I am deeply concerned by the…

I am deeply concerned by the proposed changes to the Ontario Wetland Evaluation System documents and policies. As a Master of Social Work with a specialization in policy analysis and development, my professional opinion is that the proposed edits I have just reviewed will have deep negative impacts on the Evaluation System's scientific validity & its usefulness in protecting wilderness areas essential for the long-term habitability of Ontario.

Just a few of my concerns include:

a) These edits remove all Ministry of Natural Resources oversight from the process - and, in my understanding, all concepts of oversight altogether. While I understand that professional assessors have gone through specific training which qualifies them to perform their work effectively, a key aspect of any data collection & analysis process' validity is that multiple professional opinions come together before decisions are made. Researchers must submit their work for peer review before publication; the proposed changes remove the equivalent process for evaluating Ontario's irreplaceable wetlands, opening up a great deal of room for human error and subjectivity.
I am especially concerned that under the proposed changes, the Ministry would no longer have final say on the validity of wetland assessments performed anywhere in the province - and in fact, it would appear that the Ministry could be excluded from the process altogether. When decisions about land use are being made that can affect the entire province, it is not enough to trust municipalities and private interests to act without Ministry oversight.

b) These edits appear to violate fundamental landowner rights by allowing both licenced assessors and anyone in their employ to effectively trespass on private land for purposes of wetland assessment.

c) These edits appear to strike out nearly all mentions of (and, therefore, protections for) wetland complexes, and would allow wetland complexes that are not extremely compact to be intentionally 'nickel-and-dimed' away by piecemeal re-assessments of their individual importance.

d) These edits strike out a vast amount of detail which currently exists to set specific comparable standards for the assessment process. While again, I respect licenced professionals' ability to render high-quality assessments, it is vital that the requirements for provincial environmental assessment processes remain explicitly laid out and that they be followed exactly in both letter and spirit. Environmental assessments are not like talk therapy, which is very subjective and relational; environmental assessments are more akin to medical blood tests, which must be performed to exacting standards in order to render valid results.

e) These edits would allow licenced assessors to employ anyone they personally deem suitable to perform vast amounts of the labour - and therefore, the hands-on scientific data collection - provided they are willing to sign off on the results and perform the analysis. Since any evaluation is only as valid as the quality of its data, this proposed change would invite vast amounts of human error and unprofessional judgment calls into decisions about Ontario's wetlands.

I am a personal and professional advocate for affordable housing, and I am always eager for opportunities to increase the number of good-quality units available for sale and rent for families & singletons at no more than 40% of a single income at existing minimum wage. However, the potential degradation and destruction of Ontario's wetlands in pursuit of new housing developments, which these proposed changes to the Ontario Wetland Evaluation System would expedite, not only does absolutely nothing to guarantee additional affordable housing; it also carries well-documented long-term flood risks to both new and existing residential neighbourhoods by reducing wetland buffer zones during rainstorms and Extreme Weather Events.

Given known vacancy rates (30-70% in some cases) in existing Ontario housing units - due in significant part to the use of residential properties as investment capital - there is little need to develop virgin land for new housing. Please listen to well-known affordable housing citizen advocacy groups, rather than to for-profit stakeholders, when taking measures to address Ontario's housing crisis.

Thank you.