I have concerns about the…

I have concerns about the proposed changes to the Ontario Wetlands Evaluation System. Under the “Proposed Updates to the Ontario Wetland Evaluation System” (Oct 25, 2022), Conservation Authorities can no longer be used by a municipality to evaluate these lands. We have many wetlands that have not been evaluated in our headwaters area and we rely on CAs to determine which are “Provincially Significant.” If CAs can no longer do this work, who will ?. The municipalities do not have the technical expertise to do the work. Presumably, we hire consultants (at a much higher cost than having CAs help). Since wetlands do not respect municipal boundaries, we are going to end up with a confusing bag of evaluations -- say if one municipality scores something one way and another municipality on the other side of the town line scores it another way.

It is also my understanding that the scoring system for wetlands has been changed with the result that it will be more difficult to reach the “Provincially Significant” status. Also, the proposed legislative changes will no longer allow wetlands to be grouped together as wetland complexes.

The result of all of these changes will be that more wetlands will be lost to development. Your own report -- State of Ontario's Natural Resources (SONR) Report 2021 (MNRF 2021) – points out that we lost 7,303 hectares of wetlands in southern Ontario between 2011 and 2015 (pg 35). You also point out that the rate of loss between 2011 and 2015 (1,825 hectares/year) was considerably higher than the rate of loss between 2000/02 and 2011 (615 hectares/year).

The proposed changes will only exacerbate this trend.

Sincerely

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