetland unit less than 2 ha in size but the OWES does not consider individual wetlands under 2 ha however small wetlands are disappearing faster than bigger wetlands and need more protection according to a study by researchers at the University of Waterloo. In the OWES Introduction it states "If wetlands small and large cannot survive in reasonable abundance across the landscape, their dependent species will decrease in number and eventually disappear. As you want to increase biodiversity (another ERO) yet not protecting wetlands will do the opposite.
Regarding Agricultural Lands. Planting of crops and tilling land in the wetland means you shouldn't consider it a wetland but cattle pasturing or grazing means you should. Clearly then planting of crops and tilling land in a wetland should not be allowed. Most farmers would be encouraged to plant crops and use drainage with the policy as is. How does this help to filter contaminants from reaching water bodies?
Under Section 5.0, 5.1 to 5.5 have been crossed out. These are important indicators and should be included.
Locally important wetlands should remain and be protected. Wetlands are areas of high biodiversity and help deal with climate change in terms of carbon sequestrations and flooding associated with extreme rainfall events and also drought. Many have already been lost especially in southern Ontario. According to Ontario Nature, less than 30% of the original wetlands remain in southern Ontario and in the Niagara and Greater Toronto area that number drops to 10%.
The following section is crossed out in your proposal but I believe it should remain in the document.
"Nevertheless, the evaluation is not a complete biophysical inventory and certain information, particularly about the presence of rare species and about hydrological functions, may be lacking even after the evaluation is completed. If this is determined to be the case, then more information should be obtained before making decisions about the types of land uses in the vicinity of evaluated wetlands (particularly those deemed to be provincially significant."
I do not understand the section about landowner permission to carry out wetland evaluation. Who else but the landowner would request an evaluation? No one should be allowed to do a wetland evaluation of private property unless hired by the landowner.
The government of Ontario is suppose to work for the people of Ontario. Yes, addressing the housing issue is needed but it can be done without destroying the environment. Many people might not be aware of how much trouble we are in regarding climate change and biodiversity loss. I haven't figured out if this government doesn't know either or just doesn't care. How angry will people they be when they find out about things once it is too late and knowing this government actually made things worse rather than trying to deal with the real priorities of our time.