The proposed revisions to…

The proposed revisions to the Wetland Evaluation System include three major changes, all of which will result in a loss of protections on wetlands.

The first proposed change is to remove the Ministry of Natural Resources and Forestry from playing a role in coordinating and reviewing wetland evaluations. Perhaps that is inevitable, given the years of funding cuts to that Ministry, leaving them with insufficient staff to manage their workload. I certainly recognize that proponent-driven evaluations exist in other areas of land development, which put a similar onus on the professionals developing the evaluations, with limited government oversight. In those cases however, there typically are professional accreditations such as P.Eng, RPF or CPA to ensure the work is done by a person with sufficient technical qualifications, and who has passed an ethics exam, to ensure that they will be acting in the public interest. If the Province wishes to move in a similar direction for wetland evaluations, then Ontario should be adopting a Registered Professional Biologist, or similar program.

The second change is the proposal removal of the section which provides points in the evaluation for Species at Risk. The proposal document correctly identifies that SAR are also addressed in the section which provides points for species considered Provincially Significant, however those features only receive a score of 50 points per species, as compared to 250 points per Species At Risk. As you are well aware, this effectively down-weights the importance of SAR. There is absolutely no excuse for this approach. By my estimate one-fifth of the species on the SARO list are wetland-dependent or wetland-obligate. Ontario has rightly been criticized in the past for their inaction in protecting species at risk; this proposal will actively reduce habitat for these species.

The third proposal is to remove the section which addressees the complexing of wetland habitats. The importance of wetlands near to or adjacent to other wetlands has been well established (e.g. Conservation Biology 12:749-758; Ecological Applications 25: 812-825 to give just two examples). Conversely the proposal to remove complexing comes with no scientific justification what so ever.

Together, its hard to read these three proposals as anything other than a cynical attempt to remove wetlands from the landscape. While I have no particular faith that this government has any interest in hearing the viewpoint of the electorate, I am taking advantage of the opportunity provided by the ERO to tell you that you should be ashamed of yourselves. Being a Conservative did not used to be synonymous with making bad decisions. Under the current government, it now certainly appears to.

If nothing else, I hope that this and similar feedback through the public consultation session gives you a sense of how much public support you have lost recently because of Bill 23, and make you think twice about what this Bill will do for the future of the party in Ontario.