As an Ontario resident,…

As an Ontario resident, homeowner and taxpayer I am appalled to read your proposed changes to the OWES under the guise or "more homes built faster." Building on wetlands will not provide quality, affordable homes for anyone - nor will it help protect existing homes from increased flooding and erosion as climate change worsens.

Washing the province's hands of wetland evaluation and dropping it in the laps of developers will create major conflicts of interest where developers can simply re-evaluate a provincially-significant wetland on their property to show it can be removed. This will be made even easier if the Province follows through with removing wetland complexing and species at risk considerations from the evaluation process. Wetlands are more than individual marshes, fens or swamps - they are vast, complex hydrological systems through which water is filtered and purified, carbon is sequestered out of the air and stormwater is stored. When you remove complexing from evaluations, these critical functions will be severed, fragmented and destroyed - cutting some areas off of their critical water supply while leaving others to flood.

If it's affordability you're after, please remember that wetlands carry infinitely more economic value when they’re left alone than when they’re developed. A 2021 study from the University of Waterloo found Southern Ontario’s wetlands provide $4.2 billion worth of sediment filtration and phosphorus removal services each year, keeping drinking water sources clean and helping to mitigate harmful algae blooms. Replacing these environmental services with man-made infrastructure could cost anywhere from $2.9 billion to a staggering $164 billion annually, depending on the replacement strategy. And that's just for filtration! As a taxpayer, I find this strategy extremely short-sighted and irresponsible.

Wetlands are also the cheapest and most efficient carbon sequestration machines on the planet. By merely existing, wetlands absorb carbon out of the atmosphere and hold it in their organic soils for centuries – all for free. When a wetland is destroyed, it stops pulling carbon out of the atmosphere and its collected carbon is potentially released back into the world. Taxpayers then either foot the bill for a man-made carbon capture facility or face the rising costs of a rapidly changing climate.

Wetlands are also excellent stormwater management systems, and can dramatically reduce the impact of major floods. Given that all three levels of government paid multi-millions in emergency response costs after the 2019 floods across Ontario - most notably in the Ottawa region - your government should understand that allowing more and bigger floods through wetland degradation is not beneficial to your bottom line or to taxpayers.

The Province argues that it has an offsetting plan, but it is, so far, incomplete and undeveloped - a major concern when the Province is poised to remove wetland protections. We don't yet know who will be responsible for managing and enforcing offsetting requirements, at what ratio, or if developers will be required to offset in the same catchment, subwatershed or even watershed as the lost wetland. Cash-in-lieu options are especially concerning, as they will most severely impact areas that have already experienced drastic historic wetland loss due to urbanization.

Furthermore, offsetting should be the last resort when it comes to wetlands. The guiding principle has been, and should remain, protection first. Wetlands and all of their many interconnected natural services are next to impossible to replicate, and can take years or decades to become truly functional. It's also extremely costly - as much as $1500/sq m of created wetland. It would be cheaper for the developer to simply build somewhere else. I urge the province to reconsider this strategy and adopt a robust Protection First policy with clear guidelines on how offsetting should be applied.

On OWES generally, I implore the Province to reconsider these short-sighted and destructive proposals and give Ontario the future it deserves - one of sustainable development, liveable cities and protection from worsening climate change.

Thank you.