I am very concerned with the…

I am very concerned with the proposed changes to OWES, which are reckless, short-sighted, and ill-advised. The proposed changes to wetland evaluation criteria such as elimination of wetland complexing, and reduction in the area around wetlands that is regulated only serve to weaken protection of our valuable wetlands, at a time when we should be increasing their protection.
 
Wetlands provide more value to communities than any new warehouse or residential development. Wetlands absorb and retain water that would otherwise flood communities, and slowly release this water helping maintain stream flows, especially during droughts. They filter pollutants, capture sediment, and reduce erosion which improves water quality. Wetlands are a key component contributing to clean drinking water, they provide areas for recreation, tourism, and fisheries, in addition to providing habitat for wildlife and biodiversity. The value of southern Ontario wetlands is estimated to be over 4 billion dollars per year (https://doi.org/10.1002/hyp.14442). Any changes that enable the degradation or destruction of this valuable resource is extremely short-sighted and will degrade the future health and sustainability of Ontario's communities.

I am also extremely concerned with removing wetland complexes as part of the Ontario Wetland Evaluation System without any scientific justification. This proposed change fails to account for the fact that small, seemingly isolated wetlands provide critical ecological and/or hydrological functions as part of a broader natural environment system. Recent research (https://doi.org/10.1016/j.jenvman.2022.114723) indicates Ontario continues to lose small wetlands and we need stronger protections for smaller wetlands areas.

The withdrawal of MNRF as the body responsible for wetland mapping and evaluations is also concerning and should be reversed. Wetlands do not follow municipal boundaries. Impacts to upstream wetlands in one municipality has the potential to impact downstream municipalities. The MNRF is best suited to continue its encompassing role in wetland management and planning. At the very least, Conservation Authorities should replace the MNRF role, since they can at least take a watershed approach to wetlands.

Agriculture and development have already destroyed over 70% of southern Ontario's wetlands (Archived - Wetland conservation strategy | ontario.ca). Ontario’s Housing Affordability Task Force said a shortage of land isn’t the cause of the province’s housing crisis. “Land is available, both inside the existing built-up areas and on undeveloped land outside greenbelts.” Given these facts and the multitude of benefits wetlands provide to society, there is no defensible reason to reduce protections for Ontario's wetlands at this time. If anything, most wetlands, regardless of size, should be increasingly protected from development to preserve their value and services to society as a whole.

There is a clear need to roll back these proposed changes to OWES, or at the very least hold proper consultation with stakeholders to plan a sustainable way forward. I firmly believe the current proposed changes will only harm the health and sustainability of Ontario's communities and natural systems in the long term.