Comment
I am troubled that these proposals will result in the loss of wetlands in Ontario. First according to the report Back to Basics by Dianne Saxe over 75% of wetlands have been destroyed and there is a waitlist of over 200 years to properly evaluate existing wetlands. On top of this when the borders of wetlands can be changed more easily there is no distinction of the type of wetland. Bogs and fens cannot be replaced in human lifespans and there is evidence that natural wetlands are better. I do not understand the elimination of the Wetland Evaluation Technical Team (WETT) and the Southern Wetlands Evaluation
Review Committee and the Provincial Wetlands Working Group from the manual. I am opposed to a new section Wetland Re-evaluations and Mapping Updates because wetlands in a complexed wetland should be evaluated at the same time and there should be complete evaluation (Un evaluated wetlands should be evaluated first). There are no protections against land degradation a developer could purposely damage a wetland prior to evaluation or wait for years of extreme drought. If development occurs to close to wetlands, they will not be able to follow their natural cycle of growth and shrinkage which is important for the development of plant species and removal of invasive species as well as flood mitigation. A provincially significant wetland should not be allowed to shrink in size in order to allow natural processes to occur. If anything, wetlands should grow. The elimination of references to 120 meters in bordering areas is troubling. This number is based on both scientific and takes into account political consideration as being areas where likely impacts to wetlands could occur.
A section called "A Complete Evaluation" means it would be harder to add further protections if new evidence is found that it is needed. There are no changes added to protect smaller wetlands which have been found to better reduce algae blooms
The elimination of Reproductive Habitat for Endangered or Threatened Species and Migration, Feeding or Hibernation Habitat for an Endangered or
Threatened Species is troubling because it will result in a lot of points being taken away and fails to consider how wetlands are used. This could violate Federal legislation on endangered species
The elimination of locally significant wetland is troubling
There is also concern about loss of wetlands violate international law such as Aichi targets and may violate the Ramsar Convention if any provincially significant wetlands identified as Internationally important are negatively impacted.
Please do not pass these changes.
Submitted November 1, 2022 1:41 PM
Comment on
Proposed Updates to the Ontario Wetland Evaluation System
ERO number
019-6160
Comment ID
62077
Commenting on behalf of
Comment status