I oppose the implementation…

I oppose the implementation of Bill 23 provisions that will significantly affect how wetlands are evaluated and considered for development in the future. This is a step backwards for the protection of these naturels areas and the prevention of future climate impacts .

The proposed changes will allow wetland units that are part of a Provincially Significant Wetland complex to be re-evaluated individually. Those units can be removed from the Provincially Significant Wetland. This leaves it up to consultants, hired by developers, to recommend if wetlands should lose protected status. Wetland boundaries could be remapped without having to re-evaluate the entire wetland. OMNRF is removed from the process, leaving all decisions in the hands of local municipalities where there may be little or no wetland expertise.
Conservation Authorities (CA’s) will be prohibited from being contracted by municipalities to comment on Acts, including the Planning Act. Most egregiously,
Endangered and Threatened species will no longer contribute to scoring as a Provincially significant . The presence of Species at Risk or their critical habitats must continue to be part of the criterion for assessing if a wetland is significant or not.

Conservation Authorities (CA’s) must tell the government which lands they own that would be suitable for housing. This is completely contrary to the reason for establishing and protecting these areas for the natural benefits they provide as well as their intrinsic value for local peoples and all communities in Ontario.

No additional permits seem to be needed if Planning Act authorization obtained, and new tools are proposed for the government to force CA’s to issue permits whether or not development meets environmental policies and environmental best practices.

Developers will be able to carve pieces out of protected wetlands and flood other areas to “compensate” the damage. As a former environmental practitioner I am aware of the challenges associated with ensuring these compensated places are actually managed in a long term way as to achieve the same goals as the areas they replace . This is by no means an assured means to replace naturally functioning significant wetlands .

Wetlands are nature’s sponge and help to protect areas downstream (like my own City of Thunder Bay) from flooding. Wetlands help to filter and improve water quality and they are critical as carbon sinks with their abundant vegetation. They remove carbon dioxide from the air and store it. If they are ditched and drained during development all that stored carbon dioxide and methane is released making climate change worse.

While I understand there is a need for increased and affordable housing I do not believe it should be at the expense of giving up the abundant natural capital that our wetlands provide . The regulations should be amène des to ensure that conservation authorities and OMNRF and their experts continue to provide input into planning decisions that balance the need to protect and maintain these areas where necessary and for the benefit of all the species these wetlands hold, and allow their continued natural functions such as flood protection.

Thanks for considering my feedback .